December 2019 | Version 1.2
This policy applies to you if you are:
• a visitor to our website;
• a customer who has ordered the services that we provide.
3. Personal data
Personal data includes:
• certain information that we collect automatically when you visit our website;
• certain information collected on registration (see below);
• certain information collected on submission; and
• optional information that you provide to us voluntarily (see below);
• information that has been made anonymous so that it does not identify a specific person;
• permanently de-identified information that does not relate or cannot be traced back to you specifically;
• non-personal statistical information collected and compiled by us; and
• information that you have provided voluntarily in an open, public environment or forum including any blog, chat room, community, classifieds, or discussion board (because the information has been disclosed in a public forum, it is no longer confidential and does not constitute personal information subject to protection under this policy).
Common examples of the types of personal data which we may collect and process include your:
• identifying information – such as your name, date of birth, or identification number of any kind;
• contact information – such as your phone number or email address;
• address information – such as your physical, postal or IP address, or geographic location; or
• demographic information – such as your gender or marital status.
Sensitive personal data
Depending on the goods or services that you require, we may also collect sensitive personal data including your financial information, such as your bank account details.
You must accept all the terms of this policy when you register for or use the website or any of our services. If you do not agree with anything in this policy, then you may not register for, or use the website or any of our services.
You may not access our website or register as a user if you are younger than 18 years old or do not have legal capacity to conclude legally binding contracts.
By accepting this policy, you are deemed to have read, understood, accepted, and agreed to be bound by all of its terms.
You may only send us your own personal data or the information of another data subject where you have their permission to do so.
We may change the terms of this policy at any time by updating this web page. We will notify you of any changes by placing a notice in a prominent place on the website, or by sending you an email detailing the changes that we have made and indicating the date that they were last updated. If you do not agree with the changes, then you must stop using the website and our goods and services. If you continue to use the website or our goods or services following notification of a change to the terms, the changed terms will apply to you and you will be deemed to have accepted those updated terms.
If you are a customer, those changes will apply to future service orders (including renewals and automatic renewals of existing orders). If you do not agree with the changes, you must stop using the website or the services. If you order (or renew) services following notification of a change, the changed terms will apply to you and you will be deemed to have accepted them.
Once you register on our website, you will no longer be anonymous to us. You will provide us with certain personal data.
This personal data will include:
• your name and surname;
• your email address;
• your telephone number;
• your company name, company registration number, and VAT number;
• your postal address or street address; and
• your username and password.
We will use this personal data to fulfil your account, provide additional services and information to you as we reasonably think appropriate, and for any other purposes set out in this policy.
When you order any services from us , you will be asked to provide us with additional information on a voluntary basis (services information).
We may place small text files called ‘cookies’ on your device when you visit our website. These files do not contain personal data, but they do contain a personal identifier allowing us to associate your personal data with a certain device. These files serve a number of useful purposes for you, including:
• tailoring our website’s functionality to you personally by letting us remember your preferences;
• improving how our website performs;
• allowing third parties to provide services to our website; and
• helping us deliver targeted advertising where appropriate in compliance with the applicable laws.
Third party cookies
Our website may contain electronic image requests (called a single-pixel gif or web beacon request) that allow us to count page views and to access cookies. Any electronic image viewed as part of a web page (including an ad banner) can act as a web beacon. Our web beacons do not collect, gather, monitor or share any of your personal data. We merely use them to compile anonymous information about our website.
You may also provide additional information to us on a voluntary basis (optional information). This includes content or products that you decide to upload or download from our website or when you enter competitions, take advantage or promotions, respond to surveys, order certain additional goods or services, or otherwise use the optional features and functionality of our website.
We may monitor and record any telephone calls that you make to us, unless you specifically request us not to.
Purpose for collection
We may use or process any goods information, services information, or optional information that you provide to us for the purposes that you indicated when you agreed to provide it to us. Processing includes gathering your personal data, disclosing it, and combining it with other personal information. We generally collect and process your personal data for various purposes, including:
• services purposes – such as providing our services;
• marketing purposes – such as pursuing lawful related marketing activities;
• business purposes – such as internal audit, accounting, business planning, and joint ventures, disposals of business, or other proposed and actual transactions;
• legal purposes – such as handling claims, complying with regulations, or pursuing good governance; and
• financial purposes – such as invoicing for our services.
We may use your usage information for the purposes described above and to:
• remember your information so that you will not have to re-enter it during your visit or the next time you access the website;
• monitor website usage metrics such as total number of visitors and pages accessed; and
• track your entries, submissions, and status in any promotions or other activities in connection with your usage of the website.
Consent to collection
We will obtain your consent to collect personal data:
• in accordance with applicable law;
• when you provide us with any registration information or optional information.
We may use your personal data to fulfil our obligations to you.
Messages and updates
We may send administrative messages and email updates to you about the website. We may wish to provide you with information about new goods or services in which we think you may be interested. This means that in some cases, we may also send you primarily promotional messages or technical newsletters. We will not send you promotional messages unless you have chosen to opt-into them. But, we may send you one message asking you to opt-into promotional messages without you having opted-into promotional messages. You will always have the option to opt-out of promotional messages.
We may share your personal data with:
• other divisions or companies within the group of companies to which we belong so as to provide joint content and services like registration, for transactions and customer support, to help detect and prevent potentially illegal acts and violations of our policies, and to guide decisions about our products, services, and communications (they will only use this information to send you marketing communications if you have requested their goods or services);
• our service providers under contract who help supply certain goods or help with parts of our business operations, including (but not limited to) fraud prevention, bill collection, marketing, technology services, accounting services, customer support (our contracts dictate that these goods suppliers or service providers only use your information in connection with the goods they supply or services they perform for us and not for their own benefit);
• credit bureaus to report account information, as permitted by law;
• banking partners as required by credit card association rules for inclusion on their list of terminated merchants (in the event that you utilise the services to receive payments and you meet their criteria); and
• other third parties who provide us with relevant services where appropriate.
We may disclose your personal data as required by law or governmental audit.
We may disclose personal data if required:
• by a subpoena or court order;
• to comply with any law;
• to protect the safety of any individual or the general public; and
• to prevent violation of our customer relationship terms.
We may disclose aggregate statistics (information about the customer population in general terms) about the personal data to advertisers or business partners.
We may need to disclose personal data to our employees that require the personal information to do their jobs. These include our responsible management, human resources, accounting, audit, compliance, information technology, or other personnel. Any of our employees or personnel that handle your personal data will have signed non-disclosure and confidentiality agreements.
Change of ownership
If we undergo a change in ownership, or a merger with, acquisition by, or sale of assets to, another entity, we may assign our rights to the personal data we process to a successor, purchaser, or separate entity. We will disclose the transfer on the website. If you are concerned about your personal data migrating to a new owner, you may request us to delete your personal data
We take the security of personal data very seriously and always do our best to comply with applicable data protection laws. Our hosting company will host our website in a secure server environment that uses a firewall and other advanced security measures to prevent interference or access from outside intruders. We authorize access to personal data only for those employees and certain service providers who require it to fulfil their job responsibilities. We implement disaster recover procedures where appropriate.
10. Accurate and up to date
We will try to keep the personal data we collect as accurate, complete and up to date as is necessary for the purposes defined in this policy. From time to time we may request you to update your personal data on the website. You are able to review or update any personal data that we hold on you by accessing your account online, emailing us, or phoning us. Please note that in order to better protect you and safeguard your personal data, we take steps to verify your identity before granting you access to your account or making any corrections to your personal data. Throughout your interaction with us you retain the right to rectify personal data that is incorrect or inaccurate. This does not apply if we process your personal data in our capacity as an operator or processor on behalf of a responsible party or data controller.
We will only retain your personal data for as long as it is necessary to fulfil the purposes explicitly set out in this policy, unless:
• retention of the record is required or authorised by law; or
• you have consented to the retention of the record.
During the period of retention, we will continue to abide by our non-disclosure obligations and will not share or sell your personal data.
We may retain your personal data in physical or electronic records at our discretion.
12. Transfer to another country
We may transmit or transfer personal data outside of the country in which it was collected to a foreign country and process it in that country. Personal data may be stored on servers located outside the country in which it was collected in a foreign country whose laws protecting personal data may not be as stringent as the laws in the country in which it was collected. You consent to us processing your personal data in a foreign country whose laws regarding processing of personal data may be less stringent.
13. Updating or removing
You may choose to correct or update the personal data you have submitted to us, by clicking the relevant menu in any of the pages on our website or contacting us by phone or email.
You are entitled to a right to be forgotten. We will delete any personal data that you don’t want us to have. If you do this, we will remove your personal data from our system, but we may still retain certain personal data as required or allowed by law, including:
• where we can show legitimate grounds for processing your personal data that override your request; or
• where we process your personal data in order to establish, exercise or defend legal claims.
If you are a data subject of one of our customers (who is the data controller), then you must submit your request to the relevant data controller who will then delete your personal data.
14. Data breaches
We will notify our customers of any confirmed data breaches that have occurred and which we have become aware of. It is our customers’ responsibility to notify relevant supervisory authority and any affected data subjects of the data breach.