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Privacy & Cookie Policy

 

This Privacy Policy sets out how we, [THE PLATE COMPANY UK LTD]collect, store and use information about you when you use or interact with our website, [WWW.NUMBER1PLATES.COM] (our website) and where we otherwise obtain or collect information about you. This Privacy Policy is effective from [01-05-2018][1].

 

Contents[2]

  • Summary
  • Our details
  • Information we collect when you visit our website
  • Information we collect when you contact us
  • [Information we collect when you interact with our website][3]
  • [Information we collect when you place an order [on our website]][4]
  • [Our use of automated decision-making and profiling][5]
  • How we collect or obtain information about you from third parties
  • Disclosure and additional uses of your information
  • How long we retain your information
  • How we secure your information
  • Transfers of your information outside the European Economic Area
  • Your rights in relation to your information
  • Your right to object to the processing of your information for certain purposes
  • Sensitive Personal Information
  • Changes to our Privacy Policy
  • Children’s Privacy
  • California Do Not Track Disclosures
  • Copyright, credit and logo

 

Summary[6]

This section summarises how we obtain, store and use information about you. It is intended to provide a very general overview only. It is not complete in and of itself and it must be read in conjunction with the corresponding full sections of this Privacy Policy.

  • Data controller: [THE PLATE COMPANY UK LTD][7]

 

  • How we collect or obtain information about you:
    • when you provide it to us (e.g. by contacting us [, placing an order on our website] [and]
    • from your use of our website, using cookies [and similar technologies][8],
    • [occasionally,][9] from third parties.

 

  • Information we collect: [name,] [contact details,] [payment information e.g. your credit or debit card details,] [IP address,] [information from cookies,] [information about your computer or device (e.g. device and browser type),] [information about how you use our website (e.g. which pages you have viewed,] [the time when you view them and what you clicked on,] [the geographical location from which you accessed our website (based on your IP address),] [company name or business name (if applicable),] [VAT number (if applicable),]
  • How we use your information: for administrative and business purposes (particularly to contact you [and process orders you place on our website]), [to improve our business and website,] [to fulfil our contractual obligations,] [to advertise our goods and services,] [to analyse your use of our website,] [and] [in connection with our legal rights and obligations] [and] [insert any additional ways in which you use personal information].[10]

 

  • Disclosure of your information to third parties: only to the extent necessary to [run our business,] [to our service providers,] [to fulfil any contracts we enter into with you,] [where required by law or to enforce our legal rights
  • Do we sell your information to third parties (other than in the course of a business sale or purchase or similar event): [No]

 

  • How long we retain your information: for no longer than necessary, taking into account any legal obligations we have (e.g. to maintain records for tax purposes), any other legal basis we have for using your information (e.g. your consent, performance of a contract with you or our legitimate interests as a business.For specific retention periods in relation to certain information which we collect from you, please see the main section below entitled How long we retain your information.

 

  • How we secure your information: using appropriate technical and organisational measures such as [storing your information on secure servers,][11] [encrypting transfers of data to or from our servers using Secure Sockets Layer (SSL) technology,] [encrypting payments you make on or via our website using Secure Sockets Layer (SSL) technology,] only granting access to your information where necessary [and] [insert any additional security measures you use to protect personal information such as encryption of personal data, encrypted email, pseudonymisation and/or anonymisation of personal information].

 

  • Use of cookies [and similar technologies]: [we use cookies [and similar information-gathering technologies such as [web beacons] on our website [including [essential,] [functional,] [analytical] [and] [targeting cookies]]. For more information, please visit our cookies policy here:

 

  • Transfers of your information outside the European Economic Area: [we will only transfer your information outside the European Economic Area if we are required to do so by law] OR [in certain circumstances] we [transfer] your information outside of the European Economic Area[[, including to the following countries: [insert list of countries to which you transfer information]. Where we do so, we will ensure appropriate safeguards are in place[, including [insert safeguards used for data transfers outside the European Economic Area e.g. [the third parties we use who transfer your information outside the European Economic Area have self-certified themselves as compliant with] the EU-U.S. Privacy Shield]].[12]

 

  • Use of automated decision making and profiling: We do not use] [automated decision making [and/or] profiling]. [insert description of how you use automated decision making and/or profiling in relation to your website e.g. use of web analytics, cookies, web beacons or server logs analysis tools (profiling) or use targeting cookies to display advertisements to your people who visit your website on other websites around the internet (e.g. using the Google AdSense network) (automated decision making)].

 

  • Your rights in relation to your information
    • to access your information and to receive information about its use
    • to have your information corrected and/or completed
    • to have your information deleted
    • to restrict the use of your information
    • to receive your information in a portable format
    • to object to the use of your information
    • to withdraw your consent to the use of your information
    • [not to have significant decisions made about you based solely on automated processing of your information, including profiling][13]
    • to complain to a supervisory authority

 

  • Sensitive personal information: we [do not knowingly or intentionally] collect what is commonly referred to as ‘sensitive personal information’. [Please do not submit sensitive personal information about you to us.] For more information, please see the main section below entitled Sensitive Personal Information.[14]

 

Our details

The data controller in respect of our website is [The Plate Company Uk ltd] of [Unit 1 Gordon Mills, Netherfield `Road LS20 9PD] You can contact the data controller by writing to the above. or sending an email to info@number1plates.com

[The data controller’s representative is As Above You can contact the data controller’s representative by writing to [As Above or sending an email to As Above

[The data protection officer for the data controller is As Above]. You can contact the data protection officer by writing to As Above or sending an email to As Above

If you have any questions about this Privacy Policy, please contact the data controller.

 

Information we collect when you visit our website

We collect and use information from website visitors in accordance with this section and the section entitled Disclosure and additional uses of your information.

 

Web server log information

We use a [third party][15] server to host our website Simple Servers uk LTD the privacy policy of which is available here: on their website. [Our website server automatically logs the IP address you use to access our website as well as other information about your visit such as [the pages accessed,] [information requested,] [the date and time of the request,] [the source of your access to our website),] [and] [your browser version and operating system] [and] [insert any additional information your website’s server about an individual’s visit to your website.][16]

Our server is located in the UK. please see the section of this privacy policy entitled Transfers of your information outside the European Economic Area]].[17]

 

Use of website server log information for IT security purposes

[[We do not access log data from our website server collect(s) and store(s) server logs to ensure network and IT security and so that the server and website remain uncompromised. This includes analysing log files to help identify and prevent unauthorised access to our network, the distribution of malicious code, denial of services attacks and other cyber attacks, by detecting unusual or suspicious activity.

[[Unless we are investigating suspicious or potential criminal activity,] [We/we] do not make, nor do we allow our hosting provider to make, any attempt to identify you from the information collected via server logs].][18]

Legal basis for processing: compliance with a legal obligation to which we are subject (Article 6(1)(c) of the General Data Protection Regulation).
Legal obligation: we have a legal obligation to implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk of our processing of information about individuals. Recording access to our website using server log files is such a measure.

Legal basis for processing: our and [a third party’s] legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interests: we [and our third party hosting provider] have a legitimate interest in using your information for the purposes of ensuring network and information security.
[Use of website server log information to analyse website use and improve our website

[We use the information collected by our website server logs to analyse how our website users interact with our website and its features. For example, we analyse the number of visits and unique visitors we receive, the time and date of the visit, the location of the visit [and] [the operating system and browser used] [and] [insert any additional information collected by your website server log files].]

We use the information gathered from the analysis of this information to improve our website. For example, we use the information gathered to change the information, content and structure of our website and individual pages based according to what users are engaging most with and the duration of time spent on particular pages on our website.]

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: improving our website for our website users and getting to know our website users’ preferences so our website can better meet their needs and desires.][19]

 

[Cookies and [similar technologies]]

[Cookies are data files which are sent from a website to a browser to record information about users for various purposes.

We use cookies [and similar technologies] on our website, including [[essential,] [functional,] [[analytical] [and] [targeting] cookies [and] [web beacons] [and] [insert any additional information gathering technologies you use on your website]]. For further information on how we use cookies, please see our cookies policy which is available here

You can reject some or all of the cookies we use on or via our website by changing your browser settings [or [non-essential cookies] by using our cookie control tool],[20] but doing so can impair your ability to use our website or some or all of its features. For further information about cookies, including how to change your browser settings, please visit www.allaboutcookies.org or see our cookies policy.

 

Information we collect when you contact us

We collect and use information from individuals who contact us in accordance with this section and the section entitled Disclosure and additional uses of your information.

 

Email

When you send an email to the email address displayed on our website we collect your email address and any other information you provide in that email (such as your name, telephone number and the information contained in any signature block in your email).

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).

 

Transfer and storage of your information

[Emails you send us will be stored [within] the European Economic Area on our [third party email provider’s] servers in [insert location (country) where your third party email provider stores your emails (usually where its servers are located)][21]. For further information please see the section of this privacy policy entitled Transfers of your information outside the European Economic Area.][22]

 

Contact form

When you contact us using our contact form, We also collect any other information you provide to us when you complete the contact form[, including any optional information, such as or  via your website form e.g. phone number or company name]].[23]

If you do not provide the mandatory information required by our contact form, you will not be able to submit the contact form and we will not receive your enquiry.

[If you do not supply the optional information required by our contact form, [insert consequences of an individual not providing the optional information requested by your contact form (such as phone number) e.g. we will not be able to respond to your enquiry by phone.]][24]

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).

 

Transfer and storage of your information

[Messages you send us via our contact form will be stored [within OR outside] the European Economic Area on our [third party [hosting] OR [email] provider’s] servers in [insert location (country) where your third party provider stores your emails (usually where its servers are located)]. Our third party [email] or [hosting] provider is [[insert name of third party email provider] OR [located [Their privacy policy is available here

[For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.][25]

[For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.][26]

 

[Phone[27]

When you contact us by phone, we collect your phone number and any information provide to us during your conversation with us.

[We [do not] record phone calls.][28]

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation)
Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).

 

Transfer and storage of your information

Information about your call, such as your phone number and the date and time of your call, is processed

 

Post

If you contact us by post, we will collect any information you provide to us in any postal communications you send us.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation)
Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).

 

Information we collect when you interact with our website

We collect and use information from individuals who interact with particular features of our website in accordance with this section and the section entitled Disclosure and additional uses of your information.

 

Legal basis for processing: your consent (Article 6(1)(a) of the General Data Protection Regulation).
Consent: you give your consent to us sending you our e-newsletter by signing up to receive it using the steps described above.

 

[Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: registering and administering accounts on our website to [insert purpose e.g. to provide access to content] [and facilitate the running and operation of our business.]][29]

 

Information we collect when you place an order [on our website]

We collect and use information from individuals who place an order on our website in accordance with this section and the section entitled Disclosure and additional uses of your information.

 

Information collected when you place an order

Mandatory information

When you place an order for goods or services on our website, we collect [[your name,] [email address,] [billing address,] [shipping address,] [company name (if applicable),] [VAT number (if applicable),] [and] [insert any other mandatory information you collect from customers at checkout].]

If you do not provide this information, you will not be able to purchase goods or services from us on our website or enter into a contract with us.

Legal basis for processing: necessary to perform a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: we need the mandatory information collected by our checkout form to establish who the contract is with and to contact you to fulfil our obligations under the contract, including sending you receipts and order confirmations.[30]

[Legal basis for processing: compliance with a legal obligation (Article 6(1)(c) of the General Data Protection Regulation).
Legal obligation: we have a legal obligation to issue you with an invoice for the goods and services you purchase from us where you are VAT registered and we require the mandatory information collected by our checkout form for this purpose. We also have a legal obligation to keep accounting records, including records of transactions][31]

 

Optional information

We also collect optional information from you, such as [your phone number,] [information about how you heard about us] [and] [insert any additional optional information which you collect from customers at checkout]. [We also ask you if you would like to receive marketing communications [[from us] AND/OR third parties]]. For further information, see ‘Marketing communications’ in this section below.]

[If you do not supply the optional information requested at checkout, [insert consequences of individual not providing the optional information requested by your contact form (such as phone number) e.g. we will not be able to contact you by phone.]

[Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interests: [insert the legitimate interest you have in collecting any optional information at your website checkout e.g. finding out how a customer heard about you to improve your business’ advertising methods or to be able to contact the customer by phone where (if necessary) in relation to their order][32]

[AND/OR]

Legal basis for processing: your consent (Article 6(1)(a) of the General Data Protection Regulation).
Legitimate interests: you consent to us processing any optional information you provide by submitting that information to us.][33]

 

Processing your payment

After you place an order on our website you will need to make payment for the goods or services you have ordered. In order to process your payment we use [[a third party payment processor,] OR [third party payment processors, Sage PAY & Pay Pal via an I frame gateway.

It collects, uses and processes your information, including payment information, in accordance with their privacy policies.

Legal basis for processing: necessary to perform a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: to fulfil your contractual obligation to pay for the goods or services you have ordered from us.

 

Marketing communications

At checkout you will have the option of receiving marketing communications from us.

 

[Our similar goods and services[34]

You can opt-out from receiving marketing communications in relation to our goods and which are similar to those which you purchase from us, by [insert method by which consumer may opt out from receiving communications e.g. by ticking a box to opt out or by unticking a pre-ticked box].

We will send you marketing communications in relation to similar goods and services if you do not opt out from receiving them.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interests: direct marketing and advertising our products and services.]

 

Transfer and storage of your information

[We do not use use a third party service to administer our mailing list, [

[Information you submit to subscribe for our e-newsletter will be stored [[within OR outside]] the European Economic Area on our [third party mailing list provider’s] servers in [insert location (country) where your third party email provider stores your subscribers’ information (usually where its servers are located)].][35] [For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.][36]

[Use of web beacons [and similar technologies] in emails][37]

We use technologies such as [web beacons (small graphic files)] [and] [insert any other technologies used by your third party mailing list provider] in the emails we send to allow us to assess the level of engagement our emails receive by measuring information such as the [delivery rates,] [open rates] [and] [click through rates] [and] [insert any additional information you measure about user interaction with your emails][38] which our emails achieve.] [We will only use [web beacons] [and] [insert any other tracking technologies you use] in our emails if you have consented to us doing so.]

[For more information on how we use web beacons in our emails, see our cookies policy which is available here: [insert link to cookies policy]][39]

[For more information about our third party mailing list provider and they use web beacons, please see their privacy policy which is available here: [insert link to privacy policy].][40]

 

[Our goods and services][41]

You can opt in to receiving marketing communications from us in relation to our goods and services [by [email,] [text message,] [phone,] [and/or] [post]] by [insert method by which an individual can opt in to receiving communications e.g. by ticking a box indicating that you would like to receive such communications].[42]

We will send you marketing communications in relation to our goods and services only if you opt-in to receive them.

Legal basis for processing: consent (Article 6(1)(a) of the General Data Protection Regulation).
Consent: you give your consent to us sending you information about our goods and services by signing up to receive such information in accordance with the steps described above.

 

Transfer and storage of your information

[We use a third party service to administer our mailing list, [insert name of third party provider e.g. MailChimp or Dotmailer].][43]

[Information you submit to subscribe for our e-newsletter will be stored [[within OR outside]] the European Economic Area on our [third party mailing list provider’s] servers in [insert location (country) where your third party email provider stores your subscribers’ information (usually where its servers are located)].][44] [For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.][45]

[Use of web beacons [and similar technologies] in emails][46]

We use technologies such as [web beacons (small graphic files)] [and] [insert any other technologies used by your third party mailing list provider] in the emails we send to allow us to assess the level of engagement our emails receive by measuring information such as the [delivery rates,] [open rates] [and] [click through rates] [and] [insert any additional information you measure about user interaction with your emails][47] which our emails achieve.] [We will only use [web beacons] [and] [insert any other tracking technologies you use] in our emails if you have consented to us doing so.]

[For more information on how we use web beacons in our emails, see our cookies policy which is available here: [insert link to cookies policy]][48]

[For more information about our third party mailing list provider and they use web beacons, please see their privacy policy which is available here: [insert link to privacy policy].][49]

 

[Third party goods and services][50]

[In addition to receiving information about our products and services] [You/you] can opt in to receiving marketing communications from us in relation third party goods and services [by [email,] [text message,] [phone,] [and/or] [post]] by [insert method by which an individual can opt in to receiving communications e.g. by ticking a box indicating that you would like to receive such communications].[51]

Legal basis for processing: consent (Article 6(1)(a) of the General Data Protection Regulation).
Consent: you give your consent to us sending you information about third party goods and services by signing up to receive such information in accordance with the steps described above.

Transfer and storage of your information

[We use a third party service to administer our mailing list, [insert name of third party provider e.g. MailChimp or Dotmailer].][52]

[Information you submit to subscribe for our e-newsletter will be stored [[within OR outside]] the European Economic Area on our [third party mailing list provider’s] servers in [insert location (country) where your third party email provider stores your subscribers’ information (usually where its servers are located)].][53] [For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.][54]

[Use of web beacons [and similar technologies] in emails][55]

We use technologies such as [web beacons (small graphic files)] [and] [insert any other technologies used by your third party mailing list provider] in the emails we send to allow us to assess the level of engagement our emails receive by measuring information such as the [delivery rates,] [open rates] [and] [click through rates] [and] [insert any additional information you measure about user interaction with your emails][56] which our emails achieve.] [We will only use [web beacons] [and] [insert any other tracking technologies you use] in our emails if you have consented to us doing so.]

[For more information on how we use web beacons in our emails, see our cookies policy which is available here: [insert link to cookies policy]][57]

[For more information about our third party mailing list provider and they use web beacons, please see their privacy policy which is available here: [insert link to privacy policy].][58]

 

Information collected or obtained from third parties

This section sets out how we obtain or collect information about you from third parties.

Information received from third parties

[Generally,] we do not] receive information about you from third parties. The third parties from which we receive information about you.

It is also possible that third parties with whom we have had no prior contact may provide us with information about you.

Information we obtain from third parties will generally be your name and contact details, but will include any additional information about you which they provide to us.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: where a third party has passed on information about you to us (such as your name and email address) in order for us to provide services to you, we will process your information in order to take steps at your request to enter into a contract with you and perform a contract with you (as the case may be).

Legal basis for processing: consent (Article 6(1)(a) of the General Data Protection Regulation).
Consent: where you have asked that a third party to share information about you with us and the purpose of sharing that information is not related to the performance of a contract or services by us to you, we will process your information on the basis of your consent, which you give by asking the third party in question to pass on your information to us.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interests: where a third party has shared information about you with us and you have not consented to the sharing of that information, we will have a legitimate interest in processing that information in certain circumstances.

For example, we would have a legitimate interest in processing your information to perform our obligations under a sub-contract with the third party, where the third party has the main contract with you. Our legitimate interest is the performance of our obligations under our sub-contract.

Similarly, third parties may pass on information about you to us if you have infringed or potentially infringed any of our legal rights. In this case, we will have a legitimate interest in processing that information to investigate and pursue any such potential infringement.

 

Where we receive information about you in error

If we receive information about you from a third party in error and/or we do not have a legal basis for processing that information, we will delete your information.

 

Information obtained by us from third parties

In certain circumstances (for example, to verify the information we hold about you or obtain missing information we require to provide you with a service) we will obtain information about you from certain publicly accessible sources, both EU and non-EU, such as [[the electoral register,] [Companies House,] [online customer databases,] [business directories], [media publications,] [social media,] [and] websites (including your own website if you have one) [and] [insert any additional public sources from which you collect or expect that you collect information about an individual]].[59]

In certain circumstances will also obtain information about you from private sources, both EU and non-EU, such as [insert any private sources from which you collect or expect that you collect information about an individual e.g. data brokers]

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: where you have entered into a contract or requested that we enter into a contract with you, in certain circumstances, we will obtain information about you from public sources in order to enable us to understand your business and provide services to you or services to a sufficient standard.

For example, we would obtain and/or verify your email address from your website or from a directory where you ask us to send you information by email but we do not possess the information or we need to confirm that we have recorded your email address correctly.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interests: in certain circumstances, we will have a legitimate interest in obtaining information about you from public and private sources. For example, if you have infringed or we suspect that you have infringed any of our legal rights, we will have a legitimate interest in obtaining and processing information about you from such sources in order to investigate and pursue any suspected or potential infringement.

[Legal basis for processing: consent (Article 6(1)(a) of the General Data Protection Regulation).
Consent: we may obtain information from third parties, such as data brokers, where you have consented to them sharing information with us by [insert method by which individual consent e.g. ticking a box stating that you would like your information to be share with us.]][60]

 

[Our use of automated decision-making and profiling[61]

We do not use [We do not consider that this has any legal effect on you or similarly significantly affects you.][62]

[You have the right to object to our use of automated decision making and profiling described in this section. You can do that by opting-out of cookies and similar technologies in accordance with the method described in the relevant section below. If you do not want us to process your actual IP address (usually the IP address assigned to you by your Internet Service Provider) when you visit our website, you can use a Virtual Private Network (VPN) or a free service such as Tor.]

You can find out more about our use of cookies and similar technologies (including the legal basis on which we use them) and how to opt out from them in our cookies policy, which is available here: [insert link to cookies policy]

 

[Automated decision making[63]

Automated decision making is decision making by technological means (i.e. by a machine) without human involvement.

[Use of automated decision making for [display] advertising][64]

[We automate the display advertisements containing our products and services on other websites you visit, you based on the fact that you have visited our website using cookies. For further information on the cookies we use, please see our cookies policy which is available here: [insert link to cookies policy]

Logic involved: automatically displaying advertisements to individuals who have visited our website results in increased efficiencies and costs savings for us than manually displaying advertisements or displaying advertisements by different means.

Significance and envisaged consequences: cookies will be used to recognise the fact that you have visited our website in order to display advertisements to you (unless you have blocked such cookies) and will collect information about your online behaviour.

How to object: you can block these cookies by [using the cookies control management tool on your site (if you use one)][65] [insert method of blocking cookies e.g. blocking third party cookies using browser settings, or insert specific method e.g. for Google DoubleClick, by opting out of seeing personalised ads by following the instructions here: https://support.google.com/ads/answer/2662922?hl=en-GB]. For further information, please see our cookies policy: [insert link to your cookies policy]

 

[Insert use of automated decision making][66]

[[We use automated decision making for [insert purposes for which you use automated decision making] OR [we do not use automated decision making].]

Logic involved: [insert the logic involved in you used automated decision making e.g. to increase efficiencies]

Significance and envisaged consequences: [insert the significance and envisaged consequences for the individual of your use of automated decision making]

How to object: [insert description of how individual may object i.e. stop the processing of their personal information for automated decision making purposes]

[Legal basis for processing: [insert legal basis for processing e.g. your legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).]]

[Legitimate interest: [describe your legitimate interest in the automated decision making activity (if you are relying on your legitimate interests as your legal basis for processing]]

 

Profiling

Profiling is any form of automated processing of your information to evaluate personal aspects about you, in particular to analyse or predict things like your performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.

 

[Use of profiling for web analytics

[Our web analytics service, [insert name of web analytics service e.g. Google Analytics] uses collects information such as your location (based on your IP address) and your behaviour (based on cookies) when you access our website (such as the pages you visit and what you click on) [and] [insert any other behaviours which are analysed when a user visits your website] We will only process information from cookies if you have consented to us setting cookies on your computer in accordance with our cookies policy ([insert link to cookies policy]). [Information collected about you, once collected is anonymised and stored on an aggregate basis.][67]

Logic involved: by automatically analysing and categorising information such as the location (based on IP address) as well as the behaviour and devices of visitors to our website (using cookies), we are able to gain a better understanding of what our website visitors want (in terms of the content of our website and our products), how to improve our website and how to advertise and market our services to them.

Significance and envisaged consequences: cookies will be used to track and store information about your behaviour and device on our website (unless you have opted out from receiving such cookies by [insert method of opting out from analytical cookies used on your website]) and your location will be analysed based on your IP address. [We may target advertisements based on the level of interest we receive from certain visitors and their behaviour on our website.]]

[Legal basis for processing: [insert legal basis for processing e.g. your legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).]]

[Legitimate interest: [describe your legitimate interest in the relevant profiling activity (if you are relying on your legitimate interests as your legal basis for processing]]

 

[Use of profiling in marketing emails]

[We use [[web beacons] AND/OR [insert other technologies]] in our marketing emails to analyse who opens our emails [and what actions they take (for example, what they click on)]. We will only process information from [[web beacons] AND/OR [insert other technologies you use]] if you have consented to their use in accordance with our cookies policy ([insert link to cookies policy]).

Logic involved: by analysing how our email recipients respond to our emails, we are able to improve the content and effectiveness of our emails and gauge who is most interested.

Significance and envisaged consequences: your behaviour when you open our emails will be tracked using [small gif files (web beacons)] [and] [insert any other technologies used]], including [open rates], [click through rates], [and] [insert any other information you measure about individuals in your marketing emails].

How to object: [insert method of allowing an individual to object to your use of web beacons and similar technologies e.g. contact you][68]

Legal basis for processing: legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest: [analysing the level of engagement and effectiveness of our marketing emails and content]

 

[Insert use of profiling][69]

[[We use profiling for: [insert purposes for which you use profiling]]

Logic involved: [insert the logic involved in your use of profiling e.g. to increase efficiencies]

Significance and envisaged consequences: [insert the significance and envisaged consequences for the individual of your use of profiling]

How to object: [insert description of how individual may object i.e. stop the processing of their personal information for profiling purposes]

[Legal basis for processing: [insert legal basis for processing e.g. your legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).]]

[Legitimate interest: [describe your legitimate interest in the relevant profiling activity (if you are relying on your legitimate interests as your legal basis for processing]]

 

Disclosure and additional uses of your information

This section sets out the circumstances in which will disclose information about you to third parties and any additional purposes for which we use your information.

 

Disclosure of your information to service providers

We use a number of third parties to provide us with services which are necessary to run our business or to assist us with running our business [and who process your information for us on our behalf].[70]

  • policies]

[Our third party service providers are located in [insert country in which your third party service providers are located e.g. England

Your information will be shared with these service providers where necessary to provide you with the service you have requested, whether that is accessing our website or ordering goods and services from us.

[We do not display the identities of [all of] our service providers publicly by name for security and competitive reasons. If you would like further information about the identities of our service providers, however, please contact us directly [via our contact form] or [by email] and we will provide you with such information where you have a legitimate reason for requesting it (where we have shared your information with such service providers, for example).][71]

Legal basis for processing: legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest relied on: where we share your information with these third parties in a context other than where is necessary to perform a contract (or take steps at your request to do so), we will share your information with such third parties in order to allow us to run and manage our business efficiently.

Legal basis for processing: necessary to perform a contract and/or to take steps at your request prior to entering into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: we may need to share information with our service providers to enable us to perform our obligations under that contract or to take the steps you have requested before we enter into a contract with you.

 

Disclosure of your information to other third parties

We disclose your information to other third parties in specific circumstances, as set out below.

Providing information to third parties such as [Google Inc.] [, [and] insert any other third parties to whom information is provided]. [Google collects information through our use of Google Analytics on our website. Google uses this information, including IP addresses and information from cookies, for a number of purposes, such as improving its Google Analytics service. Information is shared with Google on an aggregated and anonymised basis. To find out more about what information Google collects, how it uses this information and how to control the information sent to Google, please see the following page: https://www.google.com/policies/privacy/partners/][72]

 

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s): meeting our contractual obligations to Google under our Google Analytics Terms of Service (https://www.google.com/analytics/terms/us.html)

You can opt out of Google Analytics by installing the browser plugin here: https://tools.google.com/dlpage/gaoptout

Transfer and storage of your information

Information collected by Google Analytics is stored outside the European Economic Area on Google’s servers in the United States of America.

For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.]

 

Sharing your information with third parties, which are either related to or associated with the running of our business, where it is necessary for us to do so. These third parties include our [accountants,] [advisors,] [affiliates,] [business partners,] [independent contractors,] [and] [insurers,] [and] [insert any additional specific categories of individuals or entities with whom or which you share an individual’s personal data for managing your business]. Further information on each of these third parties is set out below.[73]

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: running and managing our business efficiently.

 

[Accountants

We share information with our accountants for tax purposes. For example, we share invoices we issue and receive with our accountants for the purpose of completing tax returns and our end of year accounts.]

d in [insert location of your advisors e.g. England].]]

 

[Affiliates

Affiliates are individuals or entities we work with to promote our business by various means, including by advertising our services on their websites, for example. Our affiliates can be in [insert the types of business or individual your affiliates are by industry, sector and sub-sector]. Affiliates will share information with us and we will share information with them where you have expressed an interest in our products or services.]

[[Our affiliates are [[insert names of affiliates] OR [industry, sector and sub-sector your affiliates are based in]. Their privacy policy is available here: [insert link to privacy policy]] OR [[Our affiliates are located in [insert location of your advisors e.g. England].]]

 

[Business partners

Business partners are businesses we work with which provide goods and services which are complementary to our own or which allow us to provide goods or services which we could not provide on our own. We share information with our business partners where you have requested services which they provide whether independently from, or in connection with or own services.]

[Our business partners are [[insert names of business partners] OR [industry, sector and sub-sector your business partners are based in]]. Their privacy policy is available here: [insert link to privacy policy]] OR [Our business partners are located in [insert location of your advisors e.g. England].]

 

[Independent contractors

[Occasionally,] we use independent contractors in our business. Your information will be shared with independent contractors only where it is necessary for them to perform the function we have hired them perform in relation to our business.]

[[Our independent contractors are [[insert names of independent contractors] OR [industry, sector and sub-sector your independent contractors are in]]. Their privacy policy is available here: [insert link to privacy policy]] OR [Our independent contractors are located in [insert location of your advisors e.g. England].]]

 

[Insurers

We will share your information with our insurers where it is necessary to do so, for example in relation to a claim or potential claim we receive or make or under our general disclosure obligations under our insurance contract with them.]

[[Our insurers are [insert name of insurers]]. Their privacy policy is available here: [insert link to privacy policy] OR [Our insurers are located in [insert location of your advisors e.g. England].]]

 

[Insert type of third party recipient of information]

[insert description of circumstances in which you will share an individual’s information with that third party recipient]

[[Our [insert name of third party recipient(s) is/are [insert name(s) of third party/third parties]]. OR [Our [insert name of third party recipient] is located in [insert location of third party recipient e.g. England].]]

 

[Sharing your information within our business’ group of companies, including [insert details of other entities in your corporate group with whom you share personal information] for internal administrative purposes, including client, customer and employee information.[74]

[Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest
: running and managing our business effectively.

AND/OR

Legal basis for processing: necessary to perform a contract [or to take steps at your request prior to entering into a contract] (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract
: we need to share your information with other companies in order to be able to meet our contractual obligations to you [or to take steps at your request prior to entering a contract.], for example because of the services or information you have requested.

[We do not display the identities of [all of] the other third parties we may share information with by name for security and competitive reasons. If you would like further information about the identities of such third parties, however, please contact us directly [via our contact form] or [by email] and we will provide you with such information where you have a legitimate reason for requesting it (where we have shared your information with such third parties, for example).][75]

 

Sharing your information with a prospective or actual purchaser or seller in the context of a business or asset sale or acquisition by us, a merger or similar business combination event, whether actual or potential.

Legal basis for processing: legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s)
: sharing your information with a prospective purchaser, seller or similar person in order to allow such a transaction to take place.

 

Disclosure and use of your information for legal reasons

 

Indicating possible criminal acts or threats to public security to a competent authority

If we suspect that criminal or potential criminal conduct has been occurred, we will in certain circumstances need to contact an appropriate authority, such as the police. This could be the case, for instance, if we suspect that we fraud or a cyber crime has been committed or if we receive threats or malicious communications towards us or third parties.

We will generally only need to process your information for this purpose if you were involved or affected by such an incident in some way.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interests: preventing crime or suspected criminal activity (such as fraud).

 

In connection with the enforcement or potential enforcement our legal rights

We will use your information in connection with the enforcement or potential enforcement of our legal rights, including, for example, sharing information with debt collection agencies if you do not pay amounts owed to us when you are contractually obliged to do so. Our legal rights may be contractual (where we have entered into a contract with you) or non-contractual (such as legal rights that we have under copyright law or tort law).

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: enforcing our legal rights and taking steps to enforce our legal rights.

 

In connection with a legal or potential legal dispute or proceedings

We may need to use your information if we are involved in a dispute with you or a third party for example, either to resolve the dispute or as part of any mediation, arbitration or court resolution or similar process.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s): resolving disputes and potential disputes.

 

For ongoing compliance with laws, regulations and other legal requirements

We will use and process your information in order to comply with legal obligations to which we are subject. For example, we may need to disclose your information pursuant to a court order or subpoena if we receive one [or to the National Crime Agency in connection with suspected or potential money laundering matters][76].

Legal basis for processing: compliance with a legal obligation (Article 6(1)(c) of the General Data Protection Regulation).
Legal obligation(s)
: legal obligations to disclose information which are part of the laws of [England and Wales][77] or if they have been integrated into the United Kingdom’s legal framework (for example in the form of an international agreement which the United Kingdom has signed).

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: where the legal obligations are part of the laws of another country and have not been integrated into the United Kingdom’s legal framework, we have a legitimate interest in complying with these obligations.

 

How long we retain your information

This section sets out how long we retain your information. We have set out specific retention periods where possible. Where that has not been possible, we have set out the criteria we use to determine the retention period.

 

Retention periods[78]

[Server log information: we retain information on our server logs for [insert period for which you retain information from server logs.]

[Order information: when you place an order for goods and services, we retain that information for six years following the end of the financial year in which you placed your order, in accordance with our legal obligation to keep records for tax purposes.][79]

Correspondence and enquiries: when you make an enquiry or correspond with us for any reason, whether [[by email] [or via our contact form] [or by phone]], we will retain your information for as long as it takes to respond to and resolve your enquiry, and for [[●] further month(s)],[80] after which point we will delete your information.

[E-Newsletter: we retain the information you used to sign up for our e-newsletter for as long as you remain subscribed (i.e. you do not unsubscribe) or if we decide to cancel our e-newsletter service, whichever comes earlier.]

[insert additional category of data stored]: [insert details of the specific retention period for additional category of data][81]

 

Criteria for determining retention periods

In any other circumstances, we will retain your information for no longer than necessary, taking into account the following:

  • [the purpose(s) and use of your information both now and in the future (such as whether it is necessary to continue to store that information in order to continue to perform our obligations under a contract with you or to contact you in the future);
  • whether we have any legal obligation to continue to process your information (such as any record-keeping obligations imposed by relevant law or regulation);
  • whether we have any legal basis to continue to process your information (such as your consent);
  • how valuable your information is (both now and in the future);
  • any relevant agreed industry practices on how long information should be retained;
  • the levels of risk, cost and liability involved with us continuing to hold the information;
  • how hard it is to ensure that the information can be kept up to date and accurate; and
  • any relevant surrounding circumstances (such as the nature and status of our relationship with you).][82]

 

How we secure your information[83]

We take appropriate technical and organisational measures to secure your information and to protect it against unauthorised or unlawful use and accidental loss or destruction, including:

  • only sharing and providing access to your information to the minimum extent necessary, subject to confidentiality restrictions where appropriate, and on an anonymised basis wherever possible;
  • [using secure servers to store your information];[84]
  • verifying the identity of any individual who requests access to information prior to granting them access to information;
  • [using Secure Sockets Layer (SSL) software to encrypt [any information you submit to us via any forms on our website] [and] [any payment transactions you make on or via our website];][85]
  • [only transferring your information via closed system or encrypted data transfers;] [and]
  • [insert any additional methods you use to ensure the security of personal information e.g. other technological measures or pseudonymisation.]

 

Transmission of information to us by email

Transmission of information over the internet is not entirely secure, and if you submit any information to us over the internet (whether by email, via our website or any other means), you do so entirely at your own risk.

We cannot be responsible for any costs, expenses, loss of profits, harm to reputation, damages, liabilities or any other form of loss or damage suffered by you as a result of your decision to transmit information to us by such means.[86]

 

Transfers of your information outside the European Economic Area[87]

[All of your information is stored in the following European Economic Area (EEA) countries [country/countries]: [insert EEA countries in which you store individuals’ information].

Other than to comply with any legal obligations to which we are subject (compliance with a court order, for example), we do not intend to transfer your information outside the EEA or to an international organisation. In the unlikely event that we are required to transfer your information outside the EEA (or to an international organisation) for such a purpose, we will ensure appropriate safeguards and protections are in place.

OR

[Your information will be transferred and stored outside the European Economic Area (EEA) in the circumstances set out below. We will also transfer your information outside the EEA or to an international organisation in order to comply with legal obligations to which we are subject (compliance with a court order, for example). Where we are required to do so, we will ensure appropriate safeguards and protections are in place.][88]

 

[Server log information

[Information collected when you visit our website is transferred outside of the EEA and stored on the servers of our [third party hosting company[, insert name of third party hosting company]. You can access their privacy policy here: [insert link to privacy policy].]

[Country of storage: [insert the country or countries where the relevant servers which collect information in relation to your website are located and where the information is stored]. This country [is/is not] subject to an adequacy decision by the European Commission.][89]

Safeguard(s) used: [our third party hosting provider has self-certified its compliance with the EU-U.S. Privacy Shield] OR [insert other safeguard which your third party hosting company uses to transfer information to a country which is outside the EEA (see Appendix 1 for the full list)] [which is available [here: [insert link to the safeguards used] OR [insert means of obtaining a copy of the safeguard]].[90]

 

[Contact form

[Information you submit to us via our contact form is transferred outside the EEA and stored on our third party [[hosting] OR [email] OR [insert entity which stores information submitted by your contact form] provider’s servers. Our [insert type of third party provider (hosting provider, email provider)] is [insert name of third party provider]. You can access their privacy policy here: [insert link to privacy policy].]

[Country of storage: [insert the country or countries where the relevant servers which collect information in relation to your website are located and where the information is stored]. This country [is/is not] subject to an adequacy decision by the European Commission.][91]

Safeguard(s) used: [our [[third party hosting provider] OR [third party email provider] OR [insert entity which stores information submitted by your contact form]] has self-certified its compliance with the EU-U.S. Privacy Shield] OR [insert other safeguard which your third party hosting company uses to transfer information to a country which is outside the EEA (see Appendix 1 for the full list)] [which is available [here: [insert link to the safeguards used] OR [insert means of obtaining a copy of the safeguard]].[92]

 

[Email

[Information you submit to us by email is transferred outside the EEA and stored on our third party email provider’s servers. Our third party email provider is: [insert name of third party email provider]. You can access their privacy policy here: [insert link to privacy policy].]

[Country of storage: [insert the country or countries where the relevant servers which collect information in relation to your website are located and where the information is stored]. This country [is/is not] subject to an adequacy decision by the European Commission.][93]

Safeguard(s) used: [our [third party email provider] OR [insert entity which stores information submitted by your contact form]] has self-certified its compliance with the EU-U.S. Privacy Shield] OR [insert other safeguard which your third party hosting company uses to transfer information to a country which is outside the EEA (see Appendix 1 for the full list)] [which is available [here: [insert link to the safeguards used] OR [insert means of obtaining a copy of the safeguard]].[94]

 

[E-Newsletter

[Information you submit to us when you sign up for our e-newsletter is transferred outside the EEA and stored on our third party mailing list provider’s servers. Our third party mailing list provider is: [insert name of third party mailing list provider]. You can access their privacy policy here: [insert link to privacy policy].]

[Country of storage: [insert the country or countries where the relevant servers which collect information in relation to your website are located and where the information is stored]. This country [is/is not] subject to an adequacy decision by the European Commission.][95]

Safeguard(s) used: [our [third party mailing list provider] has self-certified its compliance with the EU-U.S. Privacy Shield] OR [insert safeguards used to transfer information to a country which is outside the EEA (see Appendix 1 for the full list)] [which is available [here: [insert link to the safeguards used] OR [insert means of obtaining a copy of the safeguard]].[96]

 

[Google Analytics

[Information collected by Google Analytics (your IP address and actions you take in relation to our website) is transferred outside the EEA and stored on Google’s servers. You can access Google’s privacy policy here: https://www.google.com/policies/privacy/

[Country of storage: United States of America. This country is not subject to an adequacy decision by the European Commission.][97]

Safeguard(s) used: Google has self-certified its compliance with the EU-U.S. Privacy Shield which is available here: https://www.privacyshield.gov/welcome. The EU-U.S. Privacy Shield is an approved certification mechanism under Article 42 of the General Data Protection Regulation, which is permitted under Article 46(2)(f) of the General Data Protection Regulation. You can access the European Commission decision on the adequacy of the EU-U.S. Privacy Shield here: http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm

 

[Insert additional data collection method or use e.g. information outside the EEA by payment processors][98]

[Information you submit to us by [insert method individual uses to submit information to you] is transferred outside the EEA] and stored on our [insert type of third party] servers. Our [insert type of third party provider e.g. email provider] is: [insert name of third party provider]. You can access their privacy policy here: [insert link to privacy policy].]

[Country of storage: [insert the country or countries where the relevant servers which collect information in relation to your website are located and where the information is stored]. This country [is/is not] subject to an adequacy decision by the European Commission.][99]

Safeguard(s) used: [our [insert third party provider for data collection and use] has self-certified its compliance with the EU-U.S. Privacy Shield] OR [insert safeguards used to transfer information to a country which is outside the EEA (see Appendix 1 for the full list)] [which is available [here: [insert link to the safeguards used] OR [insert means of obtaining a copy of the safeguard]].[100]

 

Your rights in relation to your information

Subject to certain limitations on certain rights, you have the following rights in relation to your information, which you can exercise by writing to [insert address] [or sending an email to [insert email address]]:

  • to request access to your information and information related to our use and processing of your information;
  • to request the correction or deletion of your information;
  • to request that we restrict our use of your information;
  • to receive information which you have provided to us in a structured, commonly used and machine-readable format (e.g. a CSV file) and the right to have that information transferred to another data controller (including a third party data controller);
  • to object to the processing of your information for certain purposes (for further information, see the section below entitled Your right to object to the processing of your information for certain purposes); and
  • to withdraw your consent to our use of your information at any time where we rely on your consent to use or process that information. Please note that if you withdraw your consent, this will not affect the lawfulness of our use and processing of your information on the basis of your consent before the point in time when you withdraw your consent.
  • [the right not to be subject to a decision based solely on automated processing, including profiling which produces legal affects concerning you or similarly significantly affects you][101]

In accordance with Article 77 of the General Data Protection Regulation, you also have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or of an alleged infringement of the General Data Protection Regulation.

For the purposes of the UK, the supervisory authority is the Information Commissioner’s Office (ICO), the contact details of which are available here: https://ico.org.uk/global/contact-us/

 

Further information on your rights in relation to your personal data as an individual

The above rights are provided in summary form only and certain limitations apply to many of these rights. For further information about your rights in relation to your information, including any limitations which apply, please visit the following page on the ICO’s website:

You can also find out further information about your rights, as well as information on any limitations which apply to those rights, by reading the underlying legislation contained in Articles 12 to 22 and 34 of the General Data Protection Regulation, which is available here: http://ec.europa.eu/justice/data-protection/reform/files/regulation_oj_en.pdf

 

Verifying your identity where you request access to your information

Where you request access to your information, we are required by law to use all reasonable measures to verify your identity before doing so.

These measures are designed to protect your information and to reduce the risk of identity fraud, identity theft or general unauthorised access to your information.

 

How we verify your identity

Where we possess appropriate information about you on file, we will attempt to verify your identity using that information.

If it is not possible to identity you from such information, or if we have insufficient information about you, we may require original or certified copies of certain documentation in order to be able to verify your identity before we are able to provide you with access to your information.

We will be able to confirm the precise information we require to verify your identity in your specific circumstances if and when you make such a request.

 

Your right to object to the processing of your information for certain purposes

You have the following rights in relation to your information, which you may exercise in the same way as you may exercise by writing to [insert address] [or sending an email to [insert email address]]:

  • to object to us using or processing your information where we use or process it in order to carry out a task in the public interest or for our legitimate interests, including ‘profiling’ (i.e. analysing or predicting your behaviour based on your information) based on any of these purposes; and
  • to object to us using or processing your information for direct marketing purposes (including any profiling we engage in that is related to such direct marketing).

You may also exercise your right to object to us using or processing your information for direct marketing purposes by:

  • clicking the unsubscribe link contained at the bottom of any marketing email we send to you and following the instructions which appear in your browser following your clicking on that link;
  • [sending an SMS message containing only the words “OPT OUT” in reply to any marketing communication we send by text message;][102] [or]
  • sending an email to [insert email address], asking that we stop sending you marketing communications or by including the words “OPT OUT”.

For more information on how to object to our use of information collected from cookies and similar technologies, please see the section entitled How to accept or reject cookies in our cookies policy, which is available here: [insert link to your cookies policy]

 

Sensitive Personal Information

‘Sensitive personal information’ is information about an individual that reveals their racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic information, biometric information for the purpose of uniquely identifying an individual, information concerning health or information concerning a natural person’s sex life or sexual orientation.

[We do not knowingly or intentionally collect sensitive personal information from individuals, and you must not submit sensitive personal information to us.

If, however, you inadvertently or intentionally transmit sensitive personal information to us, you will be considered to have explicitly consented to us processing that sensitive personal information under Article 9(2)(a) of the General Data Protection Regulation. We will use and process your sensitive personal information for the purposes of deleting it.]

OR

[insert details of the sensitive personal information you collect about individuals, how you collect it, what you use it for and the legal basis on which you process it.][103]

 

Changes to our Privacy Policy

We update and amend our Privacy Policy from time to time.

 

Minor changes to our Privacy Policy

Where we make minor changes to our Privacy Policy, we will update our Privacy Policy with a new effective date stated at the beginning of it. Our processing of your information will be governed by the practices set out in that new version of the Privacy Policy from its effective date onwards.

 

Major changes to our Privacy Policy or the purposes for which we process your information

Where we make major changes to our Privacy Policy or intend to use your information for a new purpose or a different purpose than the purposes for which we originally collected it, we will notify you by email (where possible) or by posting a notice on our website.

We will provide you with the information about the change in question and the purpose and any other relevant information before we use your information for that new purpose.

Wherever required, we will obtain your prior consent before using your information for a purpose that is different from the purposes for which we originally collected it.

 

Children’s Privacy

Because we care about the safety and privacy of children online, we comply with the Children’s Online Privacy Protection Act of 1998 (COPPA). COPPA and its accompanying regulations protect the privacy of children using the internet. We do not knowingly contact or collect information from persons under the age of 18. The website is not intended to solicit information of any kind from persons under the age of 18.

It is possible that we could receive information pertaining to persons under the age of 18 by the fraud or deception of a third party. If we are notified of this, as soon as we verify the information, we will, where required by law to do so, immediately obtain the appropriate parental consent to use that information or, if we are unable to obtain such parental consent, we will delete the information from our servers. If you would like to notify us of our receipt of information about persons under the age of 18, please do so by sending an email to [insert email address].

 

California Do Not Track Disclosures

“Do Not Track” is a privacy preference that users can set in their web browsers. When a user turns on a Do Not Track signal in their browser, the browser sends a message to websites requesting that they do not track the user. For information about Do Not Track, please visit www.allaboutdnt.org

[We respond to Do Not Track browser settings or signals by [insert details of how you recognise and respond to Do Not Track browser settings]] OR [[At this time, we do not respond to Do Not Track browser settings or signals. [In addition, we use other technology that is standard to the internet, such as pixel tags, web beacons, and other similar technologies, to track visitors to the website. Those tools may be used by us and by third parties to collect information about you and your internet activity, even if you have turned on the Do Not Track signal.] For information on how to opt out from tracking technologies used on our website, see our cookies policy which is available here: [insert link to cookies policy]][104]

 

Copyright, credit and logo

This Privacy Policy is based on a General Data Protection Regulation (Regulation (EU) 2016/769) (GDPR) compliant template provided by GDPR Privacy Policy. For further information, please visit https://gdprprivacypolicy.org

The copyright in this Privacy Policy is either owned by, or licensed to, us and is protected by copyright laws around the world and copyright protection software. All intellectual property rights in this document are reserved.

Where we display the GDPR Privacy Policy logo on our website, this is used to indicate that we have adopted a privacy policy template provided by GDPR Privacy Policy as the basis for this Privacy Policy.

 

 

[1] You must insert the effective date of your privacy policy so your website users know when your privacy policy takes effect. If you have not previously uploaded a privacy policy to your website, or if you are replacing your existing privacy policy with this privacy policy, the effective date will be the date when you first upload this privacy policy to your website.

[2] When you upload this privacy policy to your website, at a minimum, you should ensure that the titles in this “Contents” section link to the relevant headings in the main body of the privacy policy. For instance, the “Our details” title in this “Contents” section should link to the “Our details” heading in the main body of the privacy policy. An alternative and highly recommended way of ensuring your privacy policy meets the clear and accessible requirements of the General Data Protection Regulation is to use drop down boxes for each section of the privacy policy which expand and show the information in that section when clicked on. This allows a user to easily access the information they are interested in quickly and effectively.

[3] Include this section if your website contains any particular functionality that collects information from users only if they specifically interact with it e.g. newsletters, registration forms and live chat functionality. Suggested text for some of these common functionalities is included in the main section below.

[4] Delete this bullet point from the Contents section if your website is not an ecommerce website and there is no method of placing an order for goods or services (if you have a purely information based brochure style website, for example). If you take payments by other means (e.g. card payments over the phone for instance) you will need to amend this section accordingly to include the relevant information about how you take payments, the information you collect and the payment providers you use.

[5] Where you use ‘automated decision-making’ or ‘profiling’, you must disclose this in your privacy policy. For information on what constitutes automated decision-making and profiling, see the footnote to the main section of this privacy policy entitled ‘Our use of automated decision making and profiling’.

[6] This summary section is designed to meet the GDPR’s requirement for a privacy policy to be in a concise, transparent, intelligible and easily-accessible form and uses the ICO’s suggestion of adopting a layered approach in order to achieve this. The individual can then look at the corresponding section in the main body of the privacy policy if they require more information on any particular aspect of your privacy policy. If you use an individual’s personal data in a way they would not reasonably expect, you must ensure that you bring it to their attention in this summary section. The summary section can be contained in or separated from the rest of the privacy policy and inserted above it (with the rest of the full privacy policy below) to draw the summary section more clearly to the user’s attention.

[7] The data controller is the person responsible for deciding the purposes for which personal information is processed (i.e. used) and the means by which such processing is done. In the vast majority of cases, this will be the company (if your business is a company) or you, the sole trader (if you run your business as a sole trader) which owns and runs the website and is therefore the same person or entity set out at the beginning of the privacy policy. You will normally be aware of who the data controller is if another person or entity is responsible for this role. If you are unsure about who the data controller is, you should seek appropriate professional advice. If you are a data controller and you have not already registered with the Information Commissioner’s Office, you must do so.

[8] Include this wording if you use other information collecting technologies on or in relation to your website e.g. web beacons (small gif files) on your website or in your marketing emails. You will need to fully describe the use of such technologies in your cookies policy and in the section entitled ‘Our use of automated decision making and profiling’ and obtain explicit consent for the use of such technologies from your users before you use them.

[9] Include the word ‘occasionally’ if you only occasionally receive information from third parties (i.e. the nature of your business does not involve the regular receipt of information about individuals from third parties). If you regularly receive information from third parties you should delete the word occasionally, and include (wherever possible) the names of the specific third parties from whom you regularly receive information about individuals. If it is not possible to identify individual third parties by name, you should identify them by the nature of the source including the following information: (i) the type of organisation, industry and sector; and (ii) whether the information was held in or outside the EU. In either case, you should indicate whether the source was public or private.

[10] Here you should summarise the purposes for which you use information about individuals.

[11] Include this section if the servers on which you store personal information are secure. Amongst other obligations, you are required to put in place appropriate technical and organisational measures to minimise the risk of loss, corruption, damage and unauthorised access to personal information. If your servers are not secure, you will need to migrate your website hosting to secure servers in order to meet this legal requirement.

[12] Where you transfer personal information outside the European Economic Area (EEA), you must ensure appropriate safeguards are in place before you make such a transfer. For further information on such safeguards please see the full section entitled ‘Transfers of your information outside the European Economic Area’.

[13] Include this right if you use automated decision making which has legal or other significant effects on an individual. Use of typical online advertising (e.g. remarketing advertisements) will not, for most businesses, be considered to have a significant effect on an individual (e.g. if you target advertisements to individuals who visit your website) but it depends on the circumstances and nature of the advertisements and your business. There is no exhaustive list of factors to take into account in determining whether something will have a significant effect on an individual but the following are relevant: (i) how intrusively you have profiled individuals to target your advertisements (e.g. complex combinations of profiling criteria); (ii) what the individuals who are receiving the advertisements would expect or want; (iii) the method of delivery of the advert; and (iv) the particular vulnerabilities of the individuals in question. An example of where online advertising could have a significant effect would be if a gambling company targeted adverts at someone who was in financial difficulties.

[14] This privacy policy template envisages that you do not collect ‘sensitive personal information’ about individuals and is designed to deal with a situation where such information is accidentally or intentionally submitted by a website user to you. Sensitive personal information is information which reveals an individual’s racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership, genetic information, biometric information, information about an individual’s health or sex life or sexual orientation. If your business does collect sensitive personal information the requirements for processing such information are very strict (for example you will usually require the individual’s explicit consent) and you should seek appropriate legal advice.

[15] Include the word third party if you do not host your website on your own server (i.e. a server owned and managed by you). In the vast majority of cases, your website will be hosted on a third party server, either on a shared (i.e. used by other websites) or dedicated (i.e. used only to host your own website) basis. If you do not have the relevant information already, you should independently confirm for yourself who your third party website hosting provider is, that they will be compliant with the GDPR and in particular that they store information securely using appropriate technical and organisational measures to protect the information stored on their servers. You will also need to enter into a data processing agreement with your hosting company if they fall under the definition of a ‘data processor’ under the GDPR (i.e. someone who processes personal data on your behalf (with you as the data controller). Whether or not your website hosting company is a data processor will depend on your individual circumstances and relationship with them but hosting companies are very often considered data processors for data controllers. The details of the requirements for data processing agreements are complex and unfortunately beyond the scope of the guidance in this privacy policy, but such agreements must satisfy the requirements of Article 28 of the GDPR at a minimum. You should speak with your website hosting company to confirm what steps they are taking to prepare for GDPR and analyse the nature of your relationship with them to determine whether or not they are a data processor or data controller. If you determine that they are a data controller, you will need to determine whether you and they are joint data controllers in respect of the data you both process, in which case you will need to enter into a joint data controller agreement to determine your respective responsibilities. You can find out more about the difference between data processors and data controllers in the ICO’s guidance which is available here: https://ico.org.uk/media/for-organisations/documents/1546/data-controllers-and-data-processors-dp-guidance.pdf.

[16] You should amend, delete and add to any information your server collects about websites visitors. If you are unsure about the information collected by your server, you should contact your hosting provider. You also need to find out from your hosting provider how long they keep information collected by their servers (i.e. the retention period) and include this in the section of your privacy policy entitled ‘How long we retain your information

[17] Include the second half of this sentence if your website’s server is based in a country which is outside the European Economic Area. You will also need to complete the relevant sections in the section of this privacy policy entitled ‘Transfers of your information outside the European Economic Area.

[18] Include this paragraph if you do not attempt to identify individuals from your website server logs or if you only attempt to identify them when investigating suspicious or potentially criminal activity, as appropriate.

[19] Include this section if you analyse your website server log information. If you do, you should make any amendments that are appropriate, such as amending the types of information you analyse and how you analyse and use it if they differ from the common types of information and uses already described in this section.

[20] Express consent will be required to place non-essential cookies on users’ devices from 25 May 2018 onwards so you will need to install a cookie control solution on your website to allow users to accept and manage non-essential cookies, ideally by individual cookie in order to meet the GDPR’s requirements for ‘granular’ consent (i.e. that a user can consent to setting precisely which cookies they want rather than being forced to accept all cookies in order to accept the cookies they want). One potential solution, currently used by the ICO itself, is Cookie Control by Civic. You can find out more information about that solution here: https://www.civicuk.com/cookie-control

[21] You need to state where you store individuals’ personal information, in particular whether it is stored within or outside the European Economic Area. If you (or your third party email provider) store emails outside the European Economic Area, you will also need to complete and provide the relevant information in the section of this privacy policy below entitled ‘Transfers of your information outside the European Economic Area’ and indicate the safeguards you use to transfer personal information outside the EEA.

[22] Include this sentence if your email provider stores emails outside of the European Economic Area (you will need to confirm with your email provider where they store your emails if you do not already know this information).

[23] You should include any optional information that a user can submit via your contact form (i.e. optional (as opposed to mandatory) fields). Note that the principle of data minimisation requires that you do not collect more information than is required so only information that is strictly necessary to collect (such as name and email address) should be mandatory. Any information which is not strictly necessary for you to be able to respond to an enquiry, should be an optional field. You may want to include a phone number as an optional field if you prefer to respond to enquiries you receive by phone (or make phone number the mandatory field and email the optional field). Where you have any optional fields on the contact form, these should be clearly marked as optional and distinguished from mandatory fields e.g. by marking mandatory fields with a red asterisk and inserting the word optional in square brackets after optional fields e.g. Phone (optional).

[24] Include this sentence if it is possible to insert optional information in your contact form. You should also explain at the ‘point of collection’ (i.e. on or around the contact form itself) what the consequences of not providing a particular piece of information are (e.g. the consequences of not providing a phone number) next to the appropriate field on the contact form.

[25] Include this paragraph if information submitted via your contact form is stored outside the European Economic Area (e.g. because your website’s server is located in a country outside the European Economic Area). You will also need to complete the relevant sections in the section of this privacy policy entitled ‘Transfers of your information outside the European Economic Area’ below and indicate the safeguards you use to transfer personal information outside the EEA.

[26] Include this paragraph if information submitted via your contact form is stored outside the European Economic Area (e.g. because your website’s server is located in a country outside the European Economic Area). You will also need to complete the relevant sections in the section of this privacy policy entitled ‘Transfers of your information outside the European Economic Area’ below and indicate the safeguards you use to transfer personal information outside the EEA.

[27] This section is designed to deal with situations where you receive phone calls e.g. because you have made a phone number available on your website for customers to contact you. If you do not have a phone number available on your website, we would still recommend retaining this section as it is possible or even likely that you will collect information about individuals in the course of business (e.g. suppliers) or because individuals have otherwise obtained your phone number. This section also assumes that your telephone provider does not transfer personal information outside the EEA. If they do transfer the information they collect in relation to phone calls, however, you will need to ensure appropriate safeguards are in place. For further information, please see the section entitled ‘Transfers of your information outside the European Economic Area’.

[28] It is recommended that you make it clear about whether you record or do not record phone calls. This privacy policy assumes that you do not record phone calls (as most businesses do not do so) and recorded phone calls are beyond the scope of this privacy policy. If you do record calls, you will need to obtain appropriate advice on how to ensure that your recording of phone calls complies with the law, including the Telecommunications (Lawful Business Practice) (Interception of Communications) Regulations 2000 (SI 2000/2699) (the ‘Lawful Business Regulations’) and the Regulation of Investigatory Powers Act 2000 (‘RIPA’), including making the appropriate disclosures at the beginning of your call and on your website (i.e. by inserting the wording ‘calls may be recorded’ next to your telephone number wherever it appears on your website) and explaining why you record calls in your privacy policy.

[29] The legal basis on which you process information to register an account on your website will vary depending on the nature of your website and the purposes of registration. If a user needs to register an account on your website following a purchase they make, the basis on which you process their information will be to perform a contract with them. If a user can register on your website without the need to purchase anything (e.g. to gain access to information such as a report), the basis on which you will process their data will be your legitimate interests. You should amend the wording of these provisions, as necessary, to describe why it is necessary for an individual to register an account on your website.

[30] You should ensure that you do not collect any more information than necessary at checkout. If you do collect any information at checkout which is not essential, you should ensure that it is clearly marked as optional. Mandatory information should be marked with a red asterisk or the word required should be included after it.

[31] Include this provision if you are VAT registered. If you are not VAT registered, you should delete it.

[32] As optional information is, by its definition, not strictly required to perform a contract, you will need another legal basis for processing it. You should therefore consider either consent or your legitimate interests. ‘How someone heard about you’ is not likely to be personal information per se but it could be used to identify someone in combination with other information (particularly other information you store about them on your website). We would suggest relying on your legitimate interests where possible and consent if you cannot find a convincing legitimate interest for collecting the information.

[33] If you are unable to justify the reason for collecting any additional information (which is personal information i.e. can be used to identify someone in combination with other information)) i.e. you cannot establish a legitimate interest for doing so, you will need to rely on consent. We would strongly recommend and advise not to collect any more personal information than you need to.

[34] This paragraph should be inserted if you use the ‘soft opt-in’, a very specific provision which allows you to market your own goods and services which are similar to those which the individual has purchased from you, provided that you have given them the chance to opt out at the time (i.e. with a tick box) and in each subsequent communication with them (i.e. with an unsubscribe link at the bottom of every email you send them). This is a very specific provision and if you use it, it is important to emphasise that you can only market goods and services which are: (i) your own (i.e. not third parties’); and (ii) similar to the goods or services which the individual purchased at the time. Because of the limitation on what you can market to individuals (i.e. not necessarily all of your goods and services), you may prefer to rely on opt-in consent (i.e. the section below entitled ‘Our goods and services’) which will allow you to market any of your goods and services to individuals.

 

Wording for the soft opt-in: If you do want to use the soft opt-in, the wording you will need to use will depend on whether you use a pre-ticked box or a non-ticked opt out box (or another appropriate method, although these are the most common). In the case of the former, the wording used should be: ‘I would like to receive information about your similar products and services by email’. In the latter case, the wording should be: ‘Tick here if you do not want to receive information about our similar products and services by email’ or ‘I do not want to receive information about your similar products and services by email’. The words ‘by email’ should be included if the only way you intend to send marketing communications to individuals is by email. If you intend to individuals marketing communications by other methods, you will need to provide for these individual methods by creating the appropriate tick boxes e.g. by email, by post, by text, by phone etc at the time of checkout.

 

[35] You need to state where your third party mailing list provider stores your subscribers’ information, and, in particular, whether it is stored inside or outside the European Economic Area (EEA).

[36] Include this paragraph if the information about individuals on your mailing list (i.e. their names and email addresses etc.) are stored outside the European Economic Area (e.g. because your mailing list provider stores the information on servers outside the EEA or because you store the information outside the EEA). You will also need to complete the relevant sections in the section of this privacy policy entitled ‘Transfers of your information outside the European Economic Area’ below and indicate the safeguards used to transfer personal information outside the EEA (e.g. because your third party provider has self-certified its compliance with the EU-U.S. Privacy Shield (if that is the safeguard it uses). You will need to confirm with your third party email provider what safeguards they use if you do not already know this information).

[37] This section is designed to cover off any web beacons or similar technologies you use in your marketing emails to measure information such as open rates and click through rates. Please note that you will need to gain explicit consent to use web beacons in your marketing emails. If you cannot get such consent, you must not use web beacons in you marketing emails. For further information, please see the footnotes to the section entitled ‘Web beacons’ in the cookies policy template.

[38] You should describe any additional information you measure in your marketing emails.

[39] Include this paragraph if you use web beacons or similar technologies to measure engagement rates with your emails.

[40] You should include a link to your third party mailing list provider’s privacy policy to allow the user to understand how they use web beacons and similar technologies.

[41] This section, which is the alternative (and recommended) method of sending marketing communications, relies on obtaining explicit (i.e. opt-in) consent from an individual to send them information about any of your products and services. This requires third party

[42] If you want to market to individuals by means other than email, you will need to include multiple tick box options for them to select the methods by which they would like to receive marketing communications (text, post etc.).

[43] This section is designed to disclose information about any third party mailing list provider you use to administer your email marketing list.

[44] You need to state where your third party mailing list provider stores your subscribers’ information, and, in particular, whether it is stored inside or outside the European Economic Area (EEA).

[45] Include this paragraph if the information about individuals on your mailing list (i.e. their names and email addresses etc.) are stored outside the European Economic Area (e.g. because your mailing list provider stores the information on servers outside the EEA or because you store the information outside the EEA). You will also need to complete the relevant sections in the section of this privacy policy entitled ‘Transfers of your information outside the European Economic Area’ below and indicate the safeguards used to transfer personal information outside the EEA (e.g. because your third party provider has self-certified its compliance with the EU-U.S. Privacy Shield (if that is the safeguard it uses). You will need to confirm with your third party email provider what safeguards they use if you do not already know this information).

[46] This section is designed to cover off any web beacons or similar technologies you use in your marketing emails to measure information such as open rates and click through rates. Please note that you will need to gain explicit consent to use web beacons in your marketing emails. If you cannot get such consent, you must not use web beacons in you marketing emails. For further information, please see the footnotes to the section entitled ‘Web beacons’ in the cookies policy template.

[47] You should describe any additional information you measure in your marketing emails.

[48] Include this paragraph if you use web beacons or similar technologies to measure engagement rates with your emails.

[49] You should include a link to your third party mailing list provider’s privacy policy to allow the user to understand how they use web beacons and similar technologies.

[50] This paragraph should be included if you send customers information about third party goods ands services (whether separatey or in addition to information about your own products and services). Most websites do not send individuals information about goods ands services other than their own but it is possible to do so. If you intend to do this, the third parties whose goods and services will be marketed must be either named individually or (if you can demonstrate why it is fair not to disclose the names) identified by very specific category of third party (i.e. what sort of business they are e.g. ‘website design businesses’ or ‘graphic designers’). It is not sufficient to say tick here if you would like to receive offers from ‘third parties’ or ‘trusted partners’, for instance, and we strongly recommend using the names of any third parties as far as possible. If you provide customers with the opportunity to receive both your and third party marketing communications, you must have two separate sets of tick boxes so that the individual can chose between receive information about your products and services and those of third parties.

[51] As optional information is, by its definition, not strictly required to perform a contract, you will need another legal basis for processing it. You should therefore consider either consent or your legitimate interests. ‘How someone heard about you’ is not likely to be personal information per se but it could be used to identify someone in combination with other information on your website. We would suggest relying on your legitimate interests where possible and consent if you cannot find a convincing legitimate interest for collecting the information.

[52] This section is designed to disclose information about any third party mailing list provider you use to administer your email marketing list.

[53] You need to state where your third party mailing list provider stores your subscribers’ information, and, in particular, whether it is stored inside or outside the European Economic Area (EEA).

[54] Include this paragraph if the information about individuals on your mailing list (i.e. their names and email addresses etc.) are stored outside the European Economic Area (e.g. because your mailing list provider stores the information on servers outside the EEA or because you store the information outside the EEA). You will also need to complete the relevant sections in the section of this privacy policy entitled ‘Transfers of your information outside the European Economic Area’ below and indicate the safeguards used to transfer personal information outside the EEA (e.g. because your third party provider has self-certified its compliance with the EU-U.S. Privacy Shield (if that is the safeguard it uses). You will need to confirm with your third party email provider what safeguards they use if you do not already know this information).

[55] This section is designed to cover off any web beacons or similar technologies you use in your marketing emails to measure information such as open rates and click through rates. Please note that you will need to gain explicit consent to use web beacons in your marketing emails. If you cannot get such consent, you must not use web beacons in you marketing emails. For further information, please see the footnotes to the section entitled ‘Web beacons’ in the cookies policy template.

[56] You should describe any additional information you measure in your marketing emails.

[57] Include this paragraph if you use web beacons or similar technologies to measure engagement rates with your emails.

[58] You should include a link to your third party mailing list provider’s privacy policy to allow the user to understand how they use web beacons and similar technologies.

[59] You should edit and amend this list as appropriate to reflect any public sources which you may obtain information about individuals from.

[60] Include this clause if you purchase lists from third parties. Note that it is possible not to include this clause in your privacy policy providing that you meet the obligation (which you are required to meet in any event) to provide individuals with a copy of your privacy policy where you have obtained their details from third parties. You should also be aware of the very high risks associated with purchasing data lists and the effective need under GDPR to be named as a third party in order for an individual to be able to have consented to their information being purchased by you.

[61] This paragraph should only be included if you use automated decision-making or profiling. Please note: this is a complex area of law, and if you are engaged in any automated decision making or profiling on your website, we strongly recommend that you obtain independent advice, as this is an area which carries a particularly high risk of fines.

If you do not use any automated decision-making or profiling, you can delete this section. The information below sets explains what these terms mean and how they are likely to apply to your website. Please note that this section envisages that you do not process any ‘sensitive personal information’.

Automated decision-making’ is where a decision is made by a machine in relation to an individual without any meaningful human involvement and where that decision significantly affects that individual (e.g. a decision whether to grant an individual credit).

Profiling’ is ‘any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.’

In terms of your website, the most likely activities that most websites will carry out that will be affected by the automated decision-making or profiling requirements are web analytics, server log information analysis tools and online advertising. Merely collecting information about who accesses your website is not profiling in itself, but the automated analysis and use of that information to categorise individuals in web analytics will constitute profiling if the processing of personal information is involved (this includes the processing of IP addresses and cookies which can be used to identify individuals (particularly if they are combined with other information)).

The most common and relevant forms of automated decision-making and profiling used by websites are targeted web advertising (e.g. remarketing advertisements, via AdSense, via Facebook Ads or any other advertisements targeting specific individuals or groups of individuals). Simply collecting information about the use of your website by an individual will not constitute profiling (e.g. via server logs) but the automated analysis and categorisation of such information by analytics providers such as Google Analytics will. If you use analytics or online advertising which is designed to target certain individuals, you must explain what information you use, how you use it and any consequences e.g. that information will be collected about them and they will receive targeted advertisements based on their actions or certain characteristics about them. If you are sure that your business does not use either automated decision-making or profiling, you can delete these provisions.

[62] Include this clause if the automated decision making you use does not legally or otherwise similarly significantly affect individuals.

[63] This privacy policy assumes that you do not engage in automated decision making that has legal effects or otherwise significantly affects an individual. To significantly affect someone, the decision making must have the potential to significantly influence an individual’s circumstances, behaviour or choices. Examples of significant effects would be the automatic refusal of an online credit application or e-recruiting practices without any human intervention. Sectors of businesses that are particularly likely to engage in such significant automated decision making in some way include banking and finance, healthcare, taxation, insurance, marketing and advertising.

[64] Insert and amend this clause if you use remarketing style advertising across the internet (e.g. if you market to individuals who have visited your site by displaying advertisements to them on other sites e.g. using Google AdSense).

[65] You will need to implement a cookies management tool on your website that allows to turn on and off cookies on your site. See Cookie Control by Civic for a potential solution (which the ICO uses): https://www.civicuk.com/cookie-control

[66] Use this template clause to describe any automated decision making you use which is not already covered by this privacy policy template e.g. credit checks. Please note, however, that this privacy policy does not cover automated decision making in relation to individuals’ sensitive personal information. In order to do that, you will generally need their explicit consent.

[67] Include this sentence if your analytics provider anonymises the data after it collects it and combines it with information from other website users to generate overall statistics that cannot be tied back to a particular user.

[68] It is difficult to allow an individual to easily opt out of web beacon tracking in marketing emails in practice, but there is a legal requirement that you allow them to do so. One solution may therefore be to manually delete someone’s details from your mailing list which contains web beacons and move them to your list which does not use web beacons (however cumbersome and time consuming this may unfortunately be). In this case, their method for objecting should be to contact you and inform you that they object to your use of web beacons. In reality, we consider it is unlikely that someone will want to receive marketing communications but also be concerned about web beacons but you will still need to gain separate consent to the use of web beacons and similar technologies in your emails and record this (e.g. on your website’s database).

[69] Use this template clause to describe any profiling you use which is not already covered by this privacy policy template e.g. automated analysis of web server logs.

[70] Many of the entities in the following list can be classified as ‘data processors’ (though this will not necessarily be the case and will depend on your individual circumstances). You will need to conduct you own analysis to confirm whether such third party processors (and any other processors you use) are ‘data processors’ for the purposes of the GDPR and enter into data processing agreements with them if so. For further information, see the ICO’s guidance which is available here: https://ico.org.uk/media/for-organisations/documents/1546/data-controllers-and-data-processors-dp-guidance.pdf

[71] Insert this provision if you have decided not to disclose the identities of you third party service providers on your website and have used categories of recipient instead.

[72] This paragraph explains how information is shared with Google Analytics as an example. If you use a different web analytics provider, you should provide a similar description of how information is shared with that third party provider and what it is used for. You will generally always need to disclose the identity of your analytics provider as they tend to collect information about website visitors by default.

[73] You need to include the details of any organisations with whom you share individuals’ personal information. As far as possible, these should be indicated using their specific names. If that is not possible, they should be identified by specific categories of business (by industry, sector and sub-sector) and you should provide their locations (i.e. what country they are located in). A suggested list of third parties with whom a business might share third parties is set out below. You should include links to their privacy policies wherever they are publicly available. If you do not name the third parties with whom you share information you will need to be able to justify why it is fair not to do so and document your decision.

[74] This provision covers a situation where your business is comprised of multiple companies within a corporate group. You should specify the details of other entities in the corporate group with whom you will share personal data. If your business is a single company or other legal entity, or are a sole trader, this provision should be deleted.

[75] Insert this provision if you have decided not to disclose the identities of you third party service providers on your website and have used categories of recipient instead.

[76] Include this sentence if your business is subject to anti-money laundering regulations such as the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017.

[77] Amend this to the appropriate jurisdiction (e.g. the laws of Scotland) if your business is not incorporated (if you are a corporate entity) or registered (if you are an individual) in England or Wales.

[78] As far as possible, you should state fixed time periods for your retention of information.

[79] If you keep information for longer than the legal record keeping period you must be able to justify why you do so and provide your explanation here.

[80] One of the most common sources of personal information is enquiries from customers or potential customers. There is no fixed time period specified by law for retaining the personal information you receive in connection with those enquiries. We would recommend setting a specific period which you can justify as reasonable. Ideally, any personal information should be deleted as soon as an enquiry has been resolved, but this may not be practical to implement for many businesses. We would anticipate that a period of one to three months would not be unreasonable for the vast majority of businesses, although a longer period may be acceptable provided that it can be justified. It is important to remember, however, that holding onto personal information generally increases the risk of liability so we would recommend that you delete such information as soon as you no longer require it, in particular to reduce the risk of you having to respond in detail to a subject access request, which can be very onerous.

[81] If you store data collected for specific circumstances for any specific period of time or on any specific basis, you should insert the relevant information here.

[82] These are general factors which the Information Commissioner’s Office recommends that you consider when determining the retention period for personal information. You should delete any factors that do not apply to your determination of how long you retain information and add any additional factors that you take into account (if any).

[83] This section includes some mandatory security measures you are required to take as well as some suggested further actions methods of securing personal information which you may or may not use in practice. You should add to this list any additional methods which you use to secure personal information which are not covered in this list.

[84] You need to ensure that personal information collected via your website is stored on secure servers.

[85] Include this provision if you accept payment for goods and services online from your website.

[86] Although transmission of information over the internet is inherently insecure, you need to ensure that personal information collected via your website is stored on secure servers.

[87] Where personal information is transferred outside of the EEA you must inform users of the country where it will be stored and the safeguards used. This section is designed to cover off this requirement. It is possible that personal information you collect may be stored in different places depending on the methods you have collected it and the purposes for which you are processing it e.g. if you use a third party email list provider to administer your email marketing list, you will need to check where they store the information. For example, MailChimp, a popular mailing list provider, stores information on their servers in the US and the safeguard they use to do so is the EU-U.S. Privacy Shield. The annex to this privacy contains the wording to use for the relevant safeguards that you use. Information collected via the contact form on your website however, assuming the information is stored on your website (and not emailed to you), will be generally be stored on your website’s server, so the location of your server will be the relevant location (although you must confirm that this is in fact where the information collected on your website is stored). Regular emails that you receive to the email address on your website, however, could be stored somewhere else (e.g. your email provider’s servers). You will therefore need to do a review and analysis of where information collected by your website is stored and the safeguards you use for overseas data transfers before you can complete this section.

If you do no transfer personal information outside of the EEA in any circumstances (e.g. all personal information you collect is located in the UK (for as long as it remains a member of the EEA) or is only transferred to other EEA countries, you can simply include the statement at the beginning of this section (i.e. We do not transfer your information outside of the EEA) and delete the rest of the information in this section. However, you must be sure that you do not transfer any personal information outside of the EEA before you do so.

[88] If you do not transfer any information outside the EEA, then you should complete the first paragraph and delete the rest of this section.

[89] You must state whether the country to which information has been transferred is subject to an adequacy decision by the European Commission or not. If it is, you will be able to rely on that adequacy decision to transfer and store information in that country. If is it not, you will need to find another appropriate safeguard to use. The list of countries subject to an adequacy decision by the European Commission is available here: http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm. Please note that the US is not subject to an adequacy decision. Rather, certain US companies have self-certified their compliance with the EU-U.S. Privacy Shield, which is an appropriate safeguard. Only if the US company has self-certified its compliance with the EU-U.S. Privacy Shield can you transfer personal information to that company in the US.

[90] Where you have made available any of the safeguards referred to in the bullet points, you must provide a means to obtain a copy of them i.e. a link to them or an email address that an individual can write to in order to request them.

[91] You must state whether the country to which information has been transferred is subject to an adequacy decision by the European Commission or not. If it is, you will be able to rely on that adequacy decision to transfer and store information in that country. If is it not, you will need to find another appropriate safeguard to use. The list of countries subject to an adequacy decision by the European Commission is available here: http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm. Please note that the US is not subject to an adequacy decision. Rather, certain US companies have self-certified their compliance with the EU-U.S. Privacy Shield, which is an appropriate safeguard. Only if the US company has self-certified its compliance with the EU-U.S. Privacy Shield can you transfer personal information to that company in the US.

[92] Where you have made available any of the safeguards referred to in the bullet points, you must provide a means to obtain a copy of them i.e. a link to them or an email address that an individual can write to in order to request them.

[93] You must state whether the country to which information has been transferred is subject to an adequacy decision by the European Commission or not. If it is, you will be able to rely on that adequacy decision to transfer and store information in that country. If is it not, you will need to find another appropriate safeguard to use. The list of countries subject to an adequacy decision by the European Commission is available here: http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm. Please note that the US is not subject to an adequacy decision. Rather, certain US companies have self-certified their compliance with the EU-U.S. Privacy Shield, which is an appropriate safeguard. Only if the US company has self-certified its compliance with the EU-U.S. Privacy Shield can you transfer personal information to that company in the US.

[94] Where you have made available any of the safeguards referred to in the bullet points, you must provide a means to obtain a copy of them i.e. a link to them or an email address that an individual can write to in order to request them.

[95] You must state whether the country to which information has been transferred is subject to an adequacy decision by the European Commission or not. If it is, you will be able to rely on that adequacy decision to transfer and store information in that country. If is it not, you will need to find another appropriate safeguard to use. The list of countries subject to an adequacy decision by the European Commission is available here: http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm. Please note that the US is not subject to an adequacy decision. Rather, certain US companies have self-certified their compliance with the EU-U.S. Privacy Shield, which is an appropriate safeguard. Only if the US company has self-certified its compliance with the EU-U.S. Privacy Shield can you transfer personal information to that company in the US.

[96] Where you have made available any of the safeguards referred to in the bullet points, you must provide a means to obtain a copy of them i.e. a link to them or an email address that an individual can write to in order to request them.

[97] You must state whether the country to which information has been transferred is subject to an adequacy decision by the European Commission or not. If it is, you will be able to rely on that adequacy decision to transfer and store information in that country. If is it not, you will need to find another appropriate safeguard to use. The list of countries subject to an adequacy decision by the European Commission is available here: http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm. Please note that the US is not subject to an adequacy decision. Rather, certain US companies have self-certified their compliance with the EU-U.S. Privacy Shield, which is an appropriate safeguard. Only if the US company has self-certified its compliance with the EU-U.S. Privacy Shield can you transfer personal information to that company in the US.

[98] If there are any other ways in which personal information is transferred outside the EEA, you should use and duplicate this template section to cover off those additional methods until you have described all of the circumstances in which you transfer personal information outside of the EEA.

[99] You must state whether the country to which information has been transferred is subject to an adequacy decision by the European Commission or not. If it is, you will be able to rely on that adequacy decision to transfer and store information in that country. If is it not, you will need to find another appropriate safeguard to use. The list of countries subject to an adequacy decision by the European Commission is available here: http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm. Please note that the US is not subject to an adequacy decision. Rather, certain US companies have self-certified their compliance with the EU-U.S. Privacy Shield, which is an appropriate safeguard. Only if the US company has self-certified its compliance with the EU-U.S. Privacy Shield can you transfer personal information to that company in the US.

[100] Where you have made available any of the safeguards referred to in the bullet points, you must provide a means to obtain a copy of them.

[101] You will need to include this right if you engage in automated decision making which has a legal effect on individuals or which similarly significantly affects individuals. This will generally not be the case in relation to regular online advertising methods and web analytics. However, you should see the section and footnotes relating to the section entitled ‘Our use of automated decision making and profiling’ below.

[102] Include this provision if you use text (SMS) marketing. If you only use email marketing, for example, you can delete this provision.

[103] Sensitive personal information is outside the scope of this privacy policy as it is not ordinarily collected by most businesses. If you do collect sensitive personal information, you should seek appropriate advice on how to ensure your website and collection methods comply with the General Data Protection Regulation and any other applicable legislation. In many cases, the only legal basis on which you will be able to process sensitive personal information will be an individual’s explicit consent (under Article 9(2)(a) of the GDPR.

[104] The legal status of a do not track request has not yet been confirmed (i.e. whether it should be considered an objection to processing or objection to profiling under the GDPR). As such, it is unclear whether there is any legal obligation to respond to such requests and whether any enforcement action will be taken against websites which do not recognise the request. We would recommend, however, that you err on the side of caution and assume that the GDPR will be recognised as a valid method of objecting to tracking technologies on your site and implement an appropriate solution to respond to this (e.g. Cookie Control by Civic: https://www.civicuk.com/cookie-control)This disclosure is required to satisfy The California Online Privacy Protection Act (CalOPPA) and there is no requirement to make such a disclosure under GDPR. Therefore, you may wish to delete this paragraph altogether although you would run the risk of being found to be in breach of CalOPPA, particularly if users from California access your website.

 

                                  Cookies Policy

This Cookies Policy sets out the basis on which we ,[ The Plate Company UK Ltd ], use cookies and similar technologies on or in relation to our website, [www.number1plates.com). This Cookies Policy is effective from 01 05 2018

‘Essential’ cookies are automatically placed on your computer or device when you access our website or take certain actions on our website. [‘Non-essential’ cookies and other technologies are only placed on your computer or device if you have consented to us doing so.][1] For information on [the difference between][2] essential [and non-essential][3] cookies, see the section below entitled About cookies.

For information on how you consent and how you can withdraw your consent to us placing non-essential cookies and other technologies on your computer or device, see the section below entitled How to accept or reject cookies.

Contents[4]

  • About cookies
  • List of cookies used
  • Essential cookies
  • Non-essential cookies
  • [Web beacons][5]
  • [Facebook Pixel][6]
  • How to accept or reject cookies
  • Copyright, credit and logo

 

About cookies

 

What are cookies?

Cookies are small data files sent by a website’s server to a web browser, processor memory or hard drive and stored there. They can be used for a range of different purposes, such as customising a website for a particular user, helping a user navigate a website, improving that user’s website experience, and storing that user’s preferences and login information.

 

Essential and non-essential cookies

Cookies can be classified as either ‘essential’ or ‘non-essential’.

Essential cookies: these are cookies that are either:

  • used solely to carry out or facilitate the transmission of communications over a network; or
  • strictly necessary to provide an online service (e.g. our website or a service on our website) which you have requested.

 

Non-essential cookies: these are any cookies that do not fall within the definition of essential cookies, such as cookies used to analyse your behaviour on a website (‘analytical’ cookies) or cookies used to display advertisements to you (‘advertising’ cookies).

 

Session and persistent cookies

 

Cookies can be classified as either ‘session’ or ‘persistent’, depending on how long they last after they are placed on your browser.

Session cookies: session cookies last for as long as you keep your browser open. They expire when you close your browser.

Persistent cookies: persistent cookies expire at a fixed point in time or if you manually delete them from your browser, whichever occurs first.

 

First and third party cookies

 

Cookies can be classified as ‘first party’ or ‘third party’.

First party cookies: these are cookies placed on your device by our website domain.

Third party cookies: these are cookies placed on your device by third party website domains.

If you require further information about cookies in general, please visit www.allaboutcookies.org

 

List of cookies used

The table below lists the cookies we collect and what information they store.

Cookie Name Cookie Description
FORM_KEY Stores randomly generated key used to prevent forged requests.
PHPSESSID Your session ID on the server.
GUEST-VIEW Allows guests to view and edit their orders.
PERSISTENT_SHOPPING_CART A link to information about your cart and viewing history, if you have asked for this.
STF Information on products you have emailed to friends.
STORE The store view or language you have selected.
USER_ALLOWED_SAVE_COOKIE Indicates whether a customer allowed to use cookies.
MAGE-CACHE-SESSID Facilitates caching of content on the browser to make pages load faster.
MAGE-CACHE-STORAGE Facilitates caching of content on the browser to make pages load faster.
MAGE-CACHE-STORAGE-SECTION-INVALIDATION Facilitates caching of content on the browser to make pages load faster.
MAGE-CACHE-TIMEOUT Facilitates caching of content on the browser to make pages load faster.
SECTION-DATA-IDS Facilitates caching of content on the browser to make pages load faster.
PRIVATE_CONTENT_VERSION Facilitates caching of content on the browser to make pages load faster.
X-MAGENTO-VARY Facilitates caching of content on the server to make pages load faster.
MAGE-TRANSLATION-FILE-VERSION Facilitates translation of content to other languages.
MAGE-TRANSLATION-STORAGE Facilitates translation of content to other languages.

 

Essential cookies

 

These are cookies which are strictly necessary for our website to be able to operate or to provide you with a service on our website which you have requested. We use the following essential cookies on our website:

  • [first party session cookies to remember your input when you fill in an online form over several pages on our website.
  • [first party session cookies for remembering the items you have placed in your shopping cart.
  • [first party session cookies to identify and authenticate you when you log into our website so you do not need to repeatedly enter your login information.

 

  • [first party [session OR persistent] security cookies used for detecting repeated failed login attempts.
  • [first party [session OR persistent] security cookies used to prevent abuse of the login system on our website
  • [[first party OR third party] session multimedia player cookies to play

    content on our website

  • [[first party OR third party] [session OR persistent] cookies to recognise whether you have accepted the use of cookies on our website. These cookies are: [insert cookie names]. These cookies expire after [insert time period for cookies to expire if they are persistent cookies e.g. 30 days].]

 

  • [[first party OR third party] [session OR persistent] cookies to remember the language in which to display our website to you. These cookies are: [insert cookie names

 

[Legal basis for processing: we process information about you contained in or obtained from essential cookies in our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interests:
ensuring our site functions properly and providing you with online services you have requested.][7]

How to opt out of essential cookies

Most browsers allow you to block all cookies, including essential cookies. Please note, however, that if you block all cookies, parts of our website and its functionality may not work or display properly.

You can delete existing cookies from your browser by clearing your browsing data and ensuring that the option to delete cookies is selected.

For more detailed information on how to accept and reject cookies, including guidance for specific browsers, please see the section below entitled How to accept or reject cookies

 

Non-essential cookies

 

We use the following types of non-essential cookies on our website:

  • Functional cookies
  • Analytical (or performance) cookies
  • Targeting (or advertising) cookies

 

Functional cookies

 

These are cookies that are designed for purposes such as enhancing a website’s functionality. These are either not strictly essential for the website or functionality which you have requested to work, or are cookies which serve non-essential purposes in addition to their essential purpose. We use the following functional cookies on our website:

How to opt in or out from functional cookies

See the section below entitled How to accept or reject cookies

 

Processing information about you contained in or obtained from functional cookies

Analytical (or performance) cookies

 

Analytical (or performance) cookies track and gather data about what a user does on a website. These cookies are not essential for our website or its functionality to work. We use the following analytical cookies on our website:

 

More information

Google Analytics cookies are classified as first party cookies as they are set by our website domain, although Google collects and processes information from our use of Google Analytics. To find out more about how Google handles information collected from Google Analytics, see Google Analytics’ privacy policy, which is available here: https://support.google.com/analytics/answer/6004245

For information on how Google uses data from cookies it uses, please visit www.google.com/policies/privacy/partners/

 

How to opt in or out from analytical cookies

See the section below entitled How to accept or reject cookies

[To opt out of Google Analytics tracking across all websites in general, you can do so here: http://tools.google.com/dlpage/gaoptout][8]

 

Processing information about you contained in or obtained from analytical cookies

[Legal basis for processing: we process information about you contained in or obtained from analytical cookies in our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interests: analysing how individuals use our website to help us improve our website and business. For further information on how we use the information gathered from our use of analytical cookies, including profiling, please see the section entitled Our use of automated decision making and profiling in our privacy policy, which is available here: [insert link to privacy policy][9]

 

Targeting (or advertising) cookies[10]

 

Targeting (or advertising) cookies record information about your visit to and use of our website, for advertising purposes. We use the targeting cookies for the following purposes on our website[www.number1plates.com[:] OR [. For information on third party targeting or advertising cookies we use on our website, please see the section below entitled Third party cookies.]][11]

  • [[first party [session OR persistent] cookies to display advertisements to you based on your interests and to measure their effectiveness. These cookies are: [insert cookie names]. These cookies expire after [insert time period for cookies to expire if they are persistent cookies e.g. 30 days].][12]

 

  • [[first party [session OR persistent] cookies to remarket advertisements to you on other websites you visit.] These cookies are: [insert cookie names]. These cookies expire after [insert time period for cookies to expire if they are persistent cookies e.g. 30 days].]

–        [include any additional purposes for which you use targeting cookies on your website.]

 

How to opt in or out from advertising cookies

See the section below entitled How to accept or reject cookies

 

Processing information about you contained in or obtained from advertising cookies

Legal basis for processing: we process information about you contained in or obtained from advertising cookies in our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).[13]
Legitimate interests: displaying advertisements to you about our products and services [insert any relevant additional details or purposes]. [For further information on how we use the information gathered from our use of advertising cookies[, including [automated decision making] and [profiling]] please see the section entitled Our use of automated decision making and profiling in our privacy policy, which is available here /privacypolicy

OR

[Legal basis for processing: consent (Article 6(1)(a) of the General Data Protection Regulation).
Consent: you give your consent to the purposes for which we process your information using advertising cookies by [insert method by which a user consents to your use of advertising cookies e.g. by clicking I accept the purposes for which you use advertising cookies in our cookie tool (describe the mechanism by which the user consents to the purposes for which you use advertising cookies on your website)]. [For further information on how we use the information gathered from our use of advertising cookies[, including [automated decision making] and [profiling]] please see the section entitled Our use of automated decision making and profiling in our privacy policy, which is available here: [insert link to privacy policy]][14]

 

Third party cookies

 

Third parties use cookies to analyse your use of our website and/or to display advertisements (including third party advertisements) to you [and] [insert any other uses of third party cookies e.g. advertisement conversion tracking such as Google AdWords]. Third party cookies used in relation to our website include:

  • [Third party advertisement cookies. [Insert name of third party] uses cookies to display advertisements to you [[on our website] OR [on other websites] OR [elsewhere across the internet] [based on your interests [and behaviour]] and to measure their effectiveness. You can find out how [insert name of third party] uses your information and how they use cookies by accessing their privacy policy at [insert URL of third party’s privacy policy] and their cookies policy at [insert URL of third party’s cookies policy]. These cookies are: [insert cookie names].] These cookies expire after [insert time period for cookies to expire if they are persistent cookies e.g. 30 days].][15]

 

  • [[Third party] OR [Google AdWords cookies]][16] [to track whether you have come to us via an advertisement we have placed on [a search engine results page] AND/OR [elsewhere across the internet, such as another website] and to record information relating to how you came to us such as your location when you accessed our website, the time of day you visited and the device you were using [and] [insert any other information collected about users e.g. by AdWords tracking or conversion cookies.] Google may use different cookies to track how you came to our website depending on what advertisement you clicked on and where.][17]

 

  • [[Third party OR Google]] [remarketing cookies] [to display advertisements to you about our goods and services across the internet, including on other websites you visit. [Google uses cookies to display advertisements to you about our products and services on other websites and locations across the internet based on the fact that you have visited our website. Google may also display other advertisements across the internet to you about third party services using the Google AdSense network, although this is beyond our control. [For more information about Google remarketing, click here: https://support.google.com/adwords/answer/2453998?hl=en][18]

 

  • [[Third party] OR [Google]] cookies [to display advertisements on our website]. [We use Google AdSense on our website. Google uses cookies to display advertisements to you on our website about third party goods and services based on the websites you have visited and your online behaviour and interests. For more information about Google AdSense, click here: https://support.google.com/adsense/answer/6242051?hl=en ]][19]

 

More information

For information about the cookies Google uses in relation to the above, see the ‘Advertising’ section on the Types of cookies used by Google page in Google’s cookies policy, which is available here: https://www.google.com/policies/technologies/types/

For information about how Google uses data from cookies for its own purposes, please visit the following link www.google.com/policies/privacy/partners/

 

How to opt in or out from third party cookies

See the section below entitled How to accept or reject cookies

 

Processing information about you contained in or obtained from third party cookies

[Legal basis for processing: we process information about you contained in or obtained from third party cookies in our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interests: the purposes for which we use the third party cookies as described above [and] [insert any relevant additional details]. [For further information on how we use the information gathered from our use of third party cookies[, including [automated decision making] and [profiling],] please see the section entitled Our use of automated decision making and profiling in our privacy policy, which is available here: [insert link to privacy policy]][20]

AND/OR

[Legal basis for processing: consent (Article 6(1)(a) of the General Data Protection Regulation).
Consent: you give your consent to the purposes for which we process your information using third party cookies by [insert method by which a user consents to your use of third party cookies e.g. by clicking I accept the purposes for which you use advertising cookies in our cookie tool (describe the mechanism by which the user consents to the purposes for which you use advertising cookies on your website)]. [For further information on how we use the information gathered from our use of third party cookies[, including [automated decision making] and [profiling]] please see the section entitled Our use of automated decision making and profiling in our privacy policy, which is available here: [insert link to privacy policy]][21]

 

Other technologies

 

[Web beacons]

[We [and any marketing companies we use][22] also embed web beacons [in our marketing emails [and/or] on our website].[23] Web beacons are small GIF image files which enable us to track your receipt of our marketing emails, how often you view our adverts or website pages, your location, IP address and browser information. Web beacons are activated whenever you open a marketing email or access a page on our website which contains a web beacon. Web beacons transmit data when you view them but are not capable of accessing any other information on your computer. Web beacons are not stored on your hard drive unless you download a GIF image containing them.

Some (but not all) browsers enable you to restrict the use of web beacons by either preventing them from sending information back to their source (for example, when you choose browser settings that block cookies and trackers), or by not accessing the images containing them (for example, if you select a ‘do not display images (in emails)’ setting in your email server).][24]

 

How to opt in or out

See the section below entitled How to accept or reject cookies

 

Legal basis for processing: we process the information we gather from the use of web beacons in our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest: [analysing the effectiveness of our email marketing campaigns [and/or [insert purpose of use of web beacons if you use them on your website in addition to email marketing]]. [For further information on how we use the information gathered from our use of web beacons[, including [automated decision making] and [profiling]] please see the section entitled Our use of automated decision making and profiling in our privacy policy, which is available here: [insert link to privacy policy]][25]

 

[Facebook Pixel][26]

[We use Facebook Pixel on our website. Facebook Pixel is a tracking code which allows us to track and monitor the success of advertisements we use on Facebook and to improve the effectiveness of those advertisements by recording information such as the device you used to access our website and the actions you took on our website using cookies. [We may also use Facebook Pixel to create retargeting advertisements and custom audiences for our advertisements on Facebook and on our website].]

Facebook aggregates data gathered from our use of Facebook Pixel on our website with data it gathers from other sources, in order to improve and target advertisements displayed on its website or via its services, to improve its systems and to provide measurement services to third parties which use Facebook’s advertising services. You can find out more about how Facebook handles information they collect about you and other individuals by accessing their privacy policy, which is available here: https://www.facebook.com/about/privacy]

 

How to opt in or out

See the section below entitled How to accept or reject cookies

[Legal basis for processing: we process the information we gather from the use of web beacons in our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: [analysing the effectiveness of our advertisements on Facebook. [For further information on how we use the information gathered from our use of Facebook Pixel [, including [automated decision making] and [profiling]] please see the section entitled Our use of automated decision making and profiling in our privacy policy, which is available here: [insert link to privacy policy]]][27]

 

OR

[Legal basis for processing: consent (Article 6(1)(a) of the General Data Protection Regulation).
Consent: you give your consent to the purposes for which we process your information using Facebook Pixel by [insert method by which a user consents to your use of advertising cookies e.g. by clicking I accept the purposes for which you use advertising cookies in our cookie tool (describe the mechanism by which the user consents to the purposes for which you use advertising cookies on your website)]. [For further information on how we use the information gathered from our use of Facebook Pixel[, including [automated decision making] and [profiling]] please see the section entitled Our use of automated decision making and profiling in our privacy policy, which is available here: [insert link to privacy policy]][28]

 

How to accept or reject cookies

 

There are a number of different ways in which you can accept or reject some or all cookies [and similar technologies][29]. Some of the main methods of doing so are described below:

You are welcome to block the use of some or all of the cookies we use on our website. However, please be aware that doing so may impair our website and its functionality or may even render some or all of it unusable.

You should also be aware that clearing all cookies from your browser will also delete any cookies that are storing your preferences, for example, whether you have accepted cookies on a website or any cookies that are blocking other cookies.

You can find more detailed information about cookies and adjusting your browser settings by visiting www.allaboutcookies.org

 

Accepting or rejecting cookies

 

[Cookie control tool[30]

[You can accept or reject [non-essential] cookies by using our cookie management tool].] [insert description of how your cookie control tool works and how a user can turn on or off different types of cookies].]

 

Browser settings

You can accept or reject some or all cookies (for example, blocking all third party cookies) by adjusting your browser settings. If you do not know how to do this, the links below set out information about how to change your browser settings for some of the most commonly used web browsers:

Some browsers, such as Chrome and Firefox, allow you to change your settings to browse in ‘incognito’ mode, limiting the amount of data placed on your machine and automatically deleting any persistent cookies placed on your device when you finish your browsing session. There are also many third party applications which you can add to your browser to block or manage cookies.

 

Existing cookies

To clear cookies that have previously been placed on your browser, you should select the option to clear your browsing history and ensure that the option to delete or clear cookies is included when you do so.

 

Google Adsettings

You can manage and opt out of personalisation of advertisements by Google by visiting Google’s ad settings page here https://adssettings.google.com/ and by:

  • unticking the button entitled ‘Also use Google Account activity and information to personalize ads on these websites and apps and store that data in your Google Account’; and
  • switching the ‘Ads Personalisation’ setting off (i.e. by ensuring the switch at the top of the page is set to the left/grey and not the right/blue).

Alternatively, you can install a free browser plugin here: https://support.google.com/ads/answer/7395996

 

Google Analytics Opt-out Browser Add-on

You can opt out of Google Analytics tracking by installing the browser add-on which is available here: http://tools.google.com/dlpage/gaoptout

 

Web beacons

You can opt in to us using web beacons in our marketing emails by: [insert description of how you obtain consent to use web beacons on your website or in your marketing emails][31]

You can opt out of our use of web beacons in our marketing emails by: [insert description of how an individual can withdraw their consent to the use of web beacons on your website or in your marketing emails]

Facebook Pixel

[You can block Facebook Pixel using our cookie control tool: [insert description of how your cookie control tool works and how a user can turn on and off the use of Facebook Pixel on your site].][32]

 

Disconnect for Facebook

You can install a browser add-on tool called ‘Disconnect Facebook pixel and FB tracking’. This will stop Facebook tracking you on third party websites. You can install the too here:

 

European Interactive Digital Advertising Alliance Tool

You can opt out of Facebook and other companies that participate in the Digital Advertising Alliance in Europe from showing you interest based ads by visiting http://www.youronlinechoices.com, selecting your country, clicking ‘Your Ad Choices’, then locating Facebook (and any other companies you want to block) and selecting the ‘Off’ option.

 

Copyright, credit and logo

 

This Cookies Policy is based on a template provided by GDPR Privacy Policy. For further information, please visit https://gdprprivacypolicy.org

The copyright in this Cookies Policy is either owned by, or licensed to, us and is protected by copyright laws around the world and copyright protection software. All intellectual property rights in this document are reserved. Where we display the GDPR Privacy Policy logo on our website, this is used to indicate that we have adopted a privacy policy template provided by GDPR Privacy Policy as the basis for this Privacy Policy.

[1] Include this statement if you use non-essential cookies on your website.

[2] Include this statement if you use non-essential cookies on your website.

[3] Include this statement if you use non-essential cookies on your website.

[4] When you upload this cookies policy to your website, you should ensure that the titles in this “Contents” section link to the relevant headings in the main body of the cookies policy. For instance, the “About cookies” title in this “Contents” section should link to the “About cookies” heading in the main body of the cookies policy.

[5] Where you use web beacons, you must disclose this in your cookies policy. Web beacons are GIF files which enable website owners to track receipt of marketing emails, how often users view adverts or website pages, users’ locations, IP addresses and browser information. If you do not use web beacons, this title can be deleted from the “Contents” section of this cookies policy, as can the corresponding clause entitled “Web beacons” in the main body of this cookies policy. However, before deleting these provisions, you must be sure that your website and/or email marketing do not use web beacons. If you are unsure about whether you use web beacons, you should ask your website developer.

[6] If you use Facebook Pixel, you must disclose it in your cookies policy. See the main section entitled Facebook Pixel for more information.

[7] The information contained in cookies (the unique string of letters and numbers contained in a cookie) can be considered personal information under the GDPR if it can uniquely identify a device or the individual using the device (either on their own or in combination with other information). Therefore, cookies themselves can be considered personal information under the GDPR. The test for whether a cookie should be considered personal information is whether it can be used to identify an individual’s device or the individual themselves, taking into account all the means reasonably likely to be used, such as singling out them out, either by you (the data controller) or another person directly or indirectly. When considering the ‘means reasonably likely to be used’, you should take into account all relevant factors such as the costs and amount of time necessary to identify the individual, the technology available to do so as well as technological developments. In particular, the GDPR envisages that it can be possible to identify someone using a cookie in combination with other unique identifiers like IP addresses and information collected by your website server. You will therefore need to consider the cookies you use individually, whether they uniquely identify a device or an individual and the information they contain in order to establish whether they constitute personal information or not. If you determine that they are personal information, you will need a legal basis for processing them. For essential cookies, we have suggested using your legitimate interests. You may also need to amend the description of your legitimate interests depending on the purpose(s) for which you use essential cookies on your website (i.e. if they are not covered by the suggested descriptions that are provided by default).

[8] This provision should only be included if you use Google Analytics on your website.

[9] The information contained in cookies (the unique string of letters and numbers contained in a cookie) can be considered personal information under the GDPR if it can uniquely identify a device or the individual using the device. Therefore, cookies themselves can be considered personal information under the GDPR. The test for whether a cookie should be considered personal information is whether it can be used to identify an individual’s device or the individual themselves, taking into account all the means reasonably likely to be used, such as singling out them out, either by you (the data controller) or another person directly or indirectly. When considering the ‘means reasonably likely to be used’, you should take into account all relevant factors such as the costs and amount of time necessary to identify the individual, the technology available to do so as well as technological developments. In particular, the GDPR envisages that it can be possible to identify someone using a cookie in combination with other unique identifiers like IP addresses and information collected by your website server. You will therefore need to consider the cookies you use individually, whether they uniquely identify a device or an individual and the information they contain in order to establish whether they constitute personal information or not. If you determine that they are personal information you will need a legal basis for processing them. For analytical cookies, we have suggested using your legitimate interests. You may also need to amend the description of your legitimate interests depending on the purpose(s) for which you use analytical cookies on your website (i.e. if they are not covered by the suggested description that is provided by default).

[10] This section is designed to cover off your use of first party advertising cookies used on your site (i.e. generally your own cookies placed used by your website). If you use third party advertising cookies, such as Google AdSense, you should complete Google AdSense in the third party cookies section below. If you do not use any first party advertising cookies on your website, you can delete this section.

[11] Include this clause if you use third party advertising cookies on your website in addition to first party advertising cookies. If you use third party advertising cookies, such as Google AdSense, you should complete the Google AdSense paragraph in the third party cookies section below.

[12] Include this clause if you use first party advertising cookies on your website. If you use third party advertising cookies, such as Google AdSense, you should complete Google AdSense in the third party cookies section below.

[13] The information contained in cookies (the unique string of letters and numbers contained in a cookie) can be considered personal information under the GDPR if it can uniquely identify a device or the individual using the device. Therefore, cookies themselves can be considered personal information under the GDPR. The test for whether a cookie should be considered personal information is whether it can be used to identify an individual’s device or the individual themselves, taking into account all the means reasonably likely to be used, such as singling out them out, either by you (the data controller) or another person directly or indirectly. When considering the ‘means reasonably likely to be used’, you should take into account all relevant factors such as the costs and amount of time necessary to identify the individual, the technology available to do so as well as technological developments. In particular, the GDPR envisages that it can be possible to identify someone using a cookie in combination with other unique identifiers like IP addresses and information collected by your website server. You will therefore need to consider the cookies you use individually, whether they uniquely identify a device or an individual and the information they contain in order to establish whether they constitute personal information or not. If you determine that they are personal information you will need a legal basis for processing them. For advertising cookies, we have suggested using your legitimate interests. You may also need to amend the description of your legitimate interests depending on the purpose(s) for which you use advertising   cookies on your website (i.e. if they are not covered by the suggested description that is provided by default).

[14] If you use very intrusive advertising or remarketing cookies you will need to obtain consent from the user to process their information (cookie data about them) for such purposes and will not be able to rely on your legitimate interests. This is separate consent from the consent the user gives to the placement of cookies on their device which is required under the Privacy and Electronic Communications Regulations. It is currently unclear whether, in practice, you will need to gain a separate consent for processing personal information contained in or derived from cookies and consent for placing cookies on a user’s device and we expect that, in practice (due to the practical unworkability of obtaining two separate consents) consent to the cookies being placed on the user’s device will constitute consent for the purposes for which a website processes personal information contained in or derived from those cookies. However, the position is not clear and not relevant guidance has been produced as yet. You should therefore assume that separate consents will be required as this is the strict legal position.

 

When consent is required

In terms of the level of intrusiveness of advertising and other tracking cookies required to trigger the requirement to obtain consent to process someone’s personal information (cookie information) for these purposes, this is not yet entirely clear. However, guidance produced by the Article 29 Working Party has indicated that advertising to a particular demographic e.g. women in London, would not be too intrusive and would not have a significant effect on individuals. However, targeting advertisements to vulnerable adults or minority groups would (e.g. showing gambling advertisements to someone in financial difficulties) and, accordingly, consent would be required. The guidance indicates that whether consent is required will always be fact and situation dependent and the following factors should be taken into account: (i) how intrusive the profiling process is; (ii) the expectations and wishes of the individuals you target; (iii) the way you deliver the advertisement; and (iv) how vulnerable the individuals you target are.

[15] You should complete this template clause if you use a third party advertising cookie provider other than Google. In addition, you should try to provide as much information (via links if necessary) to explain to users how those cookies are used if users require further detail.

[16] Include this reference if the third party cookies you use are Google AdWords cookies.

[17] This provision is designed to cover situations where someone has come to your website via a search engine advertisement service you have been using (such as Google AdWords) or via an advertisement on elsewhere on a display network (e.g. Google’s display network). If you use such advertising, you should explain what you do with the information you obtain from such advertisements (e.g. targeting your advertisements more effectively or analysing statistics about users who have accessed your website).

[18] Include this clause if you use Google AdWords remarketing for your website.

[19] Include this clause if you use Google AdSense on your website.

[20] If you use process an individual’s personal information by automated means (e.g. by the use of cookies) to evaluate, analyse or predict aspects about that individual (such as their behaviour, location or movements) i.e. to build up a profile about them, you will be conducting ‘profiling’ and you will need to disclose this in the section of your privacy policy entitled ‘Our use of automated decision making and profiling’. If you automate decisions in relation to individuals using their personal information e.g. to display advertisements to them based on the fact they have visited your website, you will need to disclose such automated decision making as well.

[21] If you use very intrusive advertising or remarketing third party cookies you will need to obtain consent from the user to process their information (cookie data about them) for such purposes and will not be able to rely on your legitimate interests. This is separate consent from the consent the user gives to the placement of cookies on their device which is required under the Privacy and Electronic Communications Regulations. It is currently unclear whether, in practice, you will need to gain a separate consent for processing personal information contained in or derived from cookies and consent for placing cookies on a user’s device and we expect that, in practice (due to the practical unworkability of obtaining two separate consents) consent to the cookies being placed on the user’s device will constitute consent for the purposes for which a website processes personal information contained in or derived from those cookies. However, the position is not clear and not relevant guidance has been produced as yet. You should therefore assume that separate consents will be required as this is the strict legal position.

 

When consent is required

In terms of the level of intrusiveness of third party advertising and other tracking cookies required to trigger the requirement to obtain consent to process someone’s personal information (cookie information) for these purposes, this is not yet entirely clear. However, guidance produced by the Article 29 Working Party has indicated that advertising to a particular demographic e.g. women in London, would not be too intrusive and would not have a significant effect on individuals. However, targeting advertisements to vulnerable adults or minority groups would (e.g. showing gambling advertisements to someone in financial difficulties) and, accordingly, consent would be required. The guidance indicates that whether consent is required will always be fact and situation dependent and the following factors should be taken into account: (i) how intrusive the profiling process is; (ii) the expectations and wishes of the individuals you target; (iii) the way you deliver the advertisement; and (iv) how vulnerable the individuals you target are.

[22] Many email marketing companies use web beacons to track a recipient’s activity when they open an email (including things like open rates and click through rates). If you use a marketing company or mailing list provider (e.g. MailChimp) that uses web beacons, you should say so and identify that provider and provide a link to their privacy policy. If you use any other tracking technologies you must disclose them as well.

[23] If you use web beacons, you should inform users of whether you use them in your emails and/or on your website.

[24] This entire section can be deleted if you are confident that your website, email server and any third party marketing companies you engage with do not use web beacons or similar tracking technologies. If you are in any doubt, it is recommended that you include this paragraph in this policy.

[25] If you use analyse information such as open rates, click through rates and any other ways in which individuals engage with your emails (i.e. to build up a profile about them and their behaviour), you will be conducting ‘profiling’ and you will need to disclose this in the section of your privacy policy entitled ‘Our use of automated decision making and profiling’. If you automate decisions in relation to individuals using their personal information e.g. you automate the decision to send out emails based on engagement rates, you will need to disclose this automated decision making in your privacy policy as well.

[26] Insert this clause if you use Facebook Pixel. Please note, however, that we Facebook’s GDPR compliance status is beyond our control and Facebook has already been fined for breaches of EU privacy law under current legislation, in particular for not getting proper consent to the processing of personal information (you can find out more about this here: https://uk.reuters.com/article/us-facebook-spain-fine/facebook-fined-1-2-million-euros-by-spanish-data-watchdog-idUKKCN1BM1OU). If you wish to use Facebook Pixel, it will therefore be very important for you to get explicit consent (through the use of a cookie compliance tool) for the use of Facebook Pixel on your website, as you should not rely on the consent obtained by Facebook for its third party advertisers to display advertisements. Even if you have obtained such consent, it is possible (even likely) that a regulator could find that Facebook’s use of information shared with it is not lawful and there is still therefore a risk that sharing information with Facebook could result in you being fined. We would therefore recommend that you do not use Facebook Pixel until Facebook’s GDPR-compliance status is confirmed. We also recognise, however, that many businesses find Facebook advertising a particularly cost-effective way of marketing and if you wish to continue to use Facebook Pixel after 25 May 2018, this cookie policy will help you mitigate (but not remove) the risks. This is for the simple reason that Facebook’s compliance is completely beyond our control.

[27] You will need to disclose in detail in your privacy policy how you automate decisions to display advertisements to users on Facebook including how you profile them using various criteria in to do so e.g. using Facebook’s custom audiences.

[28] If you use Facebook Pixel in an intrusive manner you will need to obtain consent from the user to process their information (cookie and Facebook user data about them) for such purposes and will not be able to rely on your legitimate interests. This is separate consent from the consent the user gives to the placement of cookies on their device which is required under the Privacy and Electronic Communications Regulations. It is currently unclear whether, in practice, you will need to gain a separate consent for processing personal information contained in or derived from Facebook Pixel and consent for placing Facebook cookies on a user’s device and we expect that, in practice (due to the practical unworkability of obtaining two separate consents) consent to Facebook Pixel cookies being placed on the user’s device will constitute consent for the purposes for which a website processes personal information contained in or derived from its use of Facebook Pixel. However, the position is not clear and no guidance has yet been released on this issue. You should therefore assume that separate consents will be required as this is the strict legal position.

 

When consent is required

In terms of the level of intrusiveness of advertising and other tracking cookies required to trigger the requirement to obtain consent to process someone’s personal information (cookie information) for these purposes, this is not yet entirely clear. However, guidance produced by the Article 29 Working Party has indicated that advertising to a particular demographic e.g. women in London, would not be too intrusive and would not have a significant effect on individuals. However, targeting advertisements to vulnerable adults or minority groups would (e.g. showing gambling advertisements to someone in financial difficulties) and, accordingly, consent would be required. The guidance indicates that whether consent is required will always be fact and situation dependent and the following factors should be taken into account: (i) how intrusive the profiling process is; (ii) the expectations and wishes of the individuals you target; (iii) the way you deliver the advertisement; and (iv) how vulnerable the individuals you target are.

[29] Insert this wording if you use web beacons or Facebook Pixel and complete the web beacons section below.

[30] Insert description of the cookie management tool you use on your website. Note that, due to the requirement to obtain explicit and granular consent prior to placing different types of non-essential cookies on a user’s device (if not individual non-essential cookies), the need for a cookie management will effectively become mandatory if you use any non-essential cookies on your website. There are several tools available, including Cookie Control by CIVIC, which is the solution the Information Commissioner’s Office uses (ICO) and which is available here: https://www.civicuk.com/cookie-control

[31] As web beacons are non-essential technologies like cookies, you will need to get your users’ explicit consent to use them before you use them in marketing emails or on your website. An appropriate way to do this could include getting them to tick an opt-in box when they sign up for your mailing list indicating that they are happy for you to use web beacons in your marketing emails. However, it must be just as easy to withdraw consent to the use of such technologies as it is to give it, so you would need a mechanism to allow them to withdraw consent in the same way as they gave it e.g. by unticking a box on your website. This would clearly require some web development work to implement and could be tricky. The alternative is to not use web beacons at all in your marketing emails. Unfortunately, it is not currently clear whether providing an email address that someone can write to withdraw their consent to your use of web beacons is sufficient to constitute a method which is ‘just as easy’ as ticking box and how strictly this meaning will be interpreted. We would recommend that you err on the side of caution and assume it will be strictly enforced and therefore you must provide an identical means of withdrawing consent as giving it e.g. by having a box or setting where users can change their preference for your use of web beacons back and forth (i.e. a ‘privacy dashboard’ of sorts). For further information, please see the ICO’s guidance here: https://ico.org.uk/for-organisations/guide-to-data-protection/privacy-notices-transparency-and-control/

[32] You will need to ensure that the cookie control tool you use can block Facebook Pixel from collecting information about users of your website.

European Interactive Digital Advertising Alliance Tool

You can opt out of Facebook and other companies that participate in the Digital Advertising Alliance in Europe from showing you interest based ads by visiting http://www.youronlinechoices.com, selecting your country, clicking ‘Your Ad Choices’, then locating Facebook (and any other companies you want to block) and selecting the ‘Off’ option.

Copyright, credit and logo

This Cookies Policy is based on a template provided by GDPR Privacy Policy. For further information, please visit https://gdprprivacypolicy.org

The copyright in this Cookies Policy is either owned by, or licensed to, us and is protected by copyright laws around the world and copyright protection software. All intellectual property rights in this document are reserved. Where we display the GDPR Privacy Policy logo on our website, this is used to indicate that we have adopted a privacy policy template provided by GDPR Privacy Policy as the basis for this Privacy Policy.