PRIVACY POLICY

This Privacy Policy will help you understand what data we collect, why we collect it, and what we do with it.

• 1. Introduction

• 1.1 We are committed to safeguarding the privacy of our website visitors.
• 1.2 This policy applies where we are acting as a data controller with respect to the personal data of our website visitors; in other words, where we determine the purposes and means of the processing of that personal data.
• 1.3 We will ask you to consent to our use of cookies in accordance with the terms of this policy when you first visit our website. OR By using our website and agreeing to this policy, you consent to our use of cookies in accordance with the terms of this policy.
• 1.4 Our website incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can specify whether you would like to receive direct marketing communications and limit the publication of your information.
• 1.5 In this policy, “we”, “us” and “our” refer to, Data Protection Officer. For more information about us, see Section 13.

• 2.   How we use your personal data

• Unless you voluntarily submit your information to us by completing an enquiry form or using our services, we will be unable to personally identify you.
• 2.1 In this Section 3 we have set out:
• (a) the general categories of personal data that we may process; are name, address, email address, telephone number, company and other data that could directly or indirectly identify you.
  
• (b) the purposes for which we may process personal data; and
  
• (c) the legal bases of the processing.
• 2.2 We may process data about your use of our website and services (“usage data“). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is consent OR our legitimate interests, namely monitoring and improving our website and services. Third party services such as Google Analytics are used to collect standard internet log information and compile reports using details of visitors behaviour to improve our website. We also utilise WordPress.com which is run by Automattic Inc to publish our website who could collect anonymous information about our site visitors. These third parties collect information to inform our research and marketing decisions such as the pages you visit, how long you spend on each page, how you got to the site, and what you click on while visiting the site.
• 2.3 We may process your information included in your personal profile on our website (“profile data“). The profile data may include your name, address, telephone number, email address, profile pictures, gender, date of birth, relationship status, interests and hobbies, educational details and employment details. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services. The legal basis for this processing is consent OR our legitimate interests, namely the proper administration of our website and business OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
  
• 2.4 We may process information that you post for publication on our website or through our services (“publication data“). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is consent OR our legitimate interests, namely the proper administration of our website and business OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
  
• 2.5 We may process information contained in any enquiry you submit to us regarding goods and/or services (“enquiry data“). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is consent.
  
• 2.6 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data“). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
• 2.7 We may process information contained in or relating to any communication that you send to us (“correspondence data“). The correspondence data may include [the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
• 2.8 We may process personal contact details. This data may include name, email telephone number. The source of this data is Linkedin, Newsletter broadcasts, Networking. This data may be processed for long-term nurture with your initial consent. The legal basis for this processing is consent OR our legitimate interests, namely OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
• 2.9 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely [the protection and assertion of our legal rights, your legal rights and the legal rights of others.
• 2.10 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
• 2.11 In addition to the specific purposes for which we may process your personal data set out in this Section 3, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
  
• 2.12 Please do not supply any other person’s personal data to us, unless we prompt you to do so.

• 3. Providing your personal data to others

• 3.1 We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.
• 3.2 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
•  
• 4. We may disclose your enquiry data to one or more of those selected third party suppliers of goods and services identified on our website for the purpose of enabling them to contact you so that they can offer, market and sell to you relevant goods and/or services. Each such third party will act as a data controller in relation to the enquiry data that we supply to it; and upon contacting you, each such third party will supply to you a copy of its own privacy policy, which will govern that third party’s use of your personal data.
• 4.1 In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

• 5. International transfers of your personal data

• 5.1 In this Section 5, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).
• 5.2 We and our other group companies have offices and facilities in India and Gibraltar. The European Commission has made an “adequacy decision” with respect to the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission, a copy of which can be obtained from here.
• 5.3 The hosting facilities for our website are situated in USA and India. The European Commission has made an “adequacy decision” with respect to the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission, a copy of which you can obtain from here.
• 5.4 You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

• 6. Retaining and deleting personal data

• 6.1 This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
• 6.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
• 6.3 We will retain your personal data as follows:
• (a) Name, Email and Phone will be retained for a minimum period of 1 month following 25th May 2018, and for a maximum period of 6 years following 25th May 2018. Depending on the level of involvement with the Company.
  
• 6.4 In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:
• (a) the period of retention of a name, email, a phone number will be determined based on company communications.
• (b) If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by writing to us or emailing marketing@redribbon.co.
• (c) We retain information for all active clients and site visitors until a request for deletion or anonymisation has been received subject to exceptions if there is an unresolved issue on the account (for example an unpaid invoice), for genuine business interests including fraud prevention and if we are required to by relevant laws.

• 7. Amendments

• 7.1 We may update this policy from time to time by publishing a new version on our website.
• 7.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
• 7.3 We may notify you of changes to this policy [by email or through the private messaging system on our website.

• 8. Your rights

• 8.1 You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to:
• (a) the payment of a fee (currently fixed at GBP 100); and
• (b) the supply of appropriate evidence of your identity [(for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address).
• 8.2 We may withhold personal information that you request to the extent permitted by law.
• 8.3 You may instruct us at any time not to process your personal information for marketing purposes.
• 8.4 In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.
  
  OR
  
  

• 9. Your rights

• 9.1 In this Section 8, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
• 9.2 Your principal rights under data protection law are:
• (a) the right to access;
• (b) the right to rectification;
• (c) the right to erasure;
• (d) the right to restrict processing;
• (e) the right to object to processing;
• (f) the right to data portability;
• (g) the right to complain to a supervisory authority; and
• (h) the right to withdraw consent.
• 9.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
• 9.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
• 9.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: [the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed]. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: [for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims].
• 9.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
• 9.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
• 9.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
• 9.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
• 9.10 To the extent that the legal basis for our processing of your personal data is:
• (a) consent; or
• (b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,
  and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
• 9.11 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
• 9.12 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
• 9.13 You may exercise any of your rights in relation to your personal data by written notice to us.