1. Introduction
1.1 We are
committed to safeguarding the privacy of our website visitors, customers and all
those whose data we process.
1.2 This policy
applies where we are acting as a data controller with respect to the personal
data of such persons; in other words, where we determine the purposes and means
of the processing of that personal data.
1.3 We use
cookies on our website. Insofar as those cookies are not strictly necessary for
the provision of our website, we will ask you to consent to our use of cookies
when you first visit our website.
1.4 In this
policy, "we", "us" and "our"
refer to the data controller Lewis Tandy.
2. Credit
2.1 This document
was created using a template from Docular (https://seqlegal.com/free-legal-documents/privacy-policy).
3. The personal data that we collect
3.1 In this section
we have set out the general categories of personal data that we process and, in
the case of personal data that we did not obtain directly from you, information
about the source and specific categories of that data.
3.2 We may
process data enabling us to get in touch with you ("contact data").
The contact data may include your address, telephone number and email address.
The source of the contact data is you. If you log into our website using a
social media account, we will obtain elements of the contact data from the
relevant social media account provider.
3.3 We may
process your website user account data ("account data"). The
account data may include your account identifier, name, email address, account
creation and modification dates, website settings and marketing preferences.
The primary source of the account data is you, although some elements of the
account data may be generated by our website. If you log into our website using
a social media account, we will obtain elements of the account data from the
relevant social media account provider.
3.4 We may
process information relating to transactions, including purchases of services,
that you enter into with us and/or through our website ("transaction
data"). The transaction data may include your name, your contact
details, your payment card details (or other payment details) and the
transaction details. The source of the transaction data is you and/or our
payment services provider.
3.5 We may
process information contained in or relating to any communication that you send
to us or that we send to you ("communication data"). The
communication 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.
3.6 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.
3.7 We may
process your personal data obtained from the Department of Education ("national
pupil database data"). The national
pupil database data may include your pupil identifier, the school you attend,
your year group, the distance you live from the school and the Lower Super
Output Area associated with your address.
4. Purposes of processing and legal bases
4.1 In this section,
we have set out the purposes for which we may process personal data and the
legal bases of the processing.
4.2 Operations
- We may process your personal data for the purposes of operating our
website, the processing and fulfilment of orders, providing our services, generating
invoices, bills and other payment-related documentation. The legal basis for
this processing is our legitimate interests, namely the proper administration
of our website, services and business.
4.3 Relationships
and communications - We may process contact data, account data, transaction
data and/or communication data for the purposes of managing our relationships,
communicating with you (excluding communicating for the purposes of direct
marketing), providing support services and complaint handling. The legal basis
for this processing is our legitimate interests, namely communications with our
website visitors, service users and individual customers, the maintenance of
relationships, and the proper administration of our website, services and
business.
4.4 Direct
marketing - We may process contact data, account data and/or transaction
data for the purposes of creating, targeting and sending direct marketing
communications by email. The legal basis for this processing is consent or our
legitimate interests, namely promoting our business and communicating marketing
messages and offers to our website visitors and service users.
4.5 Research and analysis - We may process usage data and/or transaction data for the purposes of researching and analysing the use of our website and services, as well as researching and analysing other interactions with our business. The legal basis for this processing is our legitimate interests, namely monitoring, supporting, improving and securing our website, services and business generally.
4.6 We
may process National School Census data for the purposes of researching and analysing
pupil distributions around schools and other school related statistics. The legal basis for this processing is our
legitimate interests, namely providing catchment area information to our
website visitors and service users.
4.7 Record
keeping - We may process your personal data for the purposes of creating
and maintaining our databases, back-up copies of our databases and our business
records generally. The legal basis for this processing is our legitimate
interests, namely ensuring that we have access to all the information we need
to properly and efficiently run our business in accordance with this policy.
4.8 Security -
We may process your personal data for the purposes of security and the
prevention of fraud and other criminal activity. The legal basis of this
processing is our legitimate interests, namely the protection of our website,
services and business, and the protection of others.
4.9 Insurance
and risk management - We may process your personal data where necessary for
the purposes of obtaining or maintaining insurance coverage, managing risks
and/or obtaining professional advice. The legal basis for this processing is
our legitimate interests, namely the proper protection of our business against
risks.
4.10 Legal
claims - We may process your personal data 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.
4.11 Legal
compliance and vital interests - We may also process 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.
5. Providing your personal data to others
5.1 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 and/or obtaining professional advice.
5.2 Your personal
data held in our website database will be stored on the servers of our hosting
services provider 1&1 IONOS (https://www.ionos.co.uk/).
5.3 We may
disclose your personal data to our suppliers or subcontractors insofar as
reasonably necessary for the proper administration of our website, services and
business.
5.4 Financial
transactions relating to our website and services may be handled by our payment
services provider Stripe. We will share transaction data with our payment
services providers only to the extent necessary for the purposes of processing
your payments, refunding such payments and dealing with complaints and queries
relating to such payments and refunds. You can find information about the
payment services providers' privacy policies and practices at https://stripe.com/en-gb/privacy.
5.5 In addition
to the specific disclosures of personal data set out in this section, 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.
6. International transfers of your personal data
6.1 In this section
we provide information about the circumstances in which your personal data may
be transferred to countries outside the United Kingdom and the European
Economic Area (EEA).
6.2 The hosting
facilities for our website are situated in Germany. The competent data protection authorities
have made an "adequacy decision" with respect to the data protection
laws of Germany. Transfers to this country will be protected by appropriate
safeguards, namely the use of standard data protection clauses adopted or
approved by the competent data protection authorities.
6.3 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.
7. Retaining and deleting personal data
7.1 This section
sets out our data retention policies and procedures, which are designed to help
ensure that we comply with our legal obligations in relation to the retention
and deletion of personal data.
7.2 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.
7.3 We will
retain your personal data as follows:
(a) contact data
will be retained for a minimum period of 1 month following the date of the most
recent contact between you and us, and for a maximum period of 20 years;
(b) account data
will be retained for a minimum period of 1 month following the date of closure
of the relevant account, and for a maximum period of 20 years following that
date;
(c) transaction
data will be retained for a minimum period of 1 month following the date of the
transaction, and for a maximum period of 20 years following that date;
(d) communication
data will be retained for a minimum period of 1 month following the date of the
communication in question, and for a maximum period of 20 years following that
date;
(e) usage data
will be retained for a maximum of 20 years following the date of collection;
and
(f) National
pupil database data will be retained for a maximum period of 1 year following the
date we were provided access to it by the Office for National Statistics.
7.4 Notwithstanding
the other provisions of this section, we may retain your personal data where
such retention 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.
8. Your rights
8.1 In this section,
we have listed the rights that you have under data protection law.
8.2 Your
principal rights under data protection law are:
(a) the right
to access - you can ask for copies of your personal data;
(b) the right
to rectification - you can ask us to rectify inaccurate personal data and
to complete incomplete personal data;
(c) the right
to erasure - you can ask us to erase your personal data;
(d) the right
to restrict processing - you can ask us to restrict the processing of your
personal data;
(e) the right
to object to processing - you can object to the processing of your personal
data;
(f) the right
to data portability - you can ask that we transfer your personal data to
another organisation or to you;
(g) the right
to complain to a supervisory authority - you can complain about our
processing of your personal data; and
(h) the right
to withdraw consent - to the extent that the legal basis of our processing
of your personal data is consent, you can withdraw that consent.
8.3 These rights
are subject to certain limitations and exceptions. You can learn more about the
rights of data subjects by visiting https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.
8.4 You may
exercise any of your rights in relation to your personal data by written notice
to us, using the contact details set out below.
9. About cookies
9.1 A cookie is a
file containing an identifier (a string of letters and numbers) that is sent by
a web server to a web browser and is stored by the browser. The identifier is
then sent back to the server each time the browser requests a page from the
server.
9.2 Cookies may
be either "persistent" cookies or "session" cookies: a
persistent cookie will be stored by a web browser and will remain valid until
its set expiry date, unless deleted by the user before the expiry date; a
session cookie, on the other hand, will expire at the end of the user session,
when the web browser is closed.
9.3 Cookies may
not contain any information that personally identifies a user, but personal
data that we store about you may be linked to the information stored in and
obtained from cookies.
10. Cookies that we use
10.1 We use cookies
for the following purposes:
(a) authentication
and status - we use cookies to identify you when you visit our website and
as you navigate our website, and to help us determine if you are logged into
our website;
(b) personalisation
- we use cookies to store information about your preferences and to personalise
our website for you;
(d) security
- we use cookies as an element of the security measures used to protect user
accounts, including preventing fraudulent use of login credentials, and to
protect our website and services generally; and
(f) analysis
- we use cookies to help us to analyse the use and performance of our website and
services;
11. Cookies used by our service providers
11.1 Our service
providers use cookies and those cookies may be stored on your computer when you
visit our website.
11.2 We use Google
Analytics. Google Analytics gathers information about the use of our website by
means of cookies. The information gathered is used to create reports about the
use of our website. You can find out more about Google's use of information by
visiting https://www.google.com/policies/privacy/partners/
and you can review Google's privacy policy at https://policies.google.com/privacy.
12. Managing cookies
12.1 Most browsers
allow you to refuse to accept cookies and to delete cookies. The methods for
doing so vary from browser to browser, and from version to version. You can
however obtain up-to-date information about blocking and deleting cookies via
these links:
(a) https://support.google.com/chrome/answer/95647
(Chrome);
(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
(Firefox);
(c) https://help.opera.com/en/latest/security-and-privacy/
(Opera);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies
(Internet Explorer);
(e) https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac
(Safari); and
(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy
(Edge).
12.2 Blocking all
cookies will have a negative impact upon the usability of many websites.
12.3 If you block
cookies, you will not be able to use all the features on our website.
13. Amendments
13.1 We may update
this policy from time to time by publishing a new version on our website.
13.2 You should
check this page occasionally to ensure you are happy with any changes to this
policy.
13.3 We may notify
you of changes to this policy by email.
14. Our details
14.1 This website
is owned and operated by Locrating Ltd.
14.2 We are
registered in England and Wales under registration number 7236786, and our
registered office is at Belmont Suite, Paragon Business Park, Chorley New Road, Horwich, Way, Bolton, BL6 6HG.
14.3 You can
contact us:
(c) by telephone,
on the contact number published on our website; or
(d) by email,
using the email address published on our website.
15. Data protection officer
15.1 Our data
protection officer's contact details are: [email protected]