INTRODUCTION
Welcome to the Living Redefined privacy notice.
Living Redefined is a group of limited companies operating its businesses under the “Living Redefined” brand. This privacy notice relates to the use of your personal data by the following Living Redefined companies:
* Living Redefined Ltd;
* Living Redefined Management Ltd
When we refer to “Living Redefined”, “we”, “us” or “our” in this privacy notice, we are referring to all companies identified above.
Living Redefined respects your privacy and is committed to protecting your personal data.
While each company may collect your personal data through the Living Redefined website (see section “how we collect your personal data”), the personal data collected by each company is collected independently and stored separately. There is no joint access to personal data, and we will only share data between Living Redefined companies with your prior consent.
We keep our privacy notice under regular review. You agree to be bound by our privacy policy as amended from time to time.
1. WHO WE ARE AND OTHER IMPORTANT INFORMATION
1.1 Purpose of this privacy notice
This privacy notice gives you information on how each Living Redefined company collects and processes your personal data, including any data you may provide through our website when you register your interest in our products and services, follow any links on our website or contact us via our webform.
The website is not intended for children, and we do not knowingly collect personal data relating to children.
It is important that you read this privacy notice, along with any other privacy notices or fair processing policy we may provide you on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your personal data. This privacy notice will supplement any other privacy notices or privacy policies we may bring to your attention from time to time and is not intended to override them.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if any of your personal details change during the course of your relationship with us.
1.2 Our data privacy manager
Living Redefined has appointed a joint data privacy manager who is responsible for overseeing questions in relation to this privacy notice, the processing of your personal data by our companies and any other data protection issues you may have. If you have any questions about this privacy notice, including any requests to exercise your rights as a data subject (see section “Your legal rights” below), please contact the data privacy manager, marking your correspondence “FAO Living Redefined Data Privacy Manager”, using the following details:
Postal address: 23 Main Street, Garforth, Leeds, England, LS25 1DS
Email address: jack@livingredefined.co.uk
Telephone: 07976 198 079
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so we would encourage you to contact us in the first instance.
1.3 Third-party links
This website may include links to third-party websites. Clicking on those links or enabling those connections may allow third parties to collect or share personal data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
2. PERSONAL DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information which identifies or enables the identification of a living individual. It does not include data which has been anonymised (i.e. data from which it is no longer possible to identify a living individual).
2.1 Types of Personal Data
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
(a) Identity Data – your first name, maiden name, last name, username or similar identifier and/or your title.
(b) Contact Data – your billing address, delivery address, email address and telephone numbers.
(c) Financial Data – your bank account and payment card details.
(d) Transaction Data – details about payments to and from you and details of products and services you have purchased from us.
(e) Technical Data – your internet protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our website.
(f) Profile Data – your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
(g) Usage Data – information about how you use our website, productsand services.
(h) Marketing and Communications Data – your preferences in relation to receiving direct marketing from us and our third parties and your communication preferences.
2.2 Aggregated Data
We also collect, use and share aggregated data, such as statistical or demographic data for a variety of purposes.
Aggregated data may be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity.
For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, at any time we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we will treat the combined data as personal data which will be used in accordance with this privacy notice.
2.3 Special Category Data
We do not collect any special category data about you (special category data includes information about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership and/or health and genetic and biometric data). We will also not collect any information about criminal convictions and offences.
2.4 What happens if you fail to provide personal data?
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may
not be able to perform the contract we have or are trying to enter into with you (for example, for Y Ltd may be unable to provide you with training services). In this case, we may have to cancel our contract or arrangement with you. We will notify you if this is the case at the time.
3. HOW YOUR PERSONAL DATA IS COLLECTED
We use the following different methods to collect data from and about;
(a) Direct interactions
You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise.
This includes personal data you provide when you:
(i) fill out any form on our website;
(ii) create an account on our website;
(iii) contact us via our webform;
(iv) subscribe to our services or publications;
(v) request marketing to be sent to you;
(vi) enquire about our products or services or enter into a contract with us for the provision of products or services; or
(vii) give us feedback or otherwise make contact with us.
(b) Automated technologies or interactions
As you interact with our website, we will automatically collect Usage Data, Profile Data and Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive Technical Data about you if you visit other websites which employ our cookies. Please see the “Cookie Policy” section below for further details.
(c) Third parties or publicly available sources
We will receive personal data about you from various third parties and public sources as set out below:
(i) Technical Data from the following parties:
– analytics providers such as Google based outside the UK;
– Hubspot who are based in the UK and host and maintain our website (or such other website hosting and maintenance providers as we may use from time to time).
(ii) Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the UK.
LIVING REDEFINED MANAGEMENT LTD
This section applies only to the activities of Living Redefined Management Ltd (“Living Redefined Management”) as controller of your personal data. It explains how Living Redefined Management uses your personal data, when it may disclose your data, what security measures it has in place to protect your data and how long it will retain your data once collected.
4. HOW WE USE YOUR PERSONAL DATA
4.1 Our legal basis for processing your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
(a) where you have given us consent to process your personal data (which may include consent to share your personal data with certain third parties);
(b) if we need to do so to perform a contract we are about to enter into, or have entered into, with you;
(c) when it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; and
(d) where we need to do so to comply with a legal obligation.
See the Glossary section below to find out more about the types of lawful bases that we will rely on to process your personal data.
Where we are relying on consent as the lawful basis for processing your personal data, you have the right to withdraw consent at any time by contacting
our data privacy manager using the contact details set out above.
4.2 Purposes for which we will use your personal data
We have set out below the ways we plan to use your personal data and which of the legal bases we rely on to do so in each case. Where relevant, we have
also identified what our legitimate interests are.
Note that we may process your personal data based upon more than one lawful basis depending on the specific purpose for which we are using your data.
Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been
set out in the table below.
| Purpose/Activity | Type of data | Lawful basis for processing, including basis of legitimate interest |
|---|---|---|
| To manage our relationship with you which will include: *Notifying you about changes to our terms or privacy notice *Asking you to leave a review or take a survey |
*Identity *Contact *Profile *Marketing and Communications |
*Performance of a contract with you *Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) |
| To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
*Identity *Contact *Technical |
Performance of a contract with you (for providing training services) |
| To process and deliver your order including: *Arranging and delivering training *Managing payments, fees and charges *Collecting and recovering money owed to us |
*Identity *Contact *Financial *Transaction *Marketing and Communications |
*Necessary for our legitimate interests (to run our business, including the provision of administration and IT services, network security, the prevention of fraud and in the context of a business reorganisation or group restructuring exercise) |
| To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you |
*Identity *Contact *Profile *Usage *Marketing and Communications *Technical |
*Consent *Necessary for our legitimate interests (to study how customers use our website, interest in our products/services, to develop them, grow our business and inform our marketing strategy) |
| To use data analytics to improve our website, products/services, marketing, customer relationships and experiences | *Technical *Usage |
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
| To make suggestions and recommendations to you about goods or services that may be of interest to you | *Identity *Contact *Technical *Usage *Profile *Marketing and Communications |
*Consent *Necessary for our legitimate interests (to develop our products/services and grow our business) |
| To share your details with certain third parties for the purpose of such third parties contacting you to discuss products and services you have expressed an interest in by registering on our website, namely http://www.livingredefined.co.uk, where you have given us consent to share such information. |
*Identity *Contact |
*Consent |
4.3 Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You can make certain decisions
about your personal data use by contacting our data privacy manager.
(a) Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you have consented to us contacting you for such marketing purposes (including when you request such information from us about our services) and you have not opted out of receiving that marketing.
(b) Third-party marketing
We only share your personal data with any third party for marketing purposes if we have obtained your express consent to do so.
(c) Right to object
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us or the relevant third party at any time.
4.4 Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts our website may become inaccessible or not function properly. For more information about the cookies we use, please the “Cookie Policy” section below.
4.5 Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for any new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. DISCLOSURE OF YOUR PERSONAL DATA
We may share your personal data with the parties set out below for the purposes set out in section 4.2 above:
(a) Internal Third Parties and External Third Parties as set out in the Glossary.
(b) Living Redefined will communicate directly with you the specific third party with whom we will share your information and its specific purpose, should the need arise in the future. Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. If new owners acquire our business, such new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. INTERNATIONAL TRANSFERS
We will not transfer your personal data outside the UK.
7. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way
and from being accidentally or unlawfully altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and
other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. DATA RETENTION
8.1 Our retention of your personal data
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We will retain your personal data for marketing purposes where you have consented for us to do so. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
By law we have to keep certain information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease
being customers for tax purposes. In some circumstances, we may be legally required to keep data for longer. We will never retain your personal data for longer than is necessary taking into account the above information. You can contact our data privacy manager if you have any queries regarding how long your personal data will be retained by us. In certain circumstances, you may have the right to ask us to delete your data (see “Your legal rights” section for further information).
We may anonymise your personal data (so that it can no longer identify or be associated with you) for research or statistical purposes. Where we do so, we are able to retain and use this information indefinitely without further notice to you.
This section applies only to the activities of Living Redefined Management (Living Redefined Management Ltd”) as controller of your personal data. It explains how Living Redefined Management uses your personal data, when it may disclose your data, what security measures it has in place to protect your data and how long it will retain your data once collected.
9, HOW WE USE YOUR PERSONAL DATA
9.1 Our legal basis for processing your personal data
We will only use your personal data when the law allows us to. Most commonly,
we will use your personal data in the following circumstances:
(a) where you have given us consent to process your personal data (which may include consent to share your personal data with certain third parties);
(b) if we need to do so to perform a contract we are about to enter into, or have entered into, with you;
(c) when it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; and
(d) where we need to do so to comply with a legal obligation.
See the Glossary section below to find out more about the types of lawful bases that we will rely on to process your personal data. Where we are relying on consent as the lawful basis for processing your personal data, you have the right to withdraw consent at any time by contacting our data privacy manager using the contact details set out above.
9.2 Purposes for which we will use your personal data
We have set out below the ways we plan to use your personal data and which of the legal bases we rely on to do so in each case. Where relevant, we have
also identified what our legitimate interests are.
Note that we may process your personal data based upon more than one lawful basis depending on the specific purpose for which we are using your data.
Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
| Purpose/Activity | Type of data | Lawful basis for processing, including basis of legitimate interest |
|---|---|---|
| To allow us to contact you to arrange training you have expressed an interest in by registering on our website | *Identity *Contact |
*Consent |
| To register you as a new customer | *Identity *Contact |
Performance of a contract with you (for providing training services) |
| To process and deliver your order including: *Arranging and delivering training *Managing payments, fees and charges *Collecting and recovering money owed to us |
*Identity *Contact *Financial *Transaction *Marketing and Communications |
*Performance of a contract with you *Necessary for our legitimate interests (to recover debts due to us) |
| To manage our relationship with you which will include: *Notifying you about changes to our terms or privacy notice *Asking you to leave a review or take a survey |
*Identity *Contact *Profile *Marketing and Communications |
*Performance of a contract with you *Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) |
| To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | *Identity *Contact *Technical |
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you |
| To deliver relevant website content and dvertisements to you and measure or understand the effectiveness of the advertising we serve to you | *Identity *Contact *Profile *Usage *Marketing and Communications *Technical |
*Consent *Necessary for our legitimate interests (to study how customers use our website, interest in our products/services, to develop them, to grow our business and to inform our marketing strategy) |
| To use data analytics to improve our website, products/services, marketing, customer relationships and experiences | *Technical *Usage |
*Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
| To make suggestions and recommendations to you about goods or services that may be of interest to you | *Identity *Contact *Profile *Usage *Marketing and Communications *Technical |
*Consent *Necessary for our legitimate interests (to develop our products/services and grow our business) |
9.3 Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You can make certain decisions about your personal data use by contacting our data privacy manager.
(a) Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have consented to us contacting you for such marketing purposes (including when you request such information from us about our services) and you have not opted out of receiving that marketing
(b) Third-party marketing
We only share your personal data with any third party for marketing purposes if we have obtained your express consent to do so.
(c) Right to object
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us or the relevant third party at any time.
9.4 Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our website may become inaccessible or not function properly. For more information about the cookies we use, please see the “Cookie Policy” section below.
9.5 Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and
that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for any new purpose is compatible with
the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
10. DISCLOSURE OF YOUR PERSONAL DATA
We may share your personal data with the parties set out below for the purposes set out in section 4.2 above:
(a) Internal Third Parties and External Third Parties as set out in the Glossary.
(b) Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. If new owners acquire our business, such new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
11. INTERNATIONAL TRANSFERS
We will not transfer your personal data outside the UK.
12. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way and from being accidentally or unlawfully altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
13. DATA RETENTION
13.1 Our retention of your personal data
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We will retain your personal data for marketing purposes where you have consented for us to do so. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
By law we have to keep certain information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes. In some circumstances, we may be legally required to keep data for longer. We will never retain your personal data for longer than is necessary taking into account the above information.
You can contact our data privacy manager if you have any queries regarding how long your personal data will be retained by us.
In certain circumstances, you may have the right to ask us to delete your data (see “Your legal rights” section for further information).
We may anonymise your personal data (so that it can no longer identify or be associated with you) for research or statistical purposes. Where we do so, we are able to retain and use this information indefinitely without further notice to you.
YOUR LEGAL RIGHTS
As a data subject, you have certain rights under data protection law in relation to your personal data. These rights, and how to exercise them, are explained in detail below.
14. YOUR RIGHTS AS A DATA SUBJECT
As a data subject, you have the right to:
14.1 Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
14.2 Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
14.3 Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request for erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
14.4 Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
14.5 Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following
scenarios:
(a) if you want us to establish the data’s accuracy;
(b) where our use of the data is unlawful but you do not want us to erase it;
(c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; and
(d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
14.6 Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
14.7 Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing
carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
15. EXERCISING YOUR RIGHTS
If you wish to exercise any of your rights under data protection law, contact our data privacy manager using one of the methods listed above.
15.1 No fee usually required
Usually, you will not have to pay a fee to access your personal data or to exercise any of the data subject rights under data protection law. We may however charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
16. WHAT WE MAY NEED FROM YOU
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data or to exercise any of your other legal rights. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
17. TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
COOKIE POLICY
18. USE OF COOKIES ON OUR WEBSITE
18.1 A cookie is a text-only string of information that a website transfers to the cookie file of the browser on your computer’s hard disk so that the website can remember who you are. A cookie will typically contain the name of the domain from which the cookie has come, the ‘lifetime’ of the cookie and a value, usually a randomly generated unique number. Two types of cookie are used on the website:
(a) Session cookies which are temporary cookies that remain in the cookie file on your browser until you close the browser; or
(b) Persistent cookies which remain in the cookie file on your browser for much longer (though how long will depend on the lifetime of the specific cookie). Cookies can help a website to arrange content to match your preferred interests more quickly. Most major websites use cookies. Cookies cannot be used by themselves to identify you.
18.2 We use session cookies to allow you to carry information across pages of our website and avoid having to re-enter information.
18.3 We use cookies;
(a) to help us to recognize you as a unique visitor (just a randomly generated number) when you return to our website and to allow us to tailor content or advertisements to match your preferred interests or to avoid showing you the same adverts repeatedly;
(b) within research surveys you ensure you are not invited to complete a questionnaire too often or after you have already done so; and (c) to track whether advertisements are clicked on by users.
18.4 On occasion third parties may also serve cookies via the website which are used for the following purposes:
(a) to compile anonymous, aggregated statistics that allow us to understand how users use our website and to help us improve the structure of our website. We cannot identify you personally in this way; and
(b) to serve advertisements on our website and track whether these advertisements are clicked on by users.
18.5 You can accept or decline cookies by modifying the settings in your browser. However, you may not be able to use all of the interactive features of our website if cookies are disabled. For information about how to disable cookies in your browser please visit the About Cookies website.
GLOSSARY
19. LAWFUL BASIS
19.1 Consent
This means that you have expressly consented to us processing your personal data for one or more specific purposes. To be valid under data protection law, your consent must meet certain standards and you have the right to withdraw your consent at any time.
19.2 Legitimate Interest
This means that our processing of your personal data is necessary for the purpose of our legitimate interests or those of a third party and those interests are not overridden by your interests or fundamental rights or freedoms. An example of a legitimate interest is our interest in conducting and managing our business to give you the best service/product and the best and most secure experience. Where we rely upon legitimate interests, we make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to do so by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
19.3 Performance of Contract
This means that processing your personal data is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
19.4 Comply with a legal obligation
This means that processing your personal data is necessary for us to comply with a legal obligation that we are subject to (such as a statutory obligation).
20. THIRD PARTIES
20.1 Internal Third Parties
Our holding or subsidiary companies where those companies act as joint
controllers or our processors. This includes, who hosts and maintains the website. Such companies are based in the United Kingdom and will only use your data in the course of providing us with IT and system administration services, to undertake leadership reporting.
20.2 External Third Parties
(a) Service providers based in the United Kingdom who provide us with IT and system administration services.
(b) Our professional advisers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
(c) HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.