Privacy Policy General

OUR UK WEBSITE PRIVACY POLICY

BACKGROUND:

We at The Rider Firm understand that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all those we do business with or who contact us at our website, [www.theriderfirm.cc] (“Our Site”). We will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.

1. Information About Us

We are Its Cycling Limited trading as The Rider Firm, a Company registered in England under company number 08583700.

Our email address is: [Team@TheRiderFirm.CC]

Our postal address/registered office is: 1-3 Huffwood Trading Estate, Partridge Green, Horsham, England, RH13 8AU

2. What does this Notice cover?

This Privacy Information explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data irrespective of whether you are in the UK or in the EEA.

3. What do we mean by Personal Data and other terms used in this Notice?

Personal data is defined by the UK GDPR and the Data Protection Act 2018 as “‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier” and by the EU GDPR as “any information relating to an identified or identifiable natural person”. We refer to this legislation collectively as “the Data Protection Legislation” in this Notice.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

The personal data that we use is set out in Part 5, below. For a definition of the other terms that we use in this Notice, please see the Glossary in Part 14, below.

4. What Personal Data Do You Collect and How?

We may collect and hold some or all of the personal and non-personal data set out in the table below, using the methods also set out in the table. We do not collect any personal data which is ‘special category’, ‘sensitive’, relates to children or to criminal convictions and/or offences.

Data Collected	How We Collect the Data
Contact Data	Directly from you when you do business with us as a customer or supplier or contact us with a view to doing business or from public records or third party data bases.
Business Data	Directly from you when you do business with us as a customer or supplier or contact us with a view to doing business or from public records or third party data bases.
Financial Data	Directly from you or from public records or third party data bases.
Identity Data	Directly from you when you do business with us as a customer or supplier or contact us with a view to doing business or from public records or third party data bases.
Marketing and Communications Data	Directly from you when you do business with us as a customer or supplier or contact us with a view to doing business or from public records or third party data bases or business data providers.
Technical Data	Directly from you when you use our website(s).

5. How Do You Use My Personal Data?

Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes how we may use your personal data, and our lawful bases for doing so:

What We Do	What Data We Use	Our Lawful Basis
Collecting your contact details from Our Site	Contact Data.	Performance of a contract. Consent – if this is required.
Administering our business.	Business Data & Financial Data.	Performance of a contract. Legitimate interests to develop our business.
Supplying or buying products and services.	Contact Data & Identity Data.	Performance of a contract.
Managing payments for our products and services.	Financial Data.	Performance of a contract.
Personalising/tailoring and improving our products and services for you.	Business Data, Financial Data & Identity Data.	Legitimate interests to develop our business.
Communicating with you when doing business.	Contact Data, Identity Data, Business Data & Financial Data.	Performance of a contract.
Providing you with information about our products and services by telephone, email or post.	Marketing and Communications Data.	Consent – if this is required. Legitimate interests to develop our business.
Protecting the security of our business assets and the well-being of our employees, customers, suppliers and visitors.	Technical Data.	Legitimate interests to safeguard our business and third parties. Vital interests.

We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 12.

If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.
In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.

6. How Long Will You Keep My Personal Data?

We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):

Type of Data	How Long We Keep It
Contact Data	5 years in relation to any prospective business communications or enquiries, then as long as we are doing business with you and for a period of 6 years after.

Business Data	5 years in relation to any prospective business communications or enquiries, then as long as we are doing business with you and for a period of 6 years after.
Financial Data	2 years in relation to any prospective business communications or enquiries, then as long as we are doing business with you and for a period of 6 years after.
Identity Data	3 years in relation to any prospective business communications or enquiries, then as long as we are doing business with you and for a period of 6 years after.
Marketing and Communications Data	3 years in relation to any prospective business communications or enquiries, then as long as we are doing business with you and for a period of 6 years after.
Technical Data	3 years in relation to any prospective business communications or enquiries, then as long as we are doing business with you and for a period of 6 years after.

7. How and Where Do You Store or Transfer My Personal Data?

We will only usually store your personal data in the UK or EEA. This means that it will be fully protected under the Data Protection Legislation.

If we store some or all of your personal data in countries outside of the UK or EEA, known as “third countries”, we will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK or EEA and under the Data Protection Legislation as follows:

We will either:

store your data in the UK or EEA or;
store or transfer personal data in or to countries that are deemed to provide an adequate level of protection for personal data. For further information about adequacy decisions and adequacy regulations, please refer to the Information Commissioner’s Office:

we will use specific approved contracts which ensure the same levels of personal data protection that apply under the Data Protection Legislation. For further information, please refer to the Information Commissioner’s Office.

The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:

limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;

procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so;

8. Do You Share My Personal Data?

We will not share any of your personal data with any third parties for any purposes, subject to the following exceptions.

If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Policy.

We may share your personal data with other companies in our group for business administration purposes. This includes subsidiaries and any holding company and its subsidiaries.

We may sometimes contract with the following third parties to supply products and/or services, such as IT or telecommunication services.

If any of your personal data is shared with a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 8.

If any personal data is transferred outside of the UK or EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK or EEA and under the Data Protection Legislation, as explained above in Part 8.

9. What Are My Rights?

Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:

The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 12.
The right to access the personal data we hold about you. Part 10 will tell you how to do this.
The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 12 to find out more.
The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 12 to find out more.
The right to restrict (i.e. prevent) the processing of your personal data.
The right to object to us using your personal data for a particular purpose or purposes.
The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
Rights relating to automated decision-making and profiling. We do not use your personal data in this way.

For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 12.

It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 12.

10. How Can I Access My Personal Data?

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 12. To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible.

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We will respond to your subject access request within one month and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

11. How Do You Use Cookies?

Our Site may place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by us and are used only by us. We use Cookies to facilitate and improve your experience of Our Site or to collect analytical information (without collecting personal data).. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.

Certain features of Our Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below, but please be aware that Our Site may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.

All Cookies used by and on Our Site are used in accordance with current Cookie Law.

These Cookies are shown in the table below.

Details of the Cookies which may be placed on your computer or device are set out in more detail in our Cookie Policy which can be accessed on this link.

You can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.

You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.

It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.

12. How Do I Contact You?

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details:

Email address: [team@theriderfirm.cc]

Telephone number: +44(0)1403 711813

Postal address: 1-3 Huffwood Trading Estate, Partridge Green, Horsham, England, RH13 8AU

13. Changes to this Privacy Policy

We may change this Privacy Policy from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

Any changes will be made available on our website This Privacy Policy was last updated on 30^th November 2022.

14. Glossary

Accident Data means information relating to your health and medical treatments.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Contact Data means any information needs to contact you such as an email address(es), telephone number(s), correspondence or billing address(es).

Business Data means information about you or your business which we need or collect in the course of dealing with you or any third party (such as any regulatory authority) which may include the nature of your business, your business or personal requirements, types and location of operations, volumes of waste or materials used and produced. This may also include information from correspondence or communications between us.

Data Protection Laws means the EU GDPR, the UK GDPR, the Data Protection Act 2018, the Privacy and Electronic Communications (EC Directive) Regulations 2003 and such other applicable privacy related legislation which may supplement, amend or replace them.

EEA means the European Economic Area. The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein.

EU GDPR means Regulation (EU) 2016/679 as applies to EU/EEA member states and applies to ”activities of an establishment of a controller or a processor in the Union, regardless of whether the processing takes place in the Union or not” (Art 3).

Financial Data means any information relating to payments (including payment card details and/or any credit limits or payment terms), invoices, taxes or duties or banking or invoicing information which relates to you or your business.

Identity Data includes first name, last name, username or similar identifier, marital status, title, date of birth and gender.

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. 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 for our legitimate interests. 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 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.

Marketing and Communications Data means your preferences in receiving marketing from us and our third parties and your communication preferences.

Performance of Contract means processing your data where it 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.

Technical Data includes internet protocol (IP) address, your 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

Vital Interests means processing your personal data where it is necessary to preserve or protect your life or well-being (such as in the case of a medical emergency).

OUR US WEBSITE PRIVACY POLICY

13. ITS CYCLING USA PRIVACY POLICY

13.1 Privacy Policy. ITS Cycling USA is committed to preserving the privacy of all visitors to our Website. Please read the following privacy policy to understand how we use and protect the information that you provide to us. By registering or placing an order on our Website, you consent to the collection, use and transfer of your information under the terms of this policy.

13.2 Information That We Collect From You. When you visit, register or order products or services on our Website you may be asked to provide certain information about yourself including your name, contact details and credit or debit card information. We may also collect information about your usage of our Website via automated means, as well as information about you from messages you post to the website and e-mails or letters you send to us. To maintain Rider Experience standards and to assist staff training, we may record and monitor incoming calls.

13.3 Use of Your Information. Your information will enable us to provide you with access to all parts of our Website and to supply the goods or services you have requested. It will also enable us to bill you and to contact you where necessary concerning your orders. We will also use and analyze the information we collect so that we can administer, support, improve and develop our business.

In particular, we may use your information to contact you for your views on our services and to notify you occasionally about important changes or developments to the Website, our services and offerings. Further, where you have consented, we might also use your information to let you know by email about other products and services which we offer which may be of interest to you or we may use it to allow you to participate in sweepstakes, contests or other promotions. If you change your mind about being contacted in the future, please contact us via chat, email or by phone, see Contact Details.

13.4 Affiliate Brands and Companies. We may share your information with our affiliated brands, parent company, and its subsidiaries or affiliated entities/partners (“Affiliated Entities”) for market research purposes for sending you advertising/promotional material, discounts, newsletters, surveys, product launches, etc. We will not transfer your information outside the ITS Cycling Ltd organization except as otherwise described in this Privacy Policy.

13.5 Disclosure of Your Information. The information you provide to us may be accessed by or given to third parties some of whom may be located outside the USA who act for us for the purposes set out in this policy or for other purposes approved by you. Those parties process information, fulfill and deliver orders, process credit card payments and provide support services on our behalf. We may also pass aggregate information on the usage of our website to third parties, but this will not include information that can be used to identify you. Finally, if our business enters into a joint venture with or is sold to or merged with another business entity, your information may be disclosed to our new business partners or owners.

Countries outside the USA do not always have strong data protection laws. However, we will always take steps to ensure that your information is used by third parties in accordance with this policy. Unless required to do so by law, we will not otherwise share, sell or distribute any of the information you provide to us without your consent.

13.6 Transfers of Personal Information to the United Kingdom. ITS Cycling USA is subsidiary of a global company with a headquarters in the United Kingdom where the privacy laws may or may not be as protective as the laws in your country. We protect your information when it is transferred out of your country using both contracts and industry standard security measures.

13.7 Website Analytics. We use a tool such as “Google Analytics” (“Analytics”) to collect information about your internet use. For example, how often you visit our site, the pages you visit, and what other Sites you may have visited prior to coming to our site. We use Analytics to gain insights into how our services are used and to help us improve our products and services. Although Analytics plants a permanent cookie on your web browser to identify you as a unique user the next time you visit this site, the cookie cannot be used by anyone but Analytics provider. To opt-out of Google Analytics, please use Google’s opt-out tool: https://tools.google.com/dlpage/gaoptout.

13.8 Do Not Track. Currently the Service is not designed to respond to “Do Not Track” signals sent from your browser.

13.9 Cookies. Cookies are small amounts of information which we may store on your computer. Unless you have indicated your objection when disclosing your details to us, our system will issue cookies to your computer when you log on to the site. Cookies make it easier for you to log on to and use the site during future visits. They also allow us to monitor website traffic and to personalize the content of the site for you. You may set up your computer to reject cookies by following the relevant instructions which can be found at www.adboutcookies.org. In that case, you may not be able to use certain features on our site. If you do not wish to receive cookies in the future, please let us know by chat, email or phone, see Contact Details.

13.10 Security and Data Retention. We employ security measures to protect your information from access by unauthorized persons and against unlawful processing, accidental loss, destruction and damage. We want you to have continuing trust in us and in our products and Services. In order to prevent unauthorized access, maintain data accuracy, and ensure the correct use of information, we have put in place reasonable and appropriate physical, electronic, and managerial procedures to safeguard the information we collect. Unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be secure. As a result, while we strive to protect your information, you acknowledge that: (a) there are security and privacy limitations of the Internet which are beyond our control; (b) the security, integrity and privacy of any and all information and data exchanged between you and us through our Website cannot be guaranteed; and (c) any such information and data may be viewed or tampered with in transit by a third party. We will retain your information for a reasonable period or as long as the law requires. We do not store credit and debit card details.

13.11 Accessing and Updating. You are entitled to see the information held about you and you may ask us to make any necessary changes to ensure that it is accurate and kept up to date. If you wish to do this, please see Contact Details.

13.12 Use Of Information By Minors. The Website is not directed to individuals under the age of eighteen (18), and we do not knowingly collect or process information from individuals under 18.

13.13 Business Transfers. As we continue to develop our business, we might be bought by, sell or buy subsidiaries or business units, either directly or in legal proceedings such as bankruptcy. In such transactions, customer information generally is one of the transferred business assets but remains subject to the obligations made in any pre-existing privacy policy.

13.14 Legal Obligations. We may share your information if we have a good faith belief that such action is necessary to: (i) comply with legal process or other legal requirements of any governmental authority; (ii) protect and defend our rights or property; (iii) enforce this Privacy Policy; (iv) protect the interests of other users of this Site or any other person; or (v) operate or conduct maintenance and repair of the Website or equipment.

13.13 Changes to our privacy policy. Any changes to our privacy policy in the future will be posted to the website and, where appropriate, through e-mail notification.

13.14 Comments. All comments, queries and requests relating to our use of your information are welcomed and should be addressed to the email addresses shown in Contact Details.

13.15 California Residents. As described above, ITS Cycling USA will only share your information with its Affiliated Entities and service providers, in connection with certain business transfers, as required by law, or, in some cases, business partners that you agree to share your information with. We do not offer any financial incentives in exchange for retention or sale of personal information. If you are a California resident, you have the right, at any time, to request what personal information we collect, use, disclose and sell and direct us to not sell your personal information, delete your personal information, opt-out of the selling of your personal information, not receive discriminatory treatment for the exercise of your privacy rights, and designate an authorized agent to make a request on your behalf. To make your request to know, delete or opt-out, email or call us and provide the following information: first name, last name, email, mailing address, brand, request (see Contact Details). We will verify your request by sending a response to the email or mailing address we have in our records for you n.

GOVERNING LAW AND MISCELLANEOUS

14. GOVERNING LAW AND JURISDICTION

14.1 Governing Law. These terms and conditions shall be governed by and construed in accordance with Colorado law. Disputes arising in connection with these terms and conditions shall be subject to the exclusive jurisdiction of Colorado courts.

14.2 Website Access Outside of USA. We do not warrant that materials/items for sale on the Website are appropriate or available for use outside the USA. It is prohibited to access the Website from territories where its contents are illegal or unlawful. If you access the Website from locations outside the USA, you do so at your own risk and you are responsible for compliance with local laws.

15. MISCELLANEOUS

15.1 Assignment. You may not assign, sub-license or otherwise transfer any of your rights under these Terms and Conditions.

15.2 Severability. If any provision of these Terms and Conditions is found by any court of competent jurisdiction to be invalid, the invalidity of that provision will not affect the validity of the remaining provisions which shall continue to have full force and effect.

15.3 Headings. Headings and captions used herein are for convenience and reference only and are not intended to define, limit, or describe the scope or intent of any provision of these Terms and Conditions.

15.4 Changes. These Terms and Conditions are subject to periodic change, revision and amendment.

15.5 Parties. Only the parties to these Terms and Conditions may seek to enforce them.

15.6 Force Majeure. We shall be not liable to you or deemed to be in breach of these Terms and Conditions by reason of any delay in performing, or any failure to perform, any of our obligations in relation to you, if the delay or failure was due to any cause beyond our reasonable control such as (but without limitation) any pandemic, strike, lock-out or other form of industrial action, failure of a utility service or transport network, act of God, war, riot, civil commotion, malicious damage, compliance with any law or government order, rule, regulation or direction, accident, breakdown of plant or machinery, fire, flood, storm or default of supplier or sub-contractors or inability to obtain materials required for performance under these Terms and Conditions.

15.7 Waiver If either you or us fail or delay or compromise in exercising a right or remedy under the Terms and Conditions, the right or remedy is not to be treated as having been waived, restricted or varied and any agreement by either you or us to refrain from exercising a right in one particular instance will not prevent you or us from exercising it in full in the future.

15.8 Cumulative remedies. All rights and remedies available to either you or us under the terms of the Terms and Conditions or under the general law are to be cumulative, and no exercise by either you or us of any such right or remedy is to restrict or prejudice the exercise of any other right or remedy granted by the Terms and Conditions or otherwise available to you or us.

CONTACT DETAILS

16. CONTACT DETAILS

General email: support@privateerbikes.com

Chat available at Website during business hours.

The www.privateerbikes.com/en-us is operated by:

ITS Cycling USA Inc., 4699 Nautilus Court, Suite #401, Boulder, Colorado 80301, United States

OUR EU WEBSITE PRIVACY POLICY

BACKGROUND:

We at Privateer Bike Wheels EU understand that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all those we do business with or who contact us at our website, [www.eu.privateerbikes.com] (“Our Site”). We will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.

1. Information About Us

We are ITS Cycling EU GmbH trading as Privateer Bikes, a Company registered in Germany under HRB Number 45041.

Our email address is: privacy@huntbikewheels.com

Our postal address/registered office is: Am Lagerplatz 2, 01099 Dresden

2. What does this Privacy Policy cover?

This Privacy Policy explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data irrespective of whether you are in the UK or in the EEA.

3. What do we mean by Personal Data and other terms used in this Notice?

Personal data is defined by the EU GDPR as “any information relating to an identified or identifiable natural person”. We refer to this legislation as “the Data Protection Legislation” in this Policy.

The personal data that we use is set out in Part 5, below. For a definition of the other terms that we use in this Notice, please see the Glossary in Part 14, below.

4. What Personal Data Do You Collect and How?

Data Collected		How We Collect the Data
Contact Data		Directly from you when you do business with us as a customer or supplier or contact us with a view to doing business or from public records or third party data bases.
Business Data		Directly from you when you do business with us as a customer or supplier or contact us with a view to doing business or from public records or third party data bases.
Financial Data		Directly from you or from public records or third party data bases.
Identity Data		Directly from you when you do business with us as a customer or supplier or contact us with a view to doing business or from public records or third party data bases.
Marketing and Communications Data		Directly from you when you do business with us as a customer or supplier or contact us with a view to doing business or from public records or third party data bases or business data providers.
	Technical Data		Directly from you when you use our website(s).

5. How Do You Use My Personal Data?

Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes how we may use your personal data, and our lawful bases for doing so:

What We Do	What Data We Use	Our Lawful Basis
Collecting your contact details from Our Site	Contact Data.	Performance of a contract. Consent – if this is required.
Administering our business.	Business Data & Financial Data.	Performance of a contract. Legitimate interests to develop our business.
Supplying or buying products and services.	Contact Data & Identity Data.	Performance of a contract.
Managing payments for our products and services.	Financial Data.	Performance of a contract.
Personalising/tailoring and improving our products and services for you.	Business Data, Financial Data & Identity Data.	Legitimate interests to develop our business.
Communicating with you when doing business.	Contact Data, Identity Data, Business Data & Financial Data.	Performance of a contract.
Providing you with information about our products and services by telephone, email or post.	Marketing and Communications Data.	Consent – if this is required. Legitimate interests to develop our business.
Protecting the security of our business assets and the well-being of our employees, customers, suppliers and visitors.	Technical Data.	Legitimate interests to safeguard our business and third parties. Vital interests.

6. How Long Will You Keep My Personal Data?

Type of Data	How Long We Keep It
Contact Data	5 years in relation to any prospective business communications or enquiries, then as long as we are doing business with you and for a period of 6 years after.

Business Data	5 years in relation to any prospective business communications or enquiries, then as long as we are doing business with you and for a period of 6 years after.
Financial Data	2 years in relation to any prospective business communications or enquiries, then as long as we are doing business with you and for a period of 6 years after.
Identity Data	3 years in relation to any prospective business communications or enquiries, then as long as we are doing business with you and for a period of 6 years after.
Marketing and Communications Data	3 years in relation to any prospective business communications or enquiries, then as long as we are doing business with you and for a period of 6 years after.
Technical Data	3 years in relation to any prospective business communications or enquiries, then as long as we are doing business with you and for a period of 6 years after.

7.How and Where Do You Store or Transfer My Personal Data?

We will only usually store your personal data in the EEA or the UK. This means that it will be fully protected under the Data Protection Legislation.

Transfers of personal data to the UK from the EEA are permitted without additional safeguards under Data Protection Legislation. If we store some or all of your personal data in countries outside of the EEA or the UK, known as “third countries”, we will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the r EEA and under the Data Protection Legislation as follows:

We will either:

store your data in the EEA or the UK; or
store or transfer personal data in or to countries that are deemed to provide an adequate level of protection for personal data. For further information about adequacy decisions and adequacy regulations, please refer to the European Commission – Adequacy decisions

The additional steps we take when storing or transferring personal data to “third countries” are specific approved contracts which ensure the same levels of personal data protection that apply under the Data Protection Legislation. For further information, please refer to the Federal Commission for Data Protection and Freedom of Information (BfDI)

The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:

limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;

8. Do You Share My Personal Data?

We will not share any of your personal data with any third parties for any purposes, subject to the following exceptions.

We may share your personal data with other companies in our group for business administration purposes. This includes subsidiaries and any holding company and its subsidiaries.

We may sometimes contract with the following third parties to supply products and/or services, such as IT or telecommunication services.

If any personal data is transferred outside of the EEA or the UK, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the EEA and under the Data Protection Legislation, as explained above in Part7.

9. What Are My Rights?

Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:

The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 12.
The right to access the personal data we hold about you. Part 10 will tell you how to do this.
The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 12 to find out more.
The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 12 to find out more.
The right to restrict (i.e. prevent) the processing of your personal data.
The right to object to us using your personal data for a particular purpose or purposes.
The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
Rights relating to automated decision-making and profiling. We do not use your personal data in this way.

For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 12.

It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.

Further information about your rights can also be obtained from the Federal Commission for Data Protection and Freedom of Information (BfDI) .

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Federal Commission for Data Protection and Freedom of Information (BfDI). We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part

10. How Can I Access My Personal Data?

11. How Do You Use Cookies?

Our Site may place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by us and are used only by us. We use Cookies to facilitate and improve your experience of Our Site or to collect analytical information (without collecting personal data). We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.

All Cookies used by and on Our Site are used in accordance with current Cookie Law.

Details of the Cookies which may be placed on your computer or device are set out in more detail in our Cookie Policy which can be accessed on this [insert link].