We are committed to safeguarding the privacy of our website visitors; this policy 1 sets out how we will treat your personal information. 2
(1) What information do we collect?
We may collect, store and use the following kinds of personal data:[(a) information about your computer and about your visits to and use of this website, such as your IP address, geographical location, browser type, referral source, length of visit and number of page views.
[(b) information relating to any transactions carried out between you and us on or in relation to this website, including information relating to any purchases you make of our goods or services.
[(c) information that you provide to us for the purpose of registering with us.
[(d) information that you provide to us for the purpose of subscribing to our website services, email notifications and/or newsletters.
[(e) any other information that you choose to send to us.
2 “Personal information”: for day-to-day purposes, it is best to assume that all information which relates to a living individual constitutes personal information. We use “personal data” and “personal information” interchangeably in this template.
We may send a cookie which may be stored on by your browser on your computer’s hard drive. We may use the information we obtain from the cookie in the administration of this website, to improve the website’s usability and for marketing purposes. We may also use that information to [recognise your computer when you visit our website, and to personalise our website for you]. 3 [Our advertisers may also send you cookies.]
Most browsers allow you to refuse to accept cookies. (For example, in Internet Explorer you can refuse all cookies by clicking “Tools”, “Internet Options”, “Privacy”, and selecting “Block all cookies” using the sliding selector.) This will, however, have a negative impact upon the usability of many websites [, including this one].]4
(3) Using your personal data
We may use your personal information to:
[(a) administer the website;]
[(b) improve your browsing experience by personalising the website;]
[(c) enable your use of the services available on the website;]
[(d) send to you goods purchased via the website, and supply to you services purchased via the website;]
3 Specify here the uses to which you will put cookies and the data that you collect from cookies.
[(e) send statements and invoices to you, and collect payments from you;]
[(f) send you general (non-marketing) commercial communications;]
[(g) send you email notifications which you have specifically requested;]
[(h) send to you [our newsletter and other] marketing communications (relating to our business [or the businesses of carefully-selected third parties] which we think may be of interest to you by post or, where you have specifically agreed to this, by email or similar technology (you can inform us at any time if you no longer require marketing communications to be sent by emailing us at [firstname.lastname@example.org])6 ;]
[(i) provide third parties with statistical information about our users – but this information will not be used to identify any individual user;]
[(j) deal with enquiries and complaints made by or about you relating to the website; and]
We will not without your express consent provide your personal information to any third parties for the purpose of direct marketing.7
(4) Other disclosures
(a) to the extent that we are required to do so by law;
(b) in connection with any legal proceedings or prospective legal proceedings;
(c) in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk); and
[(d) to the purchaser (or prospective purchaser) of any business or asset which we are (or are contemplating) selling.]8
6 As a general rule, where you plan to use personal information you have collected for the purpose of direct marketing, this should be made clear on the page where the information is collected, and you should ensure that this only happens if users opt-in to the marketing (e.g. “Click here if you would like us to send you information by email about products which we think will interest you…”). There are however exceptions to this general rule. There are also rules about the content of direct marketing communications. If you are in any doubt about complying with your legal obligations in relation to direct marketing, you should seek professional advice.
[(5) International data transfers
[If you are in the European Union, information which you provide may be transferred to countries (including [the United States], [Japan], [OTHER COUNTRIES]) which do not have data protection laws equivalent to those in force in the European Union. You expressly agree to such transfers.]]9
(6) Security of your personal data
We will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information.
[We will store all the personal information you provide on our secure servers. All electronic transactions you make to or receive from us will be encrypted [using SSL technology].]10
Of course, data transmission over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
[You are responsible for keeping your password and user details confidential. We will not ask you for your password.]
(7) Policy amendments 11
8 If there is any chance of you ever wanting to sell your business, you should include this provision.
9 The internet does not respect national borders, and if you are unsure whether your website or business involves or may involve the international transfer of personal data, it is sensible to err on the side of caution, and allow your users the opportunity to consent to international transfers. In some cases it may be possible to specify the countries to which you will send data.
10 There is an obligation upon data controllers to store personal data securely. You may provide details of your security measures here.
11 Changes to the policy – in particular as to permissible uses of personal data – may not be retrospective. In other words, if you collect personal information on one basis, you cannot, simply by changing the terms of your policy, go on to legitimately use that information on a different basis.
You may instruct us to provide you with any personal information we hold about you. Provision of such information may be subject to the payment of a fee (currently fixed at £10.00).
You may instruct us not to process your personal data for marketing purposes by email (to [email@example.com]) at any time. (In practice, you will usually either expressly agree in advance to our use of your personal data for marketing purposes, or we will provide you with an opportunity to opt-out of the use of your personal data for marketing purposes.)
(9) Third party websites
The website contains links to other websites. We are not responsible for the privacy policies or practices of third party websites.
(10) Updating information
Please let us know if the personal information which we hold about you needs to be corrected or updated.
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