2.6 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
2.7 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
2.8 In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
2.9 Please do not supply any other person's personal data to us, unless we prompt you to do so (e.g. to share meeting invitations).
3. Providing your personal data to others
3.1 We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.
3.2 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
3.3 We may disclose your name, email address and employer to our suppliers or subcontractors who provide products and services (e.g. hosting events) insofar as reasonably necessary for us to be able to provide those products and services to you.
3.4 Financial transactions relating to our website and services are handled by our payment services providers, 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/gb/privacy.
3.6 In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
4. International transfers of your personal data
4.1 In this Section 4, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).
4.2 The hosting facilities for our website are situated within the EEA in the United Kingdom, Ireland and Germany.
4.3 If we transfer personal data outside of the EEA we shall do so using the mechanics permitted by the General Data Protection Regulation, which may include EU approved contract clauses and Privacy Shield.
4.4 You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
5. Retaining and deleting personal data
5.1 This Section 5 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
5.2 We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
5.3 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 requirements. For example, details of your orders will be kept for as long as we need to retain that data to comply with our legal and regulatory requirements. This is generally 7 years unless the law prescribes a longer period.
5.4 In some circumstances you can ask us to delete your data: see 8.2 Right to Erasure in Your Rights section below for further information.
5.5 In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
5.6 Notwithstanding the other provisions of this Section 5, 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.
6. Security of personal data
6.1 We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.
6.2 We will store all your personal data on secure servers, personal computers and mobile devices, and in secure manual record-keeping systems.
6.3 The following personal data will be stored by us in encrypted form: your name, contact information, password(s) and cardholder data.
6.4 Data relating to your enquiries and financial transactions that is sent from your web browser to our web server, or from our web server to your web browser, will be protected using encryption technology.
6.5 You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
6.6 You should ensure that your password is not susceptible to being guessed, whether by a person or a computer program. You are responsible for keeping the password you use for accessing our website confidential and we will not ask you for your password (except when you log in to our app).
7.1 We may update this policy from time to time by publishing a new version on our website.
7.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
7.3 We may notify you of changes to this policy by email or through the private messaging system in our app.
8. Your rights
8.1 In this Section 8, we have summarised the rights that you have under data protection law.
8.2 Your rights are:
(b) The right of access – a right to be told what personal data we hold about you and obtain copies of it.
(c) The right of rectification – an obligation in certain circumstances to correct your personal data if it’s inaccurate or incomplete.
(d) The right to erasure – an obligation in certain circumstances to delete or remove your personal data where there is no compelling reason for its continued processing (some people also call this right ‘the right to be forgotten’).
(e) The right to restrict processing – an obligation in certain circumstances to stop actively processing your personal data.
(f) The right to data portability – an obligation in certain circumstances to allow you to transfer your personal data from us to a third party.
(g) The right to object – an obligation in certain circumstances to allow you to object to us processing your personal data where we do not have an overriding reason.
8.3 You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
8.4 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 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.
8.5 We try to respond to all legitimate requests within one month. Occasionally it may 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
8.6 You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority 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 please contact us in the first instance. If you are outside the UK, you may also make a complaint to a supervisory authority responsible for data protection where you are - you may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
8.7 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
8.8 You may exercise any of your rights in relation to your personal data by written notice to us, in addition to the other methods specified in this Section 8.
9. Third party websites
9.1 Our website and app includes hyperlinks to, and details of, third party websites.
9.2 We have no control over, and are not responsible for, the privacy policies and practices of third parties.
10. Personal data of children
10.1 Our website and services are targeted at adults.
10.2 If we have reason to believe that we hold personal data of a person who is not an adult, we will delete that personal data.
11. Updating information
11.1 Please let us know if the personal information that we hold about you needs to be corrected or updated.
12. About cookies
12.1 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.
12.2 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.
12.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
12.4 We use similar technology to cookies to identify you in our app which behave very similarly to cookies as outlined above
13. Cookies that we use
(a) strictly necessary – these are cookies that help us deliver our website;
(c) analysis of our app usage – we use similar technologies to cookies to help us to analyse the use and performance of our app. This data is processed for us by a third party (Google Analytics). Please see section 14.3 for more information.
14. Cookies used by our service providers
15. Managing cookies
15.1 Most browsers allow you to refuse to accept cookies and to delete cookies. If you want more information about this, please see allaboutcookies.org.
15.2 If you block cookies, you will not be able to use all the features on our website.
16. Cookie preferences
17. Our details
17.1 This website and app is owned and operated by District Technologies Limited.
17.2 We are registered in England and Wales under registration number [number], and our registered office is at District Technologies Limited, Unit 7 59 Dalston Lane, E8 2NG, London.
17.3 Our principal place of business is at District Technologies Limited, Top Floor, 70-71 Wells Street, London, W1T 3QE.
17.4 You can contact us:
(a) by post, to the postal address given above;
(b) by email: email@example.com.
18. Data protection registration
18.1 We are registered as a data controller with the UK Information Commissioner's Office.
18.2 Our data protection registration number is ZA347344.
19. Representative within the European Union
19.1 Our representative within the European Union with respect to our obligations under data protection law is District Technologies Limited and you can contact our representative by emailing firstname.lastname@example.org.
(Version 2.0, last updated 24 May 2018)