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  1. 1.Introduction
    1. 1.1 We are committed to safeguarding the privacy of our website visitors and service users.
    2. 1.2 This policy applies where we are acting as a data controller with respect to the personal data of our website visitors [and service users]; in other words, where we determine the purposes and means of the processing of that personal data.
    3. 1.3 By using our website and agreeing to this policy, you consent to our use of cookies in accordance with the terms of this policy.
      Please see our Cookie Policy for details about our use of cookies on this website.
    4. 1.5 In this policy, "we", "us" and "our" refer to [data controller name]. For more information about us, see Section 10.
  2. 2.Credit
    1. 2.1 This document was created using a template from SEQ Legal (https://seqlegal.com).
  3. 3.How we use your personal data
    1. 3.1 In this Section 3 we have set out:
      1. (a)the general categories of personal data that we may process;
      2. (b)[in the case of personal data that we did not obtain directly from you, the source and specific categories of that data];
      3. (c)the purposes for which we may process personal data; and
      4. (d)the legal bases of the processing.
    2. 3.2 Optional clause
      We may process data about your use of our website and services ("usage data"). The usage data may include [your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use]. The source of the usage data is Google Analytics.
      This usage data may be processed for the purposes of analysing the use of the website and services.
      The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.
    3. 3.4 Optional clause
      We may process your account data and information included in your personal profile on our website ("profile data").
      [ The profile data may include [your name, address, telephone number, email address, profile pictures, gender, date of birth, relationship status, interests and hobbies, educational details and employment details - any others - personal data only required].]
      The profile data may be processed for the purposes of enabling and monitoring your use of our website and services, operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you.
      The legal basis for this processing is our legitimate interests (namely the proper administration of our website and business) and / or the performance of a contract between you and us (and/or taking steps, at your request, to enter into such a contract) and / or your legitimate interests by providing you with the services you have asked for.
    4. 3.5 Optional clause
      We may process your personal data that are provided in the course of the use of our services ("service data").
      The service data may include [specify data]. The source of the service data is you [or your employer | or anyone else]].
      The service data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you.
      The legal basis for this processing is our legitimate interests (namely the proper administration of our website and business) and / or the performance of a contract between you and us (and/or taking steps, at your request, to enter into such a contract) and / or your legitimate interests by providing you with the services you have asked for.
    5. 3.6 Optional clause
      We may process information that you post for publication on our website or through our services ("publication data").
      The publication data may be processed for the purposes of enabling such publication and administering our website and services.
      The legal basis for this processing is our legitimate interests (namely the proper administration of our website and business) and / or the performance of a contract between you and us (and/or taking steps, at your request, to enter into such a contract) and / or your legitimate interests by providing you with the services you have asked for.
    6. 3.7 Optional clause
      We may process information contained in any enquiry you submit to us regarding goods and/or services ("enquiry data").
      The enquiry data may be processed for the purposes of answering your queries and offering, marketing and selling relevant goods and/or services to you.
      The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
    7. 3.8 Optional clause
      We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website ("transaction data"). The transaction data may include your contact details and the transaction details*
      The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions.
      The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely our interest in the proper administration of our website and business.
      * Please note, all online financial transactions are handled by our payment partner (PayPal) and we never see any of the card or bank account details that you use to make an online payment. As a result we can never store and / or process these details in any way.
    8. 3.9 Optional clause
      We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters ("notification data").
      The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters.
      The legal basis for this processing is consent given by specifically signing up for each such newsletter.
    9. 3.10 Optional clause
      We may process information contained in or relating to any communication that you send to us ("correspondence data").
      The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms.
      The correspondence data may be processed for the purposes of communicating with you and record-keeping.
      The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
    10. - Marketing and other purposes
      From time to time we may like to process information that you provide to us for the purposes of marketing products and services that we feel may be of interest and use to you.
      This data may include [your name, address, telephone number, email address, profile pictures, gender, date of birth, relationship status, interests and hobbies, educational details and employment details - any others - personal data only required].
      The legal basis for this processing is consent which you must give us before we can do this. You will be given the opportunity to give your consent when you sign up for an account on the site and after that you will be able to change your mind and give or withdraw your consent at any time by signing in and going to 'My details' on the website.
    11. 3.11 Any others...
      We may process [identify general category of data].
      This data may include [list specific items of data]. [If the user doesn't supply the data: The source of this data is [identify source].
      This data may be processed for [specify purposes].
      The legal basis for this processing is [consent] OR [our legitimate interests, namely [specify legitimate interests]] OR [the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract] OR [[specify basis]].
    12. 3.12 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.
    13. 3.13 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.
    14. 3.14 In addition to the specific purposes for which we may process your personal data set out in this Section 3, 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.
    15. 3.15 We have implemented reCAPTCHA v3 on our site and it's use is subject to the Google Privacy Policy and Terms of Use. reCAPTCHA is only used to fight spam and abuse on our site.
    16. 3.16 Please do not supply any other person's personal data to us, unless we prompt you to do so.
  4. 4.Providing your personal data to others
    1. 4.1 Optional clause
      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.
    2. 4.2 Optional clause
      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. 4.3 Optional clause
      We may disclose [specify personal data category or categories] to [our suppliers or subcontractors][ identified at [URL]] insofar as reasonably necessary for [specify purposes].
    4. 4.4 Optional clause
      Financial transactions relating to [our website and services are] handled by our payment services providers, [identify PSPs]. 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 [URLs].
    5. 4.5 Optional clause
      We may disclose [your enquiry data] to [one or more of those selected third party suppliers of goods and services identified on our website] for the purpose of [enabling them to contact you so that they can offer, market and sell to you relevant goods and/or services]. [ Each such third party will act as a data controller in relation to the enquiry data that we supply to it; and upon contacting you, each such third party will supply to you a copy of its own privacy policy, which will govern that third party's use of your personal data.]
    6. 4.6 Optional clause
      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.
  5. 5.International transfers of your personal data
    1. 5.1 In this Section 5, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).
    2. 5.2 Optional clause
      We [ and our other group companies] have [offices and facilities] in [specify countries].
      The European Commission has made an "adequacy decision" with respect to the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely
      [the use of standard data protection clauses adopted or approved by the European Commission, a copy of which can be obtained from [source]] OR
      [the use of binding corporate rules, a copy of which you can obtain from [source]] OR
      [[specify appropriate safeguards and means to obtain a copy]].]
    3. 5.3 Our webserver(s) are located within Europe and any data you supply via the website may be stored on the webserver. We do not store personal data [from the website] outside the EEA.
    4. 5.4 Optional clause
      [Specify category or categories of subcontractor] [is] OR [are] situated in [specify countries]. [ The European Commission has made an "adequacy decision" with respect to [the data protection laws of each of these countries].] [ Transfers to [each of these countries] will be protected by appropriate safeguards, namely [the use of standard data protection clauses adopted or approved by the European Commission, a copy of which can be obtained from [source]] OR [[specify appropriate safeguards and means to obtain a copy]].]
    5. 5.5 Optional clause
      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.
  6. 6.Retaining and deleting personal data
    1. 6.1 This Section 6 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.
    2. 6.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
    3. 6.3 Optional clause
      We will retain your personal data as follows:
      1. (a) [personal data category or categories] will be retained for a minimum period of [period] following [date], and for a maximum period of [period] following [date].
      2. [additional list items]
    4. 6.4 Optional clause
      In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:
      1. (a) the period of retention of [personal data category] will be determined based on [specify criteria].
      2. [additional list items]
    5. added In the case of personal data supplied to or processed by the website, your data will be retained until you close your account and request that your personal data be removed from the website. This should be initiated in [one of the following ways | the following way]:
      1. (a) Contact us using one of the methods in section 10 below. You will be required to provide appropriate evidence of your identity.
      2. [when online deletion is enabled, add it here...]
      Onc you have done this, any online account you have on the website will be closed and your data will be removed from the website within 28 days.
    6. 6.5 Notwithstanding the other provisions of this Section 6, 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.
  7. 7.Amendments - Optional clause
    1. 7.1 We may update this policy from time to time by publishing a new version on our website.
    2. 7.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
    3. 6.5 We may notify you of changes to this policy by email [ or through the private messaging system on our website].
  8. 8.Your rights
    1. 8.1 In this Section 8, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
    2. 8.2 Your principal rights under data protection law are:
      1. (a)the right to access;
      2. (b)the right to rectification;
      3. (c)the right to erasure;
      4. (d)the right to restrict processing;
      5. (e)the right to object to processing;
      6. (f)the right to data portability;
      7. (g)the right to complain to a supervisory authority; and
      8. (h)the right to withdraw consent.
    3. 8.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.

      With respect to the data you have supplied to our website (or are able to supply to our website) you can access and amend it at any time by visiting 'My Details' and other user pages when logged into our website. With respect to other data the website may have generated about you (such as [transactions, projects, appointments etc - make appropriate lists]) this can also be viewed by visiting the relevant user pages when logged into our website.
    4. 8.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

      With respect to the data you have supplied to our website (or are able to supply to our website) you can access and amend it by visiting 'My Details' and other user pages when logged into our website. With respect to other data the website may have generated about you (such as [transactions, projects, appointments etc - make appropriate lists]) this can also be viewed by visiting the relevant user pages when logged into our website, but you should contact us using one of the methods in section 10 below if you believe any information is incorrect or incomplete and needs amending.
    5. 8.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: [the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed]. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: [for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims].

      With respect to the data you have supplied to our website (or are able to supply to our website) and any data that the website may have generated about you (such as [transactions, projects, appointments etc - make appropriate lists]) you can request deletion of this data from the website. This should be initiated in [one of the following ways | the following way]:
      1. (a) Contact us using one of the methods in section 10 below and request erasure of your personal details from the website. You will be required to provide appropriate evidence of your identity.
      2. [when online deletion is enabled, add it here...]
      Onc you have done this, any online account you have on the website will be closed and your data will be removed from the website within 28 days.
    6. 8.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
    7. 8.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
    8. 8.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
    9. 8.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
    10. 8.10 To the extent that the legal basis for our processing of your personal data is:
      1. (a)consent; or
      2. (b)that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,
      and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
    11. 8.11 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
    12. 8.12 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.
    13. 8.13 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. You will be required to provide appropriate evidence of your identity.
  9. 9.Cookies

    Please see our Cookie Policy for details about our use of cookies on this website.

  10. 13.Our details
    1. 13.1 This website is owned and operated by [name].
    2. 13.2 We are registered in [England and Wales] under registration number [number], and our registered office is at [address].
    3. 13.3 Our principal place of business is at [address].
    4. 13.4 You can contact us:
      1. (a)by post, to [the postal address given above or alternative];
      2. (b)using our website contact form;
      3. (c)by telephone, on the contact number published on our website from time to time; or
      4. (d)by email, using the email address published on our website from time to time.
      5. added[additional list items]
  11. 14.Data protection officer
    1. 14.1 Our data protection officer's contact details are: [contact details].