1.1. We are committed to safeguarding the privacy of our website visitors and customers; in this policy we explain how we will handle your personal data.
1.2. This policy applies where we are acting as a data controller with respect to your personal data; in other words, where we determine the purposes and means of the processing of that personal data.
1.3. Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier‘
1.5. Our website incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can specify whether you would like to receive direct marketing communications.
1.6. In this policy, "we", "us" and "our" refer to Equahost Ltd and our employees and representatives. For more information about us, see Section 18.
2. How we use your personal data
2.1. In this Section 2 we have set out:
a) the general categories of personal data that we may process and retain;
b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
c) the purposes for which we may process and store personal data; and
d) the legal bases of the processing.
2.2 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. We may use this information to improve and optimise our website and shop (for example, by generating analytics about how our customers browse and interact with the Equahost Ltd website, and to assess the success of marketing and communications). The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.
2.3 We may process information that you post for publication on our website, social media 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.
2.4 We may process information relating to our supplier and trade customer relationships, including supplier and trade customer contact information ("supplier and trade customer relationship data"). The supplier and trade customer relationship data may include your name, your employer, your job title or role, your contact details, and information contained in communications between us and you or your employer. The source of the supplier and trade customer relationship data is you or your employer. The supplier and trade customer relationship data may be processed for the purposes of managing our relationships with suppliers and trade customers, communicating with suppliers and trade customers, keeping records of those communications and promoting our products and services to suppliers and trade customers. The legal basis for this processing is our legitimate interests, namely the proper management of our supplier and trade customer relationships.
2.5 We may process information relating to completed or attempted transactions, including purchases of goods and/or services, that you enter into with us directly and through our website ("transaction data"). The transaction data may include your name, email address, phone number, your card details including billing and shipping address and the transaction details. The source of the transaction data is you and our payment services provider. The transaction data may be processed for the purpose of supplying the purchased goods and/or 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; providing that, if you are not the person contracting with us, the legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.
2.6 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 and our legitimate interests, namely communications with our website visitors and customers.
2.7 We may process information contained in or relating to any communication that you send to us via any channel ("communication data"). The communication 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 communication 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 communications with our website visitors and customers and the proper administration of our website and business.
2.8 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.
2.9 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.
2.10 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.
3. Providing your personal data to others
3.1. 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.
3.2. Your personal data held in our website database which will be stored on our servers.
3.3. Financial transactions relating to our website and services are handled by our payment services providers GoCardless. 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://gocardless.com/privacy/
3.4. In addition to the specific disclosures of personal data set out in this Section 3, 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. Equahost Ltd is located in the UK; however we may use services and third parties based outside of the UK and EEA. 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 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.
5.2. 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. When we no longer need to use your information and there is no need for us to keep it to comply with our legal or regulatory obligations, we’ll either remove it from our systems or de-personalise it so that you are not identifiable.
5.3. 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.
6.1. We may use your personal data to provide you with targeted advertisements or marketing communications we believe may be of interest to you. You can find more information about how targeted advertising works at https://www.networkadvertising.org/understanding-online-advertising
6.2. You can opt out of targeted advertising services by visiting the Digital Advertising Alliance’s opt-out portal at http://optout.aboutads.info/
7. Do not track
7.1. Please note that we do not alter our data collection and use practices when we see a Do Not Track signal from your browser
8. Security of personal data
8.1. 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.
8.2. We will store all your personal data on secure servers, personal computers and mobile devices, and in secure manual record-keeping systems.
8.3. Where relevant, for example data relating to your enquiries and financial transaction, personal data will be protected using encryption technology.
8.4. 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.
9. Your rights
9.1. In this Section 9, 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.
9.2. Your principal rights under data protection law are:
a) the right to access - you can ask for copies of your personal data;
b) the right to rectification - you can ask us to rectify inaccurate personal data and to complete incomplete personal data;
c) the right to erasure - you can ask us to erase your personal data;
d) the right to restrict processing - you can ask use to restrict the processing of your personal data;
e) the right to object to processing - you can object to the processing of your personal data;
f) the right to data portability - you can ask that we transfer your personal data to another organisation or to you;
g) the right to complain to a supervisory authority - you can complain about our processing of your personal data; and
h) the right to withdraw consent - to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.
9.3. 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.
9.4. You may exercise any of your rights in relation to your personal data by contacting us as set out in Section 18.
10. Third party websites
10.1 Our website includes hyperlinks to, and details of, third party websites.
10.2 We have no control over, and are not responsible for, the privacy policies and practices of third parties.
11. Personal data of children
11.1. Our website and services are for persons over the age of 18.
11.2. If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.
12. Updating information
12.1 Please let us know if the personal information that we hold about you needs to be corrected or updated using the contact methods set out in Section 18.
13. About cookies
13.1 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.
13.2 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.
13.3 Cookies do not typically contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.
14. Cookies that we use
15. Cookies used by our service providers
16. Managing cookies
16.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
a) https://support.google.com/chrome/aniswer/95647 (Chrome);
b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
c) https://help.opera.com/en/latest/security-and-privacy/ (Opera);
d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
e) https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac (Safari); and
f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
16.2 Blocking all cookies will have a negative impact upon the usability of many websites.
16.3 If you block cookies, you will not be able to use all the features on our website.
17.1 We may update this policy from time to time by publishing a new version on our website.
17.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
18. Our details
18.1 This website is owned and operated by Equahost Ltd.
18.2 We are registered in England and Wales under registration number 9350312, and our registered office and principal place of business is at 71-75 Shelton Street, London, WC2H 9JQ.
18.3 You can contact us:
a) by post, to the postal address given in 18.2;
b) using our website contact form;
c) by email, at firstname.lastname@example.org
19. Data protection officer
19.1 Our data protection officer is Oliver Goodall
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