COOKIES

We are committed to protecting your privacy and we are the controller responsible for your personal information. This Privacy Policy should be read in conjunction with the Terms and Conditions of Use and the Cookie Policy for billybillingham.com (the “Website”) of which it forms part.

This Privacy Policy explains how we use the information we collect about you, that the rights you have in relation to your personal information and procedures that we have in place to safeguard your privacy.

We may amend this Privacy Policy from time to time to keep it up to date with legal requirements and the way we operate our business. Please regularly check these pages for the latest version of this notice.

The information we collect and how we use it

We will use, store or otherwise process any information that relates to you as an identifiable person (“personal information”), including but not limited to your name, postal address, e-mail address, telephone number and any other information collected on registration, through surveys and through competitions, to the extent reasonably necessary to provide the services that are available through our Website, and for the other purposes described below. We collect personal information through:

· direct interactions with you (for example, where you provide us with your information in relation to a survey or competition we are running); or

· automated technologies or interactions.

Please see our Cookie Policy for further information regarding the collection of personal information through automated technologies.

We process your personal information for the purpose of:

1. dealing with your enquiries and requests

2.providing and personalising our services

3.establishing, exercising and defending our legal rights, as well as crime prevention and prosecution of offenders

4. carrying out market research campaigns

5.running competitions and other promotional events and campaigns

6. complying with our legal or regulatory obligations

We also gather information and statistics (using the automated technologies described above) for the purposes of monitoring Website usage, and we may provide such information (in an aggregated form that does not identify you) to third parties. If you choose to post messages on our Website, we will collect that information you provide to us. We retain this information as necessary to resolve disputes, provide customer support and troubleshoot problems as permitted by law.

Marketing and our communications with you

You may from time to time wish us to provide you with information about our Website or our other service or products. We will only send you information about:

· our services; or

·services offered jointly with or on behalf of other organizations, if you have asked us to provide you with such information.

We will only ever send you promotional information in accordance with your preferences.

Alternatively, you may ask us to provide you with information about our services and/or services offered jointly with or on behalf of other organisations by sending us an e-mail at james@gordonpoole.com

If you stop using the Website or your permission to use the Website is terminated, we may continue to use and disclose your personal information in accordance with this Privacy Policy (as amended from time to time) and as permitted by law. However, if you wish us to stop e-mailing you with information in connection with the Website, please send your request in accordance with the “Your rights in relation to your information” section below.

The legal basis for using your personal information

We will only collect, use and share your personal information where we are satisfied that we have an appropriate legal basis to do this. This may be because:

· our use of your personal information is in our legitimate interest as a commercial organization (for example, where we undertake market research) – in these cases we will look after your information at all times in a way that is proportionate and respects your privacy rights and you have a right to object to processing as explained in the “Your rights in relation to your information” section below;

· you have provided your consent to us using your personal information (for example, in relation to any electronic direct marketing communications we send to you, except to the extent that electronic marketing is permitted on a ‘legitimate interest’ basis, or to collect information through the use of ‘non-essential’ cookies);

· our use of your personal information is necessary to perform a contract or take steps to enter into a contract with you (for example, to facilitate your entry into the competitions that you enter or to carry out processing required by the Terms and Conditions of Use); and/or

· our use of your personal information is necessary to comply with a relevant legal or regulatory obligation that we have (for example, where we are required to make filings with HMRC or other government agencies, or to comply with requests or law enforcement or other regulatory bodies).

Information security and retention

The Internet is not a secure medium. However, we have put in place various security procedures as set out in this Privacy Policy. Please be aware that communications over the Internet, such as emails/webmails are not secure unless they have been encrypted. We cannot accept responsibility for any unauthorised access or loss of personal information that is beyond our control. We adopt appropriate policies, rules and technical measures to protect the personal data that we have under our control (having regard to the type and amount of that data) from unauthorised access, improper use or disclosure, unauthorised modification, unlawful destruction or accidental loss. All of our employees and data processors that have access to, and are associated with, the processing of your personal information are obliged to respect the confidentiality of our visitors’ information. We will store your personal information for as long as is reasonably necessary for the purposes for which it was collected, as explained in this Privacy Policy. In some circumstances we may store your personal information for longer periods of time, for instance where we are required to do so in accordance with legal, regulatory, tax, accounting requirements.

In specific circumstances we may store your personal information for longer periods of time so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your personal information or dealings.

To whom will your information be disclosed?

Your information may, for the purposes set out in this Privacy Policy, be disclosed for processing to:

1.our employees;

2.our group companies and their employees;

3.successors in title to our business and any potential or actual third party purchaser of our business or assets;

4.third party consultants, contractors or other service providers who may access your personal information when providing services (including but not limited to IT support services) to us;

5.government bodies and law enforcement agencies and in response to other legal and regulatory requests;

6.auditors or contractors or other advisers auditing, assisting with or advising on any of our business purposes, in any jurisdiction where we operate.

Your rights in relation to your information

Subject to certain exemptions, and in some cases dependent upon the processing activity we are undertaking, you have certain rights in relation to your personal information. We may ask you for additional information to confirm your identity and for security purposes, before disclosing the personal information requested to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. You can exercise your rights by contacting us using the contact details set out at the end of this Privacy Policy. Please quote your name and address. We may not always be able to fully address your request, for example if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.

You can write to us at any time to obtain a copy of your information and to have any inaccuracies corrected. Where appropriate, you may have your personal information erased, rectified or amended. We should be grateful if you would also provide brief details of the information of which you would like a copy or which you would like to be corrected (this helps us to more readily locate your data).

You can ask us to restrict our use of your personal information, but only where (i) its accuracy is contested, to allow us to verify its accuracy; or (ii) the processing is unlawful, but you do not want it erased; (iii) it is no longer needed for the purposes for which it was collected, but we still need it to establish, exercise or defend legal claims; or (iv) you have exercised the right to object (see below), and verification of overriding grounds is pending.

You can object to any processing of your personal information which has our legitimate interests as its legal basis, if you believe your fundamental rights and freedoms outweigh our legitimate interests. If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.

You can request that we change the manner in which we contact you for marketing purposes.

You also have the right to lodge a complaint with the Information Commissioner’s Office, which can be contacted on 0303 123 1113 or via other methods of communication as explained on their website (currently https://ico.org.uk).

Cookies

Our Website uses cookies for identification, analysis and advertising purposes. By using the Website you consent to the storing and accessing of cookies on your device. Please see our Cookie Policy for more information on how our Website uses cookies.

Transferring information globally

Owing to the global nature of the Internet infrastructure, the information you provide may be transferred to countries outside of the United Kingdom and European Economic Area (“EEA”). Countries outside of the UK / EEA may not have similar legal protections in place regarding your personal information. However, we have taken the steps outlined in the “Information security and retention” section above to try and protect the security of your information. Where we transfer your personal information to third parties who help provide our services, we obtain contractual commitments from them to protect your personal information. Some of these assurances are well recognized certification schemes like the ’standard contractual clauses’. You have a right to contact us (using the details at the end of this Privacy Policy) for more information about the safeguards we have put in place to ensure the adequate protection of your personal information when this is transferred as mentioned above.

Use of your personal information submitted to other websites

We are not responsible for the privacy policies and practices of other websites even if you accessed the third party website using links from our Website. We recommend that you check the policy of each website you visit and contact the owner or operator of such website if you have concerns or questions.

Further information

For further information from us on data protection and privacy or to make any requests concerning your personal information please contact us by email at james@gordonpoole.com