This is the privacy notice of The Links Group.
We respect your privacy and are determined to protect your personal data. The purpose of this privacy notice is to inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from). We’ll also tell you about your privacy rights and how the data protection law protects you.
This privacy notice has been divided into specific areas as set out below:
1. WHO WE ARE AND IMPORTANT INFORMATION
2. THE PERSONAL DATA WE COLLECT ABOUT YOU
3. HOW WE COLLECT YOUR PERSONAL DATA
4. HOW WE USE YOUR PERSONAL DATA
5. WHO WE SHARE YOUR PERSONAL DATA WITH
6. INTERNATIONAL TRANSFERS
7. DATA SECURITY
8. DATA RETENTION
9. YOUR LEGAL RIGHTS
10. CHANGES TO THIS NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
11. QUERIES, REQUESTS OR CONCERNS
What is the purpose of this privacy notice?
This privacy notice aims to give you information on how we collect and process your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter, complete a marketing questionnaire, complete a contact form, complete a member registration form to join, register and participate in the community forum, or purchase a product or service.
This website is not intended for children and we do not knowingly collect data relating to children.
You must read this privacy notice together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
Who We Are And Important Information
The Links Group is the controller and responsible for your personal data (collectively referred to as "The Links Group", "we", "us" or "our" in this privacy notice). Our contact details are The Links Group, 2 Newark Road South, Glenrothes, Glenrothes, KY7 4NR, email: firstname.lastname@example.org. For all data matters contact Wendy Sneddon at email@example.com. The Links Group is the controller and responsible for this website.
The Personal Data We Collect About You
Personal data, or personal information, means any information about an individual from which that person can be identified. You can find out more about personal data from the Information Commissioners Office.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
· Communication Data that includes any communication that you send to us whether that be through the contact form on our website, through email, text, social media messaging, social media posting or any other communication that you send us. We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defence of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.
· Customer Data that includes data relating to any purchases of goods and/or services such as your name, title, billing address, delivery address, email address, phone number, contact details, purchase details and your card details. We process this data to supply the goods and/or services you have purchased and to keep records of such transactions. Our lawful ground 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.
· User Data that includes data about how you use our website and any online services together with any data that you post for publication on our website or through other online services. We process this data to operate our website and ensure relevant content is provided to you, to ensure the security of our website, to maintain back- ups of our website and/or databases and to enable publication and administration of our website, other online services and business. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business.
· Technical Data that includes data about your use of our website and online services such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is from our analytics tracking system. We process this data to analyse your use of our website and other online services, to administer and protect our business and website, to deliver relevant website content and advertisements to you and to understand the effectiveness of our advertising. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business and to grow our business and to decide our marketing strategy.
· Marketing Data that includes data about your preferences in receiving marketing from us and our third parties and your communication preferences. We process this data to enable you to partake in our promotions such as competitions, prize draws and free giveaways, to deliver relevant website content and advertisements to you and measure or understand the effectiveness of this advertising. Our lawful ground for this processing is our legitimate interests which in this case are to study how customers use our products/services, to develop them, to grow our business and to decide our marketing strategy.
We also collect, use and share
Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your technical data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your customer data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
We may use Customer Data, User Data, Technical Data and Marketing Data to deliver relevant website content and advertisements to you (including Facebook adverts or other display advertisements) and to measure or understand the effectiveness of the advertising we serve you. We may also use such data to send other marketing communications to you. Our lawful ground for this processing is legitimate interests which is to grow our business.
We may process your personal data without your knowledge or consent where this is required or permitted by law. We reserve the right to carry out automated decision making or automated profiling.
If you fail to provide personal data
Where we need to collect your personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
How We Collect Your Personal Data
We use different methods to collect data from and about you. You may give us your Communication Data, Customer Data, User Data, Technical Data and Marketing Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
· Apply for our products or services;
· Create an account on our website;
· Subscribe to our service or publications;
· Contact us to make an enquiry;
· Request marketing to be sent to you.
We may also receive data from third parties such as analytics providers such as Google based outside the EU, advertising networks such as Facebook based outside the EU, such as search information providers such as Google based outside the EU, providers of technical, payment and delivery services, such as data brokers or aggregators.
How We Use Your Personal Data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
· Performance of Contract this means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
· Legitimate Interest this means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests.
· Comply with a legal or regulatory obligation this means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Marketing Our lawful ground of processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business).
Under the Privacy and Electronic Communications Regulations, we may send you marketing communications from us if (i) you made a purchase or asked for information from us about our goods or services or (ii) you agreed to receive marketing communications and in each case you have not opted out of receiving such communications since.
Under these regulations, if you are a limited company, we may send you marketing emails without your consent.
Generally we do not rely on consent as a legal basis for processing your personal data. You have the right to withdraw consent to marketing at any time by contacting us at firstname.lastname@example.org.
Promotional offers from us We may use your personal data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.
Third-party marketing On occasions, we will share your personal data with organsations outside of The Links Group for marketing purposes. We may share your marketing data with other third parties who we believe can offer a complimentary service.
Opting out You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by emailing email@example.com at any time.
Where you opt-out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product or service experience or other transaction.
Who We Share Your Personal Data With
We may have to share your personal data with the parties set out below:
· Internal third parties who are part of The Links Group
· External third parties:
o Service providers who provide IT and system administration services.
o Professional advisers including lawyers, bankers, auditors and insurers.
o HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by implementing safeguards:
· We will only transfer your personal data to countries that the European Commission have approved as providing an adequate level of protection for personal data by; or
· Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or
· If we use US-based providers that are part of EU-US Privacy Shield, we may transfer data to them, as they have equivalent safeguards in place.
If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
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.
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.
By law, we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances, we may anonymise your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Your Legal Rights
Unless subject to an exemption under the data protection laws, you have the following rights with respect to your personal data:
· The right to request a copy of the personal data which we hold about you;
· The right to request that we correct any personal data if it is found to be inaccurate or out of date;
· The right to request your personal data is erased where it is no longer necessary to retain such data;
· The right to withdraw your consent to the processing at any time, where consent was the lawful basis for processing your data;
· The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
· The right to object to our processing of personal data, where applicable i.e. where processing is based on our legitimate interests, direct marketing or processing for the purposes of scientific/historical research and statistics.
If you wish to exercise any of the rights set out above, please contact Wendy Sneddon at firstname.lastname@example.org.
No fee required – with some exceptions
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 admin fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you 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.
Time limit to respond 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 updated.
Changes To This Notice And Your Duty To Inform Us Of Changes
Please keep us informed if your personal data changes during your relationship with us. It is important that the personal data we hold about you is accurate and current.
Queries, Requests Or Concerns
To exercise all relevant rights, queries or complaints in relation to this policy or any other data protection matter between you and us, please in the first instance contact Wendy Sneddon at email@example.com.
If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 03031231113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England, UK.
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.
We use the following cookies:
· Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
· Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
· Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
· Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
These cookies are likely to be analytical/performance cookies or targeting cookies.
· to ensure you are properly logged in, where this is necessary to use the website
· to store personal registration information so that you do not have to provide it to us again on subsequent visits
· to track your progress through the website so we can make improvements to the service we offer you, and/or
· to remember any preferences which the website may allow you to set
If you wish to receive more information on the cookies that we use on this website, please contact us at firstname.lastname@example.org.
The General Data Protection Regulation requires website users to be told about cookies used on this website and to opt into accepting cookies.
You will see the opt-in option at the bottom of the screen. You must make a choice.
· Opting In If you choose to opt into cookies, we will place a small cookie on your system to help us remember that you have chosen to accept technical, session, performance, tracking, and persistent cookies. This will give you full use of this website now and in the future.
· Opting out If you choose to opt-out of accepting all the cookies you are able to refuse, we will disable these cookies. You may find that much of this website, or sections of it, will no longer work. As we place no cookies on your system to remember this opt-out choice, you will see the cookies banner on every subsequent visit to this website.
· Using your browser controls to control your cookie settings Most web browsers (including Chrome, Internet Explorer, Firefox and Safari) allow you to control your cookie settings and to delete any cookies already stored on your computer or other devices.
THIRD PARTY WEBSITES