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PRIVACY POLICY
EFFECTIVE DATE: 14 MARCH 2023
This Privacy Policy sets out how we, Selectabase Limited, collect, store and use
information about you when you use or interact with our website,
www.selectabase.co.uk (our website) and where we otherwise obtain or collect
information about you.
CONTENTS
1. Summary
2. Our details
3. Information we collect when you contact us
4. Information we collect when you visit or interact with our website
5. Information obtained from third parties for use in our direct marketing
products and services
6. Our use of automated decision-making and profiling
7. Disclosure and additional uses of your information
8. How long we retain your information
9. How we secure your information
10. Transfers of your information outside the UK and European Economic Area
11. Your rights in relation to your information
12. Your right to object to the processing of your information for certain
purposes
13. Sensitive Personal Information
14. Changes to our Privacy Policy
15. Children’s Privacy
16. California Do Not Track Disclosures
17. CCTV
18. Copyright
1. SUMMARY
This section summarises how we obtain, store and use information about you. It
is intended to provide a very general overview only. It is not complete in and
of itself and it must be read in conjunction with the corresponding full
sections of this Privacy Policy.
* Data controller: Selectabase Limited
* How we collect or obtain information about you:
* When you provide it to us (e.g. by contacting us, placing an order on our
website, by subscribing for our newsletter and through creating an account),
* From your use of our website, using cookies and similar technologies, and
from third party suppliers
* Information we collect: name, contact details, email address, telephone
number, date of birth, IP address, profile information, information from
cookies, information about your computer or device (e.g. device and browser
type), information about how you use our website (e.g. which pages you have
viewed, the time when you view them and what you clicked on, the geographical
location from which you accessed our website (based on your IP address), your
company’s name or business name, your company registration number, ICO
registration number and FCA number (if applicable)
* How we use your information: for administrative and business purposes
(particularly to contact you and process orders you place on our website), to
improve our business and website, to fulfil our contractual obligations, to
advertise our goods and services, to analyse your use of our website, and in
connection with our legal rights and obligations
* Disclosure of your information to third parties: only to the extent necessary
to run our business, to our service providers, to fulfil any contracts we
enter into with you, and where required by law or to enforce our legal rights
* Do we sell or pass on your information to third parties (other than in the
course of a business sale or purchase or similar event)? Not where you have
supplied the information to us directly. We do, however, obtain information
from third party suppliers for use in our goods and services and this
involves the sale of personal information to third parties. We will only sell
your information to third parties if it is included in the data we have
acquired from our third party suppliers in accordance with data protection
rules and regulations and where it is in our legitimate interests and/or the
legitimate interests of third parties to do so for direct marketing and
profiling purposes. For further information, please see the section below
entitled 5. Information obtained from third parties for use in our direct
marketing products and services
* How long we retain your information: for no longer than necessary, taking
into account any legal obligations we have (e.g. to maintain records for tax
purposes), any other legal basis we have for using your information (e.g.
your consent, performance of a contract with you or our legitimate interests
as a business) and certain additional factors described in the main section
below entitled 8. How long we retain your information. For specific retention
periods in relation to certain information which we collect from you, please
see the main section below entitled 8. How long we retain your information
* How we secure your information: using appropriate technical and
organisational measures such as storing your information on secure servers,
encrypting transfers of data to or from our servers using Secure Sockets
Layer (SSL) technology, only granting access to your information where
necessary
* Use of cookies and similar technologies: we use cookies and similar
information-gathering technologies including essential, functional and
analytical cookies. For more information, please visit our cookies policy
here: https://www.selectabase.co.uk/cookies/
* Transfers of your information outside the UK and European Economic Area: In
certain circumstances, we will transfer your information outside of the UK
and European Economic Area, including to the USA. Where we do so, we will
ensure appropriate safeguards are in place, including, for example, that the
third parties we use who transfer your information outside the UK and
European Economic Area have self-certified themselves as compliant with the
EUU.S. Privacy Shield
* Use of automated decision-making and profiling: we use automated profiling on
our website through our use of web analytics. We do not use automated
decision-making. For further information, please see 6. Our use of automated
decision-making and profiling below
* Your rights in relation to your information: to access your information and
to receive information about its use, to have your information corrected
and/or completed, to have your information deleted, to restrict the use of
your information, to receive your information in a portable format to object
to the use of your information, to withdraw your consent to the use of your
information, to complain to a supervisory authority
* Sensitive personal information: we do not knowingly or intentionally collect
what is commonly referred to as ‘sensitive personal information’. Please do
not submit sensitive personal information about you to us. For more
information, please see the main section below entitled 13. Sensitive
Personal Information
2. OUR DETAILS
DATA CONTROLLER
The data controller is Selectabase Limited, a limited company registered in
England and Wales (company registration number 05234487). Our registered address
is The Archive Centre, Honeywood.
Road, Dover, Kent, CT16 3EH. You can contact the data controller by writing to
Selectabase Limited, The Archive Centre, Honeywood Road, Dover, Kent, CT16 3EH
or sending an email to admin@selectabase.co.uk.
If you have any questions about this Privacy Policy, please contact the data
controller using the contact details of the Data Protection Officer below:
DATA PROTECTION OFFICER
We have appointed GRCI Law Limited, to act as our DPO.
Postal address
DQM GRC Limited
Cressex Business Park,
Wellington Road,
High Wycombe HP12 3PR
Email: selectabasedpo@dqmgrc.com Tel: +44 (0) 1494 442900
EU REPRESENTATIVE
We have appointed IT Governance Europe Limited to act as our EU Representative.
If you wish to exercise your rights under the EU General Data Protection
Regulation (GDPR), or have any queries in relation to your rights or privacy
matters generally please contact our Representative using these contact details.
Please ensure you include our company name in any correspondence.
EU Representative
IT Governance Europe
The Mill, Newtown Link Rd,
Stagreenan, Drogheda, Co. Louth, A92 CD3D, Ireland
Email: eurep@itgovernance.eu
3. INFORMATION WE COLLECT WHEN YOU CONTACT US
We collect and use information from individuals who contact us in accordance
with this section and the section entitled 7. Disclosure and additional uses of
your information.
Visit the following link to Your Data Rights –
https://www.selectabase.co.uk/your-data-rights/
Information collected Legal basis for processing Transfer and storage Email
When you send an email to the email address displayed on our website we collect
your email address and any other information you provide in that email (such as
your name, telephone number and the information contained in any signature block
in your email).
Legitimate interests
(Article 6(1)(f) of the General Data Protection Regulation
“GDPR”). We have a legitimate interest in responding to enquiries and messages
we receive and keeping records of correspondence.
Necessary to perform a contract or to take steps at your request to enter into a
contract (Article 6(1)(b) of the GDPR). Where your message relates to us
providing you with goods or services or taking steps at your request prior to
providing you with our goods and services (for example, providing you with
information about such goods and services), we will process your information in
order to do so).
We use a third-party email provider to store emails you send us. Our third-party
email provider is Intermedia.
Emails you send us are stored within the United Kingdom.
Contact form
When you contact us using our contact form, we collect your name, first name,
email address, phone number and postcode. We also collect any other information
you provide to us when you complete the contact form.
If you do not provide the mandatory information required by our contact form,
you will not be able to submit the contact form and we will not receive your
enquiry.
Messages you send us via our contact form will be stored in our servers in the
United Kingdom. Phone
When you contact us by phone, we collect your phone number and any information
provide to us during your conversation with us.
Information about your call, such your phone number and the date and time of
your call, is processed by our third-party telephone service provider and stored
in the United Kingdom.
Calls are recorded for training and monitoring purposes. The retention period
for recorded calls is 2 years.
Post
If you contact us by post, we will collect any information you provide to us in
any postal communications you send us.
Information you send us by post is stored in the United Kingdom.
4. INFORMATION WE COLLECT WHEN YOU VISIT OR INTERACT WITH OUR WEBSITE
We collect and use information from website visitors in accordance with this
section and the section entitled 7. Disclosure and additional uses of your
information.
Visit the following link to Your Data Rights –
https://www.selectabase.co.uk/your-data-rights/
Information collected Legal basis for processing Transfer and storage Web server
log information
We use our own web server to host our website. Our web server automatically logs
the IP address you use to access our website as well as other information about
your visit such as the pages accessed, information requested, the date and time
of the request, the source of your access to our website (e.g. the website or
URL (link) which referred you to our website), and your browser version and
operating system.
We collect and store server logs to ensure network and IT security and so that
the server and website remain uncompromised. This includes analysing log files
to help identify and prevent unauthorised access to our network, the
distribution of malicious code, denial of services attacks and other
cyber-attacks, by detecting unusual or suspicious activity.
Unless we are investigating suspicious or potential criminal activity, we do not
make, nor do we allow our hosting provider to make, any attempt to identify you
from the information collected via server logs.
Compliance with a legal obligation to which we are subject (Article 6(1)(c) of
the
GDPR). We have a legal obligation to implement appropriate technical and
organisational measures to ensure a level of security appropriate to the risk of
our processing of information about individuals.
Recording access to our website using server log files is such a measure.
Legitimate interests (Article 6(1)(f) of the GDPR). We have a legitimate
interest in using your information for the purposes of ensuring network and
information security.
Our web server is located in the United Kingdom. Cookies
Cookies are data files which are sent from a website to a browser to record
information about users for various purposes.
We use cookies on our website, including essential, functional and analytical
cookies. For further information on how we use cookies, please see our cookies
policy which is available here: https://www.selectabase.co.uk/cookies/
You can reject some or all of the cookies we use on or via our website by
changing your browser settings but doing so can impair your ability to use our
website or some or all of its features. For further information about cookies,
including how to change your browser settings, please visit allaboutcookies.org
or see our cookies policy.
Consent (Article 6(1)(a) of he GDPR). Please see our cookie policy for further
information: https://www.selectabase.co.uk/cookies/ E-newsletter
When you sign up for our e-newsletter, to receive information, news and offers
about our products, services and promotions from us, by contacting our sales
staff and requesting to be added to our e-newsletter mailing list, we collect
your name and email address.
Consent (Article 6(1)(a) of the GDPR). We use a third-party provider to send out
our e-newsletter and administer our mailing list, called Mailgun. You can access
their privacy policy here: www.mailgun.com/privacy-policy/
Information you submit to subscribe for our e-newsletter will be stored within
the European Economic Area on Mailgun’s.
Registering on our website
When you register and create an account on our website, we collect your name,
title, email address, company, address, telephone number, IP address and any
other information you provide to us when you complete the registration form,
including any optional information (if applicable), such as your industry,
company registration number, ICO registration number and FCA number.
If you do not provide the mandatory information required by the registration
form, you will not be able to register or create an account on our website.
If you do not supply the optional information requested by our registration
form, this may affect the time it takes for us to process your order and/or our
ability to understand your requirements for our services.
Legitimate interests (Article 6(1)(f) of the GDPR). We have a legitimate
interest in registering and administering accounts on our website to provide you
the ability to upload feedback and to facilitate the running and operation of
our business. The information you submit will be stored in our servers in the
United Kingdom. When you place an order on our website
Mandatory Information
When you place an order for goods or services on our website, we collect your
name, title, email address, company name, telephone number, billing/shipping
address and IP address.
If you do not provide this information, you will not be able to purchase goods
or services from us on our website or enter into a contract with us.
Necessary to perform a contract (Article 6(1)(b) of the GDPR). We need the
mandatory information collected by our checkout form to establish who the
contract is with and to contact you to fulfil our obligations under the
contract, including sending you receipts and order confirmations.
Compliance with a legal obligation (Article 6(1)(c) of the GDPR). We have a
legal obligation to issue you with an invoice for the goods and services you
purchase from us where you are VAT registered and we require the mandatory
information collected by our checkout form for this purpose. We also have a
legal obligation to keep accounting records, including records of transactions.
Legitimate interests (Article 6(1)(f)). We collect your phone number for our
legitimate interest of more easily and effectively contacting you in relation to
your order and your account.
The information you submit will be stored in our servers in the United Kingdom.
Optional information
We also collect optional information from you, such as your industry, company
registration number and ICO registration number.
Your consent (Article 6(1)(a) GDPR). You consent to us processing any optional
information you provide by providing it to us. Processing your payment
After you place an order on our website, or offline via our contact number, you
will need to make payment for the goods or services you have ordered. In order
to process your payment, we use a third party payment processor. Your payment
will be processed by Sage Pay.
Sage Pay collects, uses and processes your information, including payment
information, in accordance with their privacy policies. You can access their
privacy policies via the following link:
https://www.sagepay.co.uk/policies/privacy-policy/
Necessary to perform a contract (Article 6(1)(b) of the GDPR). To fulfil your
contractual obligations to pay for the goods or services you have ordered from
us. Sage Pay may transfer information relating to your transaction and the
processing of your transaction outside the European Economic Area. Where they do
so, they will put
appropriate safeguards in place.
For further information about the safeguards used when your information is
transferred outside the European
Economic Area, see the section of this privacy policy below entitled Transfers
of your information outside the European Economic Area.
5. INFORMATION OBTAINED FROM THIRD PARTIES FOR USE IN OUR DIRECT MARKETING
PRODUCTS AND SERVICES
This section sets out how we obtain information about you from third party data
suppliers (such as Experian – see
https://www.experian.co.uk/privacy/consumer-information-portal/) from which we
acquire business to business and business to consumer data, for use in our
direct marketing products and services.
HOW WE OBTAIN INFORMATION ABOUT YOU FROM SUPPLIERS
Our suppliers (such as Experian – see
https://www.experian.co.uk/privacy/consumer-information-portal/) obtain
information via third party forms which set out how your personal information
will be used and that it will be transferred to third parties for their direct
marketing and profiling purposes. They then transfer this information to us.
Once we have obtained your information from our suppliers, we may either use
this information for our own direct marketing and profiling purposes and/or pass
this information on to third parties for their direct marketing and profiling
purposes.
INFORMATION WE OBTAIN FROM THIRD PARTY SUPPLIERS
Information we obtain from third party suppliers will include:
* Business to business contact data such as name, business name, address,
telephone number, email address (for incorporated companies only), Companies
House information, and business profiling information. This data is screened
for use in the direct marketing channels postal, telephone and corporate
email marketing
* Business to consumer contact data such as name, address, and consumer
profiling information. Used for postal marketing only. This data is screened
for use in the direct marketing channel postal marketing only
Legal basis for processing: our and third parties’ legitimate interests (Article
6(1)(f) of the GDPR).
Legitimate interests: where a third party supplier has shared information about
you with us (and you have not objected to the processing of your information) we
will have a legitimate interest in processing that information for our own
direct marketing and profiling purposes and the legitimate interests of third
parties for their direct marketing and profiling purposes.
PROFILING
Profiling is any form of processing of your information to evaluate personal
aspects about you, in particular to analyse or predict things like your
performance at work, economic situation, health, personal preferences,
interests, reliability, behaviour, location or movements.
We analyse your information based on various criteria, such as geographical
area, business size and type to determine which data is likely to be the most
relevant for our and/or our clients’ direct marketing purposes. By analysing and
categorising your information based on certain criteria, we are able to ensure
that the direct marketing conducted by us and our clients is as relevant and
targeted as it can be and to reduce costs.
WHO WE SUPPLY YOUR DATA TO
Your data will be provided to carefully selected reputable organisations (our
clients). We and our clients will only use your data for: marketing
communications, profiling (including market research and analysis and
segmentation).
We and our clients operate in the following areas for use in the manners
described above – Retail, Financial Services, Lifestyle, Household & Technology,
and Public Sector.
Retail Financial Services Lifestyle Household & Technology Public Sector Fashion
& Leisure Goods Comparison Websites Astrology Electric, Gas & Water Utilities
Government Food & Drink Financial
Providers/Services
Automotive Multi-Utilities Legal Services Producers & Retailers Insurance
Providers Competition Sites Home Improvement Not for Profit Marketing &
Advertising Shares Education & Research Construction General Retailers
Prospecting Self Improvement Household Goods & Services FMCG Gambling IT
Services & Software Mail Order Health & Welfare Media, TV & Radio Prospecting
Parenting Film online & Print Subscription Services Real Estate
Entertainment/Gaming/Leisure Telecommunications Charity Travel
If you wish to opt out from Selectabase providing your details to third parties
please visit the following link – https://www.selectabase.co.uk/data-optout
Visit the following link to Your Data Rights –
https://www.selectabase.co.uk/your-data-rights/
For further information and details on how Experian obtains and utilises its
personal data for direct marketing purposes please visit the following link –
https://www.experian.co.uk/privacy/consumer-information-portal/
6. OUR USE OF AUTOMATED DECISION-MAKING AND PROFILING
We use automated profiling on or in relation to our website. We do not consider
that this has any legal effect on you or similarly significantly affects you. We
do not use automated decision-making.
You have the right to object to our use of automated profiling described in this
section. You can do that by opting out of cookies and similar technologies in
accordance with the method described in the relevant section below. If you do
not want us to process your actual IP address (usually the IP address assigned
to you by your Internet Service Provider) when you visit our website, you can
use a Virtual Private Network (VPN) or a free service such as Tor.
You can find out more about our use of cookies and similar technologies
(including the legal basis on which we use them) and how to opt out from them in
our cookies policy, which is available here:
https://www.selectabase.co.uk/cookies/
AUTOMATED PROFILING
Automated profiling is profiling carried out by a machine without significant
human involvement.
Use of automated profiling for web analytics: Our web analytics service, Google
Analytics uses collects information such as your location (based on your IP
address) and your behaviour (based on cookies) when you access our website (such
as the pages you visit and what you click on). We will only process information
from cookies if you have consented to us setting cookies on your computer in
accordance with our cookies policy https://www.selectabase.co.uk/cookies/).
Logic involved: by automatically analysing and categorising information such as
the location (based on IP address) as well as the behaviour and devices of
visitors to our website (using cookies), we are able to gain a better
understanding of what our website visitors want (in terms of the content of our
website and our products), how to improve our website and how to advertise and
market our services to them.
Significance and envisaged consequences: cookies will be used to track and store
information about your behaviour and device on our website (unless you have
opted out from receiving such cookies by rejecting cookie, more information
found on our cookies policy here: https://www.selectabase.co.uk/cookies/) and
your location will be analysed based on your IP address.
Legal basis for processing: consent (Article 6(1)(a) of the GDPR). Consent: you
give your consent to our use of Google Analytics by turning on Google Analytics
using our cookie control tool.
7. DISCLOSURE AND ADDITIONAL USES OF YOUR INFORMATION
This section sets out the circumstances in which will disclose information about
you to third parties and any additional purposes for which we use your
information.
Please note, this section describes ordinary disclosures to third party service
providers and legal reasons. For information about how we disclose information
to our clients which we have obtained about you from third party suppliers,
please see the section above entitled 5. Information obtained from third parties
for use in our direct marketing products and services.
Disclosure of your information to service providers and other third parties in
the ordinary course of business
Third party to whom your information is disclosed Legal basis for processing
Transfer and storage Regular Service Providers We use a number of third parties
to provide us with services which are necessary to run our business or to assist
us with running our business and who process your information for us on our
behalf. These include the following:
• Telephone provider (UK),
• Email provider (UK),
• Mailing house provider (UK),
• Mailing list provider (EEA),
• IT service provider (UK),
• Web developer (UK), and
• Hosting provider (UK)
Apart from our mailing list provider, which are located in the EEA, our service
providers are located in the United Kingdom.
Your information will be shared with these service providers where necessary to
provide you with the service you have requested, whether that is accessing our
website or ordering goods and services from us.
We do not display the identities of all of our service providers publicly by
name for security and competitive reasons. If you would like further information
about the identities of our service providers, however, please contact us
directly by email and we will provide you with such information where you have a
legitimate reason for requesting it (where we have shared your information with
such service providers, for example).
Legitimate interests (Article 6(1)(f) of the GDPR). Where we share your
information with these third parties in a context other than where is necessary
to perform a contract (or take steps at your request to do so), we will share
your information with such third parties in order to allow us to run and manage
our business efficiently.
Necessary to perform a contract and/or to take steps at your request prior to
entering into a contract (Article 6(1)(b) of the GDPR). We may need to share
information with our service providers to enable us to perform our obligations
under that contract or to take the steps you have requested before we enter into
a contract with you.
Our service providers are located in the United Kingdom.
Other third parties Google
Google collects information through our use of Google Analytics (respectively on
our website) on our website. Google uses this information, including IP
addresses and information from cookies, for a number of purposes, such as
improving its Google Analytics service. Information is shared with Google on an
aggregated and anonymised basis. To find out more about what information Google
collects, how it uses this information and how to control the information sent
to Google, please see the following page:
https://policies.google.com/technologies/partner-sites
You can opt out of Google Analytics in general by installing the browser plugin
here:
https://tools.google.com/dlpage/gaoptout/
Consent (Article 6(1)(a) of the GDPR). Information collected by Google Analytics
is stored outside the European Economic Area on Google’s servers in the USA.
For further information about the safeguards used when your information is
transferred outside the European Economic Area, see the section of this privacy
policy below entitled Transfers of your information outside the European
Economic Area.
Accountants
We share information with our accountants for tax purposes. For example, we
share invoices we issue and receive with our accountants for the purpose of
completing tax returns and our end of year accounts.
Legitimate interests (Article 6(1)(f) of the GDPR). We have a legitimate
interest in running and managing our business efficiently. Our accountants are
located in the United Kingdom. Business partners
Business partners are businesses we work with which provide goods and services
which are complementary to our own or which allow us to provide goods or
services which we could not provide on our own. We share information with our
business partners where you have requested services which they provide whether
independently from, or in connection with or own services.
Legitimate interests (Article 6(1)(f) of the GDPR). We have a legitimate
interest in running and managing our business efficiently. Our business partners
are located in the United Kingdom. Advisors
Occasionally, we obtain advice from advisors, such as accountants, financial
advisors, lawyer and public relations professionals. We will share your
information with these third parties only where it is necessary to enable these
third parties to be able to provide us with the relevant advice. Legitimate
interests (Article 6(1)(f) of the GDPR). We have a legitimate interest in
running and managing our business efficiently. Our advisors are located in the
United Kingdom. Affiliates
Affiliates are individuals or entities we work with to promote our business or
their own business by various means, including by advertising our services on
their websites, for example. Affiliates will share information with us and we
will share information with them where you have expressed an interest in our
products or services. Legitimate interests (Article 6(1)(f) of the GDPR). We
have a legitimate interest in running and managing our business efficiently. Our
affiliates are located in the United Kingdom. Insurers
We will share your information with our insurers where it is necessary to do so,
for example in relation to a claim or potential claim we receive or make or
under our general disclosure obligations under our insurance contract with them.
Legitimate interests
(Article 6(1)(f) of the GDPR). We have a legitimate interest in running and
managing our business efficiently. Our insurers are location in the United
Kingdom.
Disclosure of your information for legal reasons
Legal reason for disclosure Legal basis for processing Indicating possible
criminal acts or threats to public security to a competent authority
If we suspect that criminal or potential criminal conduct has been occurred, we
will in certain circumstances need to contact an appropriate authority, such as
the police. This could be the case, for instance, if we suspect that a fraud or
a cyber crime has been committed or if we receive threats or malicious
communications towards us or third parties.
We will generally only need to process your information for this purpose if you
were involved or affected by such an incident in some way.
Legitimate interests (Article 6(1)(f) of the GDPR). Preventing crime or
suspected criminal activity (such as fraud).
In connection with the enforcement or potential enforcement our legal rights
We will use your information in connection with the enforcement or potential
enforcement of our legal rights, including, for example, sharing information
with debt collection agencies if you do not pay amounts owed to us when you are
contractually obliged to do so. Our legal rights may be contractual (where we
have entered into a contract with you) or non-contractual (such as legal rights
that we have under copyright law or tort law).
Legitimate interests (Article 6(1)(f) of the GDPR). Enforcing our legal rights
and taking steps to enforce our legal rights. In connection with a legal or
potential legal dispute or proceedings
We may need to use your information if we are involved in a dispute with you or
a third party for example, either to resolve the dispute or as part of any
mediation, arbitration or court resolution or similar process.
Legitimate interests (Article 6(1)(f) of the GDPR). Resolving disputes and
potential disputes. For ongoing compliance with laws, regulations and other
legal requirements
We will use and process your information in order to comply with legal
obligations to which we are subject. For example, we may need to disclose your
information pursuant to a court order or subpoena if we receive one.
Compliance with a legal obligation (Article 6(1)(c) of the GDPR). Legal
obligations to disclose information which are part of the laws of England and
Wales, or if they have been integrated into the United Kingdom’s legal framework
(for example in the form of an international agreement which the United Kingdom
has signed).
Legitimate interests (Article 6(1)(f)). Where the legal obligations are part of
the laws of another country and have not been integrated into the United
Kingdom’s legal framework, we have a legitimate interest in complying with these
obligations.
8. HOW LONG WE RETAIN YOUR INFORMATION
This section sets out how long we retain your information. We have set out
specific retention periods where possible. Where that has not been possible, we
have set out the criteria we use to determine the retention period.
RETENTION PERIODS
Server log information: we retain information on our server logs for 52 days.
Order information: when you place an order for goods and services, we retain
that information for seven years following the date on which you placed your
order for tax purposes and to defend against legal claims.
Correspondence and enquiries: when you make an enquiry, or correspond with us
for any reason, whether by email, via post or by phone, we will retain your
information for as long as it takes to respond to and resolve your enquiry, and
then for 3 further years on our back-up servers after which point we will delete
your information.
E-Newsletter: we retain the information you used to sign up for our e-newsletter
for as long as you remain subscribed (i.e. you do not unsubscribe) or if we
decide to cancel our e-newsletter service, whichever comes earlier.
Purchased data: we retain this information for a maximum period of 30 months
after the date of purchase by one of our clients.
Account information: we retain your account information for as long as you have
an active account. We delete account information after 24 months of inactivity.
CRITERIA FOR DETERMINING RETENTION PERIODS
In any other circumstances, we will retain your information for no longer than
necessary, taking into account the following:
* the purpose(s) and use of your information both now and in the future (such
as whether it is necessary to continue to store that information in order to
continue to perform our obligations under a contract with you or to contact
you in the future);
* whether we have any legal obligation to continue to process your information
(such as any recordkeeping obligations imposed by relevant law or
regulation);
* whether we have any legal basis to continue to process your information (such
as your consent);
* how valuable your information is (both now and in the future);
* any relevant agreed industry practices on how long information should be
retained;
* the levels of risk, cost and liability involved with us continuing to hold
the information;
* how hard it is to ensure that the information can be kept up to date and
accurate; and
* any relevant surrounding circumstances (such as the nature and status of our
relationship with you)
9. HOW WE SECURE YOUR INFORMATION
We take appropriate technical and organisational measures to secure your
information and to protect it against unauthorised or unlawful use and
accidental loss or destruction, including (amongst others):
* only sharing and providing access to your information to the minimum extent
necessary, subject to confidentiality restrictions where appropriate, and on
an anonymised basis wherever appropriate;
* using secure servers and facilities to store your information;
* verifying the identity of any individual who requests access to information
prior to granting them access to information; and
* using Secure Sockets Layer (SSL) software to encrypt any information you
submit to us via any forms on our website
TRANSMISSION OF INFORMATION TO US BY EMAIL
Transmission of information over the internet is not entirely secure, and if you
submit any information to us over the internet (whether by email, via our
website or any other means), you do so entirely at your own risk.
We cannot be responsible for any costs, expenses, loss of profits, harm to
reputation, damages, liabilities or any other form of loss or damage suffered by
you as a result of your decision to transmit information to us by such means.
10. TRANSFERS OF YOUR INFORMATION OUTSIDE THE UK AND THE EUROPEAN ECONOMIC AREA
Your information will be transferred and stored outside the UK and the European
Economic Area (EEA) in the circumstances set out below.
We will also transfer your information outside the UK and the EEA or to an
international organisation in order to comply with legal obligations to which we
are subject (compliance with a court order, for example). Where we are required
to do so, we will ensure appropriate safeguards and protections are in place.
When data is transferred Country of
storage
Safeguard(s) used Payment processing
When you pay for goods and services in relation to our website, if you use Sage
Pay, Sage Pay may transfer information about your order and the processing of
your order outside the European Economic Area.
Various countries outside the UK and EEA. Appropriate safeguards will be put in
place. You can access Sage Pay’s privacy policy here. Google Analytics
Information collected by Google Analytics (your IP address and actions you take
in relation to our website) is transferred outside the
EEA and stored on Google’s servers. You can access Google’s privacy policy here.
USA. This country is not subject to an adequacy decision by the European
Commission. Google has self-certified its compliance with the EU-U.S. Privacy
Shield which is available here. The EU-U.S. Privacy Shield is an approved
certification mechanism under Article 42 of the GDPR, which is permitted under
Article 46(2)(f) of the GDPR. You can access the European Commission decision on
the adequacy of the EU-U.S. Privacy Shield here.
11. YOUR RIGHTS IN RELATION TO YOUR INFORMATION
Subject to certain limitations on certain rights, you have the following rights
in relation to your information, which you can exercise by writing to
Selectabase Limited, The Archive Centre, Honeywood Road, Dover, Kent, CT16 3EH,
sending an email to admin@selectabase.co.uk, or visiting the following link to
Your Data Rights – https://www.selectabase.co.uk/your-data-rights/:
* to request access to your information and information related to our use and
processing of your information;
* to request the correction or deletion of your information;
* to request that we restrict our use of your information;
* to receive information which you have provided to us in a structured,
commonly used and machine-readable format (e.g. a CSV file) and the right to
have that information transferred to another data controller (including a
third party data controller)
* to object to the processing of your information for certain purposes (for
further information, see the section below entitled Your right to object to
the processing of your information for certain purposes); and
* to withdraw your consent to our use of your information at any time where we
rely on your consent to use or process that information. Please note that if
you withdraw your consent, this will not affect the lawfulness of our use and
processing of your information on the basis of your consent before the point
in time when you withdraw your consent
In accordance with Article 77 of the GDPR, you also have the right to lodge a
complaint with a supervisory authority, in particular in the Member State of
your habitual residence, place of work or of an alleged infringement of the
GDPR.
For the purposes of the UK, the supervisory authority is the Information
Commissioner’s Office (ICO), the contact details of which are available here:
https://ico.org.uk/global/contact-us/.
Further information on your rights in relation to your personal data as an
individual.
The above rights are provided in summary form only and certain limitations apply
to many of these rights. For further information about your rights in relation
to your information, including any limitations which apply, please visit the
following pages on the ICO’s website:
* https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/
and
* https://ico.org.uk/your-data-matters/
You can also find out further information about your rights, as well as
information on any limitations which apply to those rights, by reading the
underlying legislation contained in Articles 12 to 22 and 34 of the GDPR, which
is available here:
https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32016R0679
Verifying your identity where you request access to your information.
Where you request access to your information, we are required by law to use all
reasonable measures to verify your identity before doing so.
These measures are designed to protect your information and to reduce the risk
of identity fraud, identity theft or general unauthorised access to your
information.
How we verify your identity.
Where we possess appropriate information about you on file, we will attempt to
verify your identity using that information.
If it is not possible to identity you from such information, or if we have
insufficient information about you, we may require original or certified copies
of certain documentation in order to be able to verify your identity before we
are able to provide you with access to your information.
We will be able to confirm the precise information we require to verify your
identity in your specific circumstances if and when you make such a request.
12. YOUR RIGHT TO OBJECT TO THE PROCESSING OF YOUR INFORMATION FOR CERTAIN
PURPOSES
You have the following rights in relation to your information, which you may
exercise in the same way as you may exercise by writing to Selectabase Limited,
The Archive Centre, Honeywood Road, Dover, Kent, CT16 3EH , sending an email to
admin@selectabase.co.uk, or visiting the following link to Your Data Rights –
https://www.selectabase.co.uk/your-data-rights/:
* to object to us using or processing your information where we use or process
it in order to carry out a task in the public interest or for our legitimate
interests, including ‘profiling’ (i.e. analysing or predicting your behaviour
based on your information) based on any of these purposes; and
* to object to us using or processing your information for direct marketing
purposes (including any profiling we engage in that is related to such direct
marketing)
You may also exercise your right to object to us using or processing your
information for direct marketing purposes by:
* clicking the unsubscribe link contained at the bottom of any marketing email
we send to you and following the instructions which appear in your browser
following your clicking on that link;
* sending an email to admin@selectabase.co.uk:, asking that we stop sending you
marketing communications or by including the words “OPT OUT”; or
* using our opt-out request form which is available here:
selectabase.co.uk/data-optout/
For more information on how to object to our use of information collected from
cookies and similar technologies, please see the section entitled How to accept
or reject cookies in our cookies policy, which is available here:
https://www.selectabase.co.uk/cookies/
13. SENSITIVE PERSONAL INFORMATION
‘Sensitive personal information’ is information about an individual that reveals
their racial or ethnic origin, political opinions, religious or philosophical
beliefs, or trade union membership, genetic information, biometric information
for the purpose of uniquely identifying an individual, information concerning
health or information concerning a natural person’s sex life or sexual
orientation.
We do not knowingly or intentionally collect sensitive personal information from
individuals, and you must not submit sensitive personal information to us.
If, however, you inadvertently or intentionally transmit sensitive personal
information to us, you will be considered to have explicitly consented to us
processing that sensitive personal information under Article 9(2)(a) of the
GDPR. We will use and process your sensitive personal information for the
purposes of deleting it.
14. CHANGES TO OUR PRIVACY POLICY
We update and amend our Privacy Policy from time to time.
Minor changes to our Privacy Policy.
Where we make minor changes to our Privacy Policy, we will update our Privacy
Policy with a new effective date stated at the beginning of it. Our processing
of your information will be governed by the practices set out in that new
version of the Privacy Policy from its effective date onwards.
Major changes to our Privacy Policy or the purposes for which we process your
information.
Where we make major changes to our Privacy Policy or intend to use your
information for a new purpose or a different purpose than the purposes for which
we originally collected it, we will notify you by email (where possible) or by
posting a notice on our website.
We will provide you with the information about the change in question and the
purpose and any other relevant information before we use your information for
that new purpose.
Wherever required, we will obtain your prior consent before using your
information for a purpose that is different from the purposes for which we
originally collected it.
15. CHILDREN’S PRIVACY
Because we care about the safety and privacy of children online, we comply with
the Children’s Online Privacy Protection Act of 1998 (COPPA). COPPA and its
accompanying regulations protect the privacy of children using the internet. We
do not knowingly contact or collect information from persons under the age of
18. The website is not intended to solicit information of any kind from persons
under the age of 18.
It is possible that we could receive information pertaining to persons under the
age of 18 by the fraud or deception of a third party. If we are notified of
this, as soon as we verify the information, we will, where required by law to do
so, immediately obtain the appropriate parental consent to use that information
or, if we are unable to obtain such parental consent, we will delete the
information from our servers. If you would like to notify us of our receipt of
information about persons under the age of 18, please do so by sending an email
to admin@selectabase.co.uk.
16. CALIFORNIA DO NOT TRACK DISCLOSURES
“Do Not Track” is a privacy preference that users can set in their web browsers.
When a user turns on a Do Not Track signal in their browser, the browser sends a
message to websites requesting that they do not track the user. For information
about Do Not Track, please visit https://allaboutdnt.com/.
At this time, we do not respond to Do Not Track browser settings or signals. In
addition, we use other technology that is standard to the internet, such as
cookies to track visitors to the website. Those tools may be used by us and by
third parties to collect information about you and your internet activity, even
if you have turned on the Do Not Track signal. For information on how to opt out
from tracking technologies used on our website, see our cookies policy which is
available here: https://www.selectabase.co.uk/cookies/
17. CCTV
We use CCTV on and around our premises for the prevention and detection of crime
and to safeguard our staff and visitors.
Legal basis for processing: Legitimate interests (Article 6(1)(f)) of the GDPR.
We have a legitimate interest in carrying out these activities.
CCTV footage is stored for 14 days on our secure servers in the UK.
18. COPYRIGHT
The copyright in this Privacy Policy is either owned by, or licensed to, us and
is protected by copyright laws around the world and copyright protection
software. All intellectual property rights in this document are reserved.
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Selectabase Ltd - The Archive Centre Honeywood Road, Dover, Kent, CT16 3EH -
Registered in the UK: 5234487 - VAT Number: GB-6738901 01
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