Under the new data protection law starting in May 2018 we have a number of lawful reasons that we can use (or ‘process’) your personal information, one of the lawful reasons is ‘legitimate interests’.
Broadly speaking Legitimate Interests means that we can process your personal information if we have a genuine and legitimate reason and we are not harming any of your rights and interests.
So, what does this mean? When you provide your personal details to us we use your information for our legitimate business interests to carry out our work of servicing businesses throughout our territory. Before doing this, though, we will also carefully consider and balance any potential impact on you and your rights.
Some typical examples of when we might use the approach are for preventing fraud, direct marketing, maintaining the security of our systems, data analytics, enhancing, modifying or improving our services, identifying usage trends and determining the effectiveness of our campaigns and sales.
We will process the personal information you have supplied to us to conduct and manage our business to enable us to give you the most appropriate marketing, information, service and products and provide the best and most secure experience. These are what we consider to be our ‘Legitimate Interests’.
The following are some examples of when and why we would use this approach in our work:
- Marketing: We will make best effort to ensure our marketing is tailored and relevant for you where-ever we deem you to be in the sales cycle.
- Process Orders: In order for us to process an order, payment has to be taken and contact information collected, such as name, address and telephone number, provided. Both the buyer and seller would need to record the transaction.
- Your best interest: Processing your information to protect you against fraud when communicating with us on our website, and to ensure our websites and systems are secure.
- Personalisation: Where the processing enables us to enhance, modify, personalise or otherwise improve our services/communications for the benefit of our customers and prospects.
- Analytics: To process your personal information for the purposes of customer analysis, assessment, profiling and marketing, on a personalised or aggregated basis, to help us with our activities and to provide you with the most relevant information if this does not harm any of your rights and interests.
- Research: To determine the effectiveness of promotional campaigns and advertising and to develop our products, services, systems and relationships with you.
- Due Diligence: We may need to conduct investigations on supporters, potential customers and business partners to determine if those companies and individuals have been involved or convicted of offences such as fraud, bribery and corruption.
We will also hold information about you so that we can respect your preferences for being contacted by us.
When we process your personal information for our legitimate interests, we will consider and balance any potential impact on you and your rights under data protection and any other relevant law. Our legitimate business interests do not automatically override your interests – we will not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
What personal information do we collect from the people that visit our website?
When registering on our site, as appropriate, you may be asked to enter your name, email address, phone number or other details to help you with your experience.
When do we collect information?
We collect information from you when you subscribe to a newsletter or enter information on our site.
How do we protect your information?
Our website is scanned on a regular basis for security holes and known vulnerabilities in order to make your visit to our site as safe as possible.
We use regular Malware Scanning.
Your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential.
We implement a variety of security measures when a user enters, submits, or accesses their information to maintain the safety of your personal information.
All transactions are processed through a gateway provider and are not stored or processed on our servers.
Do we use ‘cookies’?
- Compile aggregate data about site traffic and site interactions in order to offer better site experiences and tools in the future. We may also use trusted third-party services that track this information on our behalf.
You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser settings. Since browser is a little different, look at your browser’s Help Menu to learn the correct way to modify your cookies.
If you turn cookies off, It won’t affect the user’s experience .
We do not sell, trade, or otherwise transfer to outside parties your Personally Identifiable Information, unless it is in relation to fulfilling your order or regulated professional organisations.
Occasionally, at our discretion, we may include or offer third-party products or services on our website. These third-party sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.
Google’s advertising requirements can be summed up by Google’s Advertising Principles. They are put in place to provide a positive experience for users. https://support.google.com/adwordspolicy/answer/1316548?hl=en
We have implemented the following:
We, along with third-party vendors such as Google use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) or other third-party identifiers together to compile data regarding user interactions with ad impressions and other ad service functions as they relate to our website.
Users can set preferences for how Google advertises to you using the Google Ad Settings page. Alternatively, you can opt out by visiting the Network Advertising Initiative Opt Out page or by using the Google Analytics Opt Out Browser add on.
California Online Privacy Protection Act
According to CalOPPA, we agree to the following:
Users can visit our site anonymously.
Can change your personal information:
- By emailing us
- By calling us
How does our site handle Do Not Track signals?
We honour Do Not Track signals and Do Not Track, plant cookies, or use advertising when a Do Not Track (DNT) browser mechanism is in place.
Does our site allow third-party behavioral tracking?
It’s also important to note that we do not allow third-party behavioural tracking
COPPA (Children Online Privacy Protection Act)
When it comes to the collection of personal information from children under the age of 13 years old, the Children’s Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, United States’ consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children’s privacy and safety online.
We do not specifically market to children under the age of 13 years old.
Fair Information Practices
The Fair Information Practices Principles form the backbone of privacy law in the United States and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect personal information.
In order to be in line with Fair Information Practices we will take the following responsive action, should a data breach occur:
We will notify you via email
- Within 1 business day
We also agree to the Individual Redress Principle which requires that individuals have the right to legally pursue enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or government agencies to investigate and/or prosecute non-compliance by data processors.
CAN SPAM Act
The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.
We collect your email address in order to:
- Send information, respond to enquiries, and/or other requests or questions
- Process orders and to send information and updates pertaining to orders.
- Send you additional information related to your product and/or service
To be in accordance with CANSPAM, we agree to the following:
- Not use false or misleading subjects or email addresses.
- Identify the message as an advertisement in some reasonable way.
- Include the physical address of our business or site headquarters.
- Monitor third-party email marketing services for compliance, if one is used.
- Honour opt-out/unsubscribe requests quickly.
- Allow users to unsubscribe by using the link at the bottom of each email.
If at any time you would like to unsubscribe from receiving future emails, you can follow the instructions at the bottom of each email and we will promptly remove you from ALL correspondence.
3-4 St John’s Hill
Remember, you can change the way you hear from us or withdraw your permission for us to process your personal details at any time by using our contact form on the ‘Contact Us‘ page or by using our online Preference Centre.
Last Edited on 2018-05-08