W7 Privacy Policy
This document was last updated on 10th February 2019
W7 Ltd (Company number 4197362) respects your privacy and is committed to protecting your personal data. This privacy notice will inform you how we collect and process personal data, and tell you about your privacy rights.
It is important that you read this privacy notice together with any other privacy notice or fair processing 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.
We are the controller of your data and are responsible for it. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
We may also act as processor for your data on behalf of a controller, in which case we are not responsible for it but the same standards of privacy will apply.
Our services are not intended for children and we do not knowingly collect data relating to children.
Contacting Us & Complaints
We have appointed a data privacy manager. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us using these details:
Data Privacy Manager
W7 Limited
21 Brook Gardens
Emsworth
PO10 7JY
Or alternatively at: simon.baxter@w7ltd.com
You have the right to make a complaint at any time to the Information Commissioner’s Office (‘ICO’), the UK supervisory authority for data protection issues. The ICO’s website can be viewed at www.ico.org.uk. We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please always contact us in the first instance.
If we provide links to third-party websites, plug-ins and applications, during our relationship with you, that is not a representation that we control such third-party resources and we are not responsible for their privacy statements. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We encourage you to read the privacy notice of every website you visit.
Where we need to collect 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 such a 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. We accept no liability under contract if it cannot be performed due to your withholding of data from us.
Data We May Collect
Personal data means any information about an individual from which that individual can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
Contact Data includes billing address, delivery address, email address and telephone numbers.
Financial Data includes bank account and payment card details.
Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use.
Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
Usage Data includes information about how you use our products and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
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 Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal 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.
How We May Collect It
We use different methods to collect data from and about you including through:
Direct interactions. You may give us data by filling in enquiry forms or by corresponding with us by post, phone, email, in person or otherwise. This includes personal data you provide when you, for example:
Enquire or instruct us for our products or services;
Subscribe to our services or publications;
Request marketing materials to be sent to you;
Enter a competition, promotion or survey; or
Give us feedback.
Automated technologies or interactions. As you interact with our products, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies (please see our cookie policy below for further details on which cookies we may store.)
1. Cross site forgery protection cookie – This is an unobtrusive security cookie, and exempt from declaration
2. Session Cookie – This is an unobtrusive cookie, and exempt from declaration
3. Google Analytics Doubleclick request cookie – This forms part of the analytics tracking suite, this cookie is unobtrusive cookie, and exempt from declaration
4. Google analytics Tracking Cookie – This is a minimally-intrusive cookie, and doesn’t share any personal information. It is classified as a first-party anonymous cookieused only for analytical purposes.
Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources, for example:
Analytics and search information providers;
Advertising networks;
Providers of technical, payment and delivery services;
Data brokers or aggregators;
Companies House; and
The Electoral Register;
Other Data Controllers or Processors. When our client is a data controller or data processor of your data (and so we are a processor or sub-processor, respectively), we may be provided your data in order to fulfil our contract with our client. We do not take responsibility for the privacy standards of our client, but endeavour to ensure they meet with the legal minimum. In any event, our standards of privacy will apply to your data whether we have obtained information directly from you or from a controller client.
How We Use Your 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:
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.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. 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 best and most secure experience. 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. We do 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).
Where we need to comply with a legal or regulatory obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
We have set out below a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Purpose/Activity: To register you as a new customer
Type of data:
Identity
Contact
Lawful basis for processing including basis of legitimate interest:
Performance of a contract with you
Purpose/Activity: To process and deliver work including:
Managing payments, fees and charges
Collect and recover money owed to us
Type of data:
Identity
Contact
Financial
Transaction
Marketing and Communications
Lawful basis for processing including basis of legitimate interest:
Performance of a contract with you
Necessary for our legitimate interests (to recover debts due to us)
Purpose/Activity: To manage our relationship with you which will include:
Notifying you about changes to our terms or privacy policy
Asking you to leave a review or take a survey
Type of data:
Identity
Contact
Profile
Marketing and Communications
Lawful basis for processing including basis of legitimate interest:
Performance of a contract with you
Necessary to comply with a legal obligation
Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
Purpose/Activity: To enable you to partake in a prize draw, competition or complete a survey
Type of data:
Identity
Contact
Profile
Usage
Marketing and Communications
Lawful basis for processing including basis of legitimate interest:
Performance of a contract with you
Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
Purpose/Activity: To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
Type of data:
Identity
Contact
Technical
Lawful basis for processing including basis of legitimate interest:
Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
Necessary to comply with a legal obligation
Purpose/Activity: To measure or understand the effectiveness of the advertising we serve to you
Type of data:
Identity
Contact
Profile
Usage
Marketing and Communications
Technical
Lawful basis for processing including basis of legitimate interest: Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
Purpose/Activity: To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
Type of data:
Technical
Usage
Lawful basis for processing including basis of legitimate interest: Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
Purpose/Activity: To make suggestions and recommendations to you about goods or services that may be of interest to you
Type of data:
Identity
Contact
Technical
Usage
Profile
Lawful basis for processing including basis of legitimate interest: Necessary for our legitimate interests (to develop our products/services and grow our business)
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
We may use your Identity, Contact, Technical, Usage and Profile 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 (we call this marketing).
You will receive marketing communications from us if you have requested information from us, purchased goods or services from us, or if you provided us with your details when you entered a competition or registered for a promotion; and, in each case, you have not opted out of receiving that marketing.
We will secure your express opt-in consent before we share your personal data with any company for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by checking or unchecking relevant boxes to adjust your marketing preferences, or by following the opt-out links on any marketing message sent to you, or by contacting us 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 your having purchased a service or product from us.
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to receive an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Sharing Your Data
We may have to share your personal data with the parties set out below for the purposes set out in the table above.
Service providers acting as processors based in the United Kingdom who provide IT and system administration services.
Professional advisers acting as processors including lawyers, bankers, auditors and insurers based in the United Kingdom, who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue & Customs, regulators and other authorities acting as processors based in the United Kingdom who require reporting of processing activities in certain circumstances.
Third-party email marketing providers such as Dotdigital (only where campaigns have been requested)
GDPR compliant third party cloud storage providers such as Dropbox
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Once it is within our control, we do not transfer your personal data outside the European Economic Area (‘EEA’), unless you (or the third party controller or processor which is instructing us and to which you have given your data which we are then processing) are based outside the EEA.
Data Security & Retention
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. As above, 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 and contractual legal limitation purposes.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Your Legal Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which overrides your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights above). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request under such circumstances.
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 hasten our response.
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.