Gardsec Ltd.
Privacy Policy
Last updated May 2018
We are committed to safeguarding the privacy of our website visitors and forum users. This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and forum users; in other words, where we determine the purposes and means of the processing of that personal data. We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website and forum, we will ask you to consent to our use of cookies when you first visit our website. In this policy, “we”, “us” and “our” refer to Gardsec Ltd.
1. How we use your personal data
In this Section we have set out:
(a) the general categories of personal data that we may process;
(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
(c) the purposes for which we may process personal data; and
(d) the legal bases of the processing.
1.1 We may process data about your use of our website and forum. The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.
1.2 We may process your account data. The account data may include your name and email address. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-‐ ups of our databases and communicating with you. The legal basis for this processing is the proper administration of our website and business.
1.3 We may process your information included in your personal profile on our forums. The profile data may include your name, address, telephone number, email address, profile pictures, gender, date of birth, relationship status, interests and hobbies, educational details and employment details. The profile data may be processed for our legitimate interests, namely the proper administration of our website and business.
1.4 We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website and forum. The transaction data may include your contact details, your card details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis 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 and our legitimate interests, namely the proper administration of our website and business.
1.5 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters. The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is at your request, to enter into such a contract.
1.6 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-‐of-‐court procedure. The legal basis for this processing is our legitimate interests, namely [the protection and assertion of our legal rights, your legal rights and the legal rights of others.
2. Data Handling
2.1 We may disclose your personal data to any member of our group of companies this means our subsidiaries, our ultimate holding company and all its subsidiaries insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.
2.2 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-‐of-‐court procedure.
2.3 We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.
2.4 We will store all your personal data on secure servers, personal computers and mobile devices, and in secure manual record-‐keeping systems.
2.5 The following personal data will be stored by us in encrypted form: your name, contact information, password(s) and cardholder data.
2.6 Data relating to your enquiries and financial transactions that is sent from your web browser to our web server, or from our web server to your web browser, will be protected using encryption technology.
2.7 You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
3. International transfers of your personal data
3.1 In this Section we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).
3.2 The hosting facilities for our website are situated in England. The European Commission has made an “adequacy decision” with respect to the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission.
3.3 You acknowledge that personal data that you submit for publication through our website or forum may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
4. Retaining and deleting personal data
4.1 This Section sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
4.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
4.3 In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria: We keep records of your communications with us for five years in case we have
to refer to a conversation or enquiry. This could be because it relates to our legitimate business interests; you are still in communication with us,
or for legal reasons. We keep your contact information on any mailing lists you chose to join unless you tell us otherwise. If you haven’t opened one
of our emails for some time, we may contact you to ask if you still want to hear from us. If you unsubscribe from a mailing list, we retain some basic information to ensure we don’t contact you again in the future.
5. Amendments
5.1 We may update this policy from time to time by publishing a new version on our website.
5.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
5.3 We may notify you of significant changes to this policy by email or through the private messaging system on our website.
6. Your rights
6.1 Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
6.2 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data.
6.3 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
6.4 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-‐based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure.
6.5 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party.
6.6 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
6.7 To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-‐readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
6.8 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
6.9 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
6.10 You may exercise any of your rights in relation to your personal data by emailing us directly.
7. Third party websites
7.1 Our website includes hyperlinks to, and details of, third party websites.
7.2 We have no control over, and are not responsible for, the privacy policies and practices of third parties.
8. Personal data of children
8.1 Our website and services are targeted at persons over the age of 13.
8.2 If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data
9. About cookies
9.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
9.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by
the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
9.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
10. Cookies that we use
10.1 We use cookies for the following purposes:
(a) authentication – we use cookies to identify you when you visit our website and as you navigate our website
(b) status – we use cookies to help us to determine if you are logged into our website
(c) personalisation – we use cookies to store information about your preferences and to personalise our website for you
(d) security – we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally
(e) analysis – we use cookies to help us to analyse the use and performance of our website and services
(f) cookie consent – we use cookies to store your preferences in relation to the use of cookies more generally
11. Our details
11.1 This website is owned and operated by Gardsec Ltd.
11.2 We are registered in England and Wales under registration number 06122746 and our registered office is:
Avondale House, 262 Uxbridge, Road, Hatch End, Middlesex, HA5 4HS
11.3 Our principal place of business is available upon request.
11.4 You can contact us:
(a) by email admin@gardsec.co.uk
