Privacy Policy

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This Privacy Policy sets out how we, Nutel Solutions Ltd, collect, store and use information about you when you use or interact with our website, www.FoneRepair.com and where we otherwise obtain or collect information about you. This Privacy Policy is effective from 5th May 2018.

Contents:

  1. Summary
  2. Our details
  3. Information we collect when you visit our website
  4. Information we collect when you contact us
  5. Information we collect when you interact with our website
  6. Information we collect when you place an order on our website
  7. Our use of automated decision-making and profiling
  8. How we collect or obtain information about you from third parties
  9. Disclosure and additional uses of your information
  10. How long we retain your information
  11. How we secure your information
  12. Transfers of your information outside the European Economic Area
  13. Your rights in relation to your information
  14. Your right to object to the processing of your information for certain purposes
  15. Sensitive Personal Information
  16. Changes to our Privacy Policy
  17. Children’s Privacy
  18. California Do Not Track Disclosures
  19. Copyright, credit and logo

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.

1.1 - Data controller: Nutel Solutions Ltd.

1.2 - How we collect or obtain information about you:

  • when you provide it to us e.g. by contacting us, by registering for an account on our website, by placing an order on our website and by agreeing to receive certain marketing information such as promotional e-mails or newsletters.
  • from your use of our website, using cookies
  • Occasionally from third parties when you submit reviews of our service(s).

1.3 - Information we collect: name, contact details, billing address, IP address, 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) date and time of first becoming our customer, order history, order returns history, last login time (if applicable), Skype Chat ID (if applicable), company name or business name (if applicable), Company Website Address, Company Registration Number (if applicable) VAT number (if applicable), Company Registration Certificate copy (if applicable).

1.4 - 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

1.5 - 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.

1.6 - Do we sell your information to third parties (other than in the course of a business sale or purchase or similar event): No

1.7 - 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). For specific retention periods in relation to certain information which we collect from you, please see the main section below entitled How long we retain your information.

1.8 - 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, and only granting access to your information where necessary.

1.10 - Transfers of your information outside the European Economic Area: In certain circumstances for marketing reasons and server infrastructure performance monitoring we may transfer your information outside of the European Economic Area, including to the United States of America. Where we do so, we will ensure appropriate safeguards are in place by ensuring that the third parties we use who transfer your information outside the European Economic Area have self-certified themselves as compliant with the EU-U.S. Privacy Shield. For more information, please see the main section below entitled Transfers of your information outside the European Economic Area.

1.11 - Use of automated decision making and profiling: We do not use automated decision making but do use profiling. This is achieved by the use of Google web analytics, cookies and web beacons contained within our e-newsletters.

1.12 - 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

1.13 - 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 Sensitive Personal Information.

 

2. Our details

The data controller in respect of our website is Nutel Solutions Ltd. company registration number: 5363457 of 162-168 High Street, Rayleigh, Essex SS6 7BS.

If you have any questions about this Privacy Policy, please contact the data controller.

 

3. Information we collect when you visit our website

We collect and use information from website visitors in accordance with this section and the section entitled Disclosure and additional uses of your information.

3.1 - Web server log information:

3.2 - Use of website server log information for IT security purposes:

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.

Legal basis for processing: compliance with a legal obligation to which we are subject (Article 6(1)(c) of the General Data Protection Regulation).

Legal obligation: 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.

Legal basis for processing: our and Amazon Web Services legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interests: we and Amazon Web Services have a legitimate interest in using your information for the purposes of ensuring network and information security.

3.3 - Use of website server log information to analyse website use and improve our website:

We use the information collected by our website server logs to analyse how our website users interact with our website and its features. For example, we analyse the number of visits and unique visitors we receive, the time and date of the visit, the location of the visit and the operating system and browser used.

We use the information gathered from the analysis of this information to improve our website. For example, we use the information gathered to change the information, content and structure of our website and individual pages based according to what users are engaging most with and the duration of time spent on particular pages on our website. We also use this information to plan for increases in the processing and storage capacity of our servers so that website performance is uncompromised.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest: improving our website for our website users and getting to know our website users’ preferences so our website can better meet their needs and desires.

3.4 Cookies:

Cookies are data files which are sent from a website to a browser to record information about users for various purposes.

 

4. 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 Disclosure and additional uses of your information.

4.1 - 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).

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: 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.

4.2 - Transfer and storage of your information

Emails you send us will be stored outside the European Economic Area on Google’s Gmail servers in the USA. For further information please see the section of this privacy policy entitled Transfers of your information outside the European Economic Area.

4.3 - Contact form:

When you contact us using our contact form, we collect your name, email address and IP address. We also collect any other information you provide to us when you complete the contact form, including any optional information such as phone number.

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.

If you do not supply the optional information required by our contact form we will not be able to respond to your enquiry by phone.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: 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.

4.4 - Transfer and storage of your information:

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.

4.5 - Phone:

When you contact us by phone, we collect your phone number and any information you provide to us during your conversation with us.

We do not record phone calls.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation)

Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: 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.

4.6 - Transfer and storage of your information:

Information about your phone call will be stored by our third party telephone service provider within the European Economic Area.

4.7 - Post:

If you contact us by post, we will collect any information you provide to us in any postal communications you send us.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation)

Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: 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.

 

5. Information we collect when you interact with our website:

We collect and use information from individuals who interact with particular features of our website in accordance with this section and the section entitled Disclosure and additional uses of your information.

5.1 - E-Newsletter / E-Mail Promotional Offers:

When you sign up for our e-newsletter on our website or opt to receive news, offers and promotional material from us by ticking an option box during customer account creation, we collect your name and email address to be added to our mailing list(s)

Legal basis for processing: your consent (Article 6(1)(a) of the General Data Protection Regulation).

Consent: you give your consent to us sending you our e-newsletter by signing up to receive it using the steps described above.

5.2 - Transfer and storage of your information:

Information you submit to subscribe for our e-newsletter will be stored outside the European Economic Area on our third party mailing list provider’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.

5.3 - Use of web beacons in emails:

We use technologies such as web beacons (small graphic files) in the emails we send to allow us to assess the level of engagement our emails receive by measuring information such as the delivery rates, open rates and click through rates which our emails achieve. We will only use web beacons in our emails if you have consented to us doing so.

5.4 - Registering on our website:

When you register and create an account on our website, we collect the following information: fullname, email address, billing address, shipping address, IP address, Company Name, phone number, company registration number, copy of company registration certificate, how you found us and any other information you provide to us when you complete the registration form, including any optional information, such as TAX/VAT number, Skype Address/I.D, Company website.

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.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest: registering and administering accounts on our website to retain order history and contact information to provide a more efficient customer experience and facilitate the running and operation of our business.

5.5 - Transfer and storage of your information:

 

6. Information we collect when you place an order on our website

We collect and use information from individuals who place an order on our website in accordance with this section and the section entitled Disclosure and additional uses of your information.

6.1- Information collected when you place an order:

6.1.1 - Mandatory information:

When you place an order for goods or services on our website, we collect your name, email address, billing address, shipping address, telephone number, company name (if applicable), VAT number (if applicable), Purchase Order Number, and third party successful payment transaction reference(s) (if applicable).

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.

Legal basis for processing: necessary to perform a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: 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.

Legal basis for processing: compliance with a legal obligation (Article 6(1)(c) of the General Data Protection Regulation).

Legal obligation: 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

6.1.2 - Optional information

We also collect optional information from you, such as a desired delivery date and purchase order number.

If you do not supply the optional information requested at checkout we will not be able to endeavour to expedite dispatch or delivery of your goods and/or provide invoices displaying a matching purchase order number.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interests: To improve business’ advertising methods and be able to contact the customer via e-mail to offer goods and services to maintain and/or increase sales and improve customer experience.

Legal basis for processing: your consent (Article 6(1)(a) of the General Data Protection Regulation).

Legitimate interests: you consent to us processing any optional information you provide by submitting that information to us.

6.2 - Processing your payment:

After you place an order on our website you will need to make payment for the goods or services you have ordered. In order to process your payment we use third party payment processors, including Sage Pay and Paypal. and also allow for direct bank transfer payment. Your payment will be processed by the third party payment processor you choose to process your payment via a payment gateway either through redirection to their website or by third party payment sections being embedded into our website checkout page. Direct bank transfer payment selections will not process any information and will simply display the full details to transfer the funds to us using your own bank. Bank transfer orders will not be processed until payment is cleared.

6.3 - Transfer and storage of your information:

Sagepay is located in the UK. Information relating to the processing of your payment is stored within the European Economic Area on our third party payment processor’s servers in Ireland.

Paypal is located in the USA. Information relating to the processing of your payment is stored outside the European Economic Area on our third party payment processor’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.

Legal basis for processing: necessary to perform a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: to fulfil your contractual obligation to pay for the goods or services you have ordered from us.

6.4 - Marketing communications:

At customer account registration you will have the option of receiving marketing communications from us. You also have the option to sign up to our newsletter by entering your e-mail and clicking subscribe on any page of our website.

6.5 - Our goods and services

You can opt in to receiving marketing communications from us in relation to our goods and services by ticking a box indicating you would like to receive such communications during customer account registration and/or by entering your e-mail into a subscription box located within the footer of any page on our website.

We will send you marketing communications in relation to our goods and services only if you opt-in to receive them.

Legal basis for processing: consent (Article 6(1)(a) of the General Data Protection Regulation).

Consent: you give your consent to us sending you information about our goods and services by signing up to receive such information in accordance with the steps described above.

6.6 - Transfer and storage of your information:

We use a third party service to administer our mailing list Mailchimp.

Information you submit to subscribe for our e-newsletter will be stored outside the European Economic Area on our third party mailing list provider’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.

Use of web beacons in emails

We use technologies such as web beacons (small graphic files) in the emails we send to allow us to assess the level of engagement our emails receive by measuring information such as the delivery rates, open rates and click through rates which our emails achieve. We will only use web beacons in our emails if you have consented to us doing so.

6.7 - Third party goods and services:

In addition to receiving information about our products and services you can opt in to receiving marketing communications from us in relation third party goods and services by ticking a box indicating you would like to receive such communications at checkout and/or by entering your e-mail into a subscription box located within the footer of any page on our website

Legal basis for processing: consent (Article 6(1)(a) of the General Data Protection Regulation).

Consent: you give your consent to us sending you information about third party goods and services by signing up to receive such information in accordance with the steps described above.

6.8 - Transfer and storage of your information

We use a third party service to administer our mailing list Mailchimp.

Information you submit to subscribe for our e-newsletter will be stored outside the European Economic Area on our third party mailing list provider’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.

 

7. Our use of automated decision-making and profiling

We use profiling on our website. We do not consider that this has any legal effect on you or similarly significantly affects you.

You have the right to object to our use of 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.

Use of profiling in marketing emails

Logic involved: by analysing how our email recipients respond to our emails, we are able to improve the content and effectiveness of our emails and gauge who is most interested.

Significance and envisaged consequences: your behaviour when you open our emails will be tracked using small gif files (web beacons), including open rates, and click through rates.

Legal basis for processing: legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest: Analysing the level of engagement and effectiveness of our marketing emails and content

 

8. How we collect or obtain information about you from third parties

This section sets out how we obtain or collect information about you from third parties.

8.1 - Information received from third parties:

Generally we do receive information about you from third parties. The third parties from which we receive information about you will generally include Ebay and Amazon.

It is also possible that third parties with whom we have had no prior contact may provide us with information about you.

Information we obtain from third parties will generally be your name and contact details, but will include any additional information about you which they provide to us.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: where a third party has passed on information about you to us (such as your name and email address) in order for us to provide services to you, we will process your information in order to take steps at your request to enter into a contract with you and perform a contract with you (as the case may be).

Legal basis for processing: consent (Article 6(1)(a) of the General Data Protection Regulation).

Consent: where you have asked that a third party to share information about you with us and the purpose of sharing that information is not related to the performance of a contract or services by us to you, we will process your information on the basis of your consent, which you give by asking the third party in question to pass on your information to us.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interests: where a third party has shared information about you with us and you have not consented to the sharing of that information, we will have a legitimate interest in processing that information in certain circumstances.

For example, we would have a legitimate interest in processing your information to perform our obligations under a sub-contract with the third party, where the third party has the main contract with you. Our legitimate interest is the performance of our obligations under our sub-contract.

Similarly, third parties may pass on information about you to us if you have infringed or potentially infringed any of our legal rights. In this case, we will have a legitimate interest in processing that information to investigate and pursue any such potential infringement.

Where we receive information about you in error

If we receive information about you from a third party in error and/or we do not have a legal basis for processing that information, we will delete your information.

8.2 - Information obtained by us from third parties:

In certain circumstances (for example, to verify the information we hold about you or obtain missing information we require to provide you with a service) we will obtain information about you from certain publicly accessible sources, both EU and non-EU, such as the electoral register, Companies House, the European Commission, online customer databases, business directories, media publications and websites (including your own website if you have one).

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: where you have entered into a contract or requested that we enter into a contract with you, in certain circumstances, we will obtain information about you from public sources in order to enable us to understand your business and provide services to you or services to a sufficient standard.

For example, we would obtain and/or verify your email address from your website or from a directory where you ask us to send you information by email but we do not possess the information or we need to confirm that we have recorded your email address correctly.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interests: in certain circumstances, we will have a legitimate interest in obtaining information about you from public and private sources. For example, if you have infringed or we suspect that you have infringed any of our legal rights, we will have a legitimate interest in obtaining and processing information about you from such sources in order to investigate and pursue any suspected or potential infringement.

Logic involved: automatically displaying advertisements to individuals who have visited our website results in increased efficiencies and costs savings for us than manually displaying advertisements or displaying advertisements by different means.

Significance and envisaged consequences: cookies will be used to recognise the fact that you have visited our website in order to display advertisements to you (unless you have blocked such cookies) and will collect information about your online behaviour.

 

9. 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.

9.1 - Disclosure of your information to 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, some of which who process your information for us on our behalf.
These include the following:

Apart from Google Mail, Mailchimp, Boostmyshop, M2Epro, IWD Agency, Amazon Web Services and Paypal which are located in USA, our service providers are located in England.

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.

Legal basis for processing: legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest relied on: 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.

Legal basis for processing: 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 General Data Protection Regulation).

Reason why necessary to perform a contract: 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.

9.2 - Disclosure of your information to other third parties

We disclose your information to other third parties in specific circumstances, as set out below.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

9.3 - Transfer and storage of your information:

Information collected by Google Analytics is stored outside the European Economic Area on Google’s servers in the United States of America.

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.

Sharing your information with third parties, which are either related to or associated with the running of our business, where it is necessary for us to do so. These third parties include our accountants, advisors and insurers. Further information on each of these third parties is set out below.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest: running and managing our business efficiently.

9.4 - 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.

9.5 - Advisors:

Occasionally, we obtain advice from advisors, such as lawyers. 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.

9.6 - 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.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest: running and managing our business effectively.

Sharing your information with a prospective or actual purchaser or seller in the context of a business or asset sale or acquisition by us, a merger or similar business combination event, whether actual or potential.

Legal basis for processing: legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest(s): sharing your information with a prospective purchaser, seller or similar person in order to allow such a transaction to take place.

9.7 - Disclosure and use of your information for legal reasons:

9.7.1 - 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 we 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.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interests: preventing crime or suspected criminal activity (such as fraud).

9.7.2 - 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).

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest: enforcing our legal rights and taking steps to enforce our legal rights.

9.7.3 - 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.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest(s): resolving disputes and potential disputes.

9.7.4 - 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 or to the National Crime Agency in connection with suspected or potential money laundering matters.

Legal basis for processing: compliance with a legal obligation (Article 6(1)(c) of the General Data Protection Regulation).

Legal obligation(s): 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).

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest: 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.

 

10. 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.

10.1 - Retention periods:

Server log information: we retain information on our server logs for [insert period for which you retain information from server logs.

Order information: when you place an order for goods and services, we retain that information for six years following the end of the financial year in which you placed your order, in accordance with our legal obligation to keep records for tax purposes.

Correspondence and enquiries: when you make an enquiry or correspond with us for any reason, whether by email or by phone, we will retain your information for as long as it takes to respond to and resolve your enquiry, and for 30 further days 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.

10.2 - 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 record-keeping 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).

 

11. 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:

  • 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 possible;
  • Using secure servers to store your information
  • Verifying the identity of any individual who requests access to information prior to granting them access to information;
  • Using Secure Sockets Layer (SSL) software to encrypt any information you submit to us via any forms on our website and any information passed to third party payment services you select via our website
  • Only transferring your information via closed system or encrypted data transfers

11.1 - 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.

 

12. Transfers of your information outside the European Economic Area

The vast majority of your information is processed and stored in the following European Economic Area (EEA) country: Ireland.

Other than to comply with any legal obligations to which we are subject (compliance with a court order, for example), we do not intend to transfer any of your information, other than is necessary for our e-newsletter(s) or e-mail processing, outside the EEA or to an international organisation. In the unlikely event that we are required to transfer your information outside the EEA (or to an international organisation) for such a purpose, we will ensure appropriate safeguards and protections are in place.

Your information may be transferred and stored outside the European Economic Area (EEA) in the circumstances set out below. We will also transfer your information outside 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.

12.1 - Email

Country of storage: USA. This country is not subject to an adequacy decision by the European Commission.

12.2 - E-Newsletter:

Country of storage: USA. This country is not subject to an adequacy decision by the European Commission.

12.3 - Google Analytics

Country of storage: USA. This country is not subject to an adequacy decision by the European Commission.

 

13. Your rights in relation to your information

  • 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.
  • the right not to be subject to a decision based solely on automated processing, including profiling which produces legal affects concerning you or similarly significantly affects you

In accordance with Article 77 of the General Data Protection Regulation, 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 General Data Protection Regulation.

13.1 - 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:

13.2 - 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.

13.3 - 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.

 

14. Your right to object to the processing of your information for certain purposes

  • 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; or
  • sending an email to sales@nutelsolutions.co.uk, asking that we stop sending you marketing communications or by including the words “OPT OUT”.

 

15. 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 General Data Protection Regulation. We will use and process your sensitive personal information for the purposes of deleting it.

 

16. Changes to our Privacy Policy

We update and amend our Privacy Policy from time to time.

16.1 - 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.

16.2 - 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.

 

17. 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.

 

18. California Do Not Track Disclosures

 

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.

Where we display the GDPR Privacy Policy logo on our website, this is used to indicate that we have adopted a privacy policy template provided by GDPR Privacy Policy as the basis for this Privacy Policy.

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