We are committed to safeguarding the privacy of our customers and website visitors; this policy sets out how we will treat your personal information.
(1) Important Information and who we are
Purpose of this Privacy notice
This privacy notice aims to give you information on how Redfish Group Limited, collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter, purchase a product or service or take part in a competition.
This website is not intended for children and we do not knowingly collect data relating to children.
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.
Our full details are:
Full name of legal entity: Redfish Group Limited
Email address: email@example.com
Postal address: The Old Savings Bank, 26-28 Lairgate, Beverley, HU17 8EP
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 (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
(2) What information do we collect?
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, store and use the following kinds of personal information:
(a) Identify Data – includes first name, maiden name, last name, username or similar identifier, job position and company;
(b) Contact Data – includes email address, company address and telephone numbers;
(c) Usage Data – information about your computer and about your visits to and use of our website (including your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation);
(d) 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 to access this website;
(e) Profile Data – information that you provide to us for the purpose of registering your interest or signing up to email and/or postal communication with us;
(f) Marketing and Communications Data – information that you provide to us for the purpose of subscribing to our website services, email notifications and/or newsletters; and
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.
If you fail to provide personal data
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 this 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.
(3) How is your personal data collected?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- apply for our products;
- sign up for our newsletter on our website;
- sign up for a demo of our products and/or services on our website;
- request marketing to be sent to you;
- enter a competition, promotion or survey; or
- give us some feedback.
Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies to distinguish you from other users of our website. This enables us to deliver a good experience on the website and allow us to make improvements in the future. A cookie is a small piece of information sent to a web browser to a web server, enabling information from the browser to be collected by the server. To find out more about cookies, including what as been set and how to manage and delete them please www.allaboutcookies.org.
We also use Google Analytics cookies on our website. This cookie is specifically used to collect information on how visitors use our site. We use this information to understand how visitors are using the site in order to make improvements to the user experience. This information is collected in an anonymous form, including the number of visitors to our website, where visitors have come from and the pages viewed.
Most web browsers alow some control of most cookies through browser settings. Please see more on this or take a look at instructions on how to manage here www.allaboutcookies.org. It may be possible to set up your computer to reject cookies although, if implemented you may not be able to use certain features on our website. To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gooptout.Third parties or publicly available sources.
We may receive personal data about you from various third parties and public sources as set out below:
- Technical Data from the following parties:
- analytics providers such as Google based outside the EU;
- advertising networks such as Google Adwords and Linked In based outside the EU; and
- search information providers such as Linked In based outside the EU.
- Contact, Financial and Company Data from Experian Business Express based inside the EU.
- Identity and Contact Data from data brokers or aggregators such as Dun and Bradstreet, Intelligent and Blue Sheep based inside the EU.
- Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.
- Social network sites such as Linked In, Twitter and Facebook based outside of the EU.
(4) Using your personal information
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 we need to perform the contract we are about to enter into or have entered into with you.
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.
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. With respect to email, telephone and direct marketing communications we operate a principle of legitimate interest only contacting those individuals where we feel there is real and genuine relevance. You have the right to withdraw consent to marketing at any time by contacting us 0845 862 0416 or emailing firstname.lastname@example.org
Purposes for which we will use your personal data
We have set out below, in a table format, 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||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as a new customer||(a) Identity
|Performance of a contract with you|
|To process and/or deliver your product/services including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(e) Marketing and Communications
|(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
|To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey
(d) Marketing and Communications
|(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
|To enable you to partake in a prize draw, competition or complete a survey||(a) Identity
(e) Marketing and Communications
|(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
|To administer and protect our business (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity
|(a) 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)
(b) Necessary to comply with a legal obligation
|To deliver relevant marketing, website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||(a) Identity
(e) Marketing and Communications
|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)|
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences||(a) Technical
|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)|
|To make suggestions and recommendations to you about goods or services that may be of interest to you||(a) Identity
|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.
Marketing and promotional material from us
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 or received products and/or services from us or if you provided us with your details for our newsletter mailing list, in each case, you have not opted out of receiving that marketing.
We do not share any details with third parties.
You can ask us to stop sending you marketing messages at any time by contacting us at any time. Email email@example.com or call 0845 862 0416
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of [a product/service purchase, product/service experience or other transactions].
Change of purpose
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 get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. Email firstname.lastname@example.org or call 0845 862 0416.
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.
In addition, we may disclose your personal information:
(a) to the extent that we are required to do so by law;
(b) in connection with any ongoing or prospective legal proceedings;
(c) in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk);
(d) to the purchaser (or prospective purchaser) of any business or asset that we are (or are contemplating) selling; and
(e) to any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.
(6) International data transfers
In addition, personal information that you submit for publication on the website will be published on the Internet and may be available, via the Internet, around the world. We cannot prevent the use or misuse of such information by others.
By submitting your personal data to us you expressly agree to such transfer, processing and storage of personal information.
(7) Security of your personal information
We will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information.
We will store all the personal information you provide on our secure (password- and firewall-protected) servers.
You acknowledge that the transmission of information over the Internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
(8) Retention of your personal information
We will retain your personal information for one or more of the following reasons:
- For as long as you remain a client with us,
- For as long as you maintain consent to marketing, newsletters,
- In accordance with the licence of our products/services
- Until the time limit for any legal challenges to the supply of the products/services has expired,
- To comply with legal and regulatory requirements,
- For inclusion in analysis carried out by us with respect to our business
(9) Policy amendments
(10) Your rights
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 override 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.
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.
Processing of your instructions will be subject to the supply of appropriate evidence of your identity (for this purpose, we will usually accept the exact email address you used to register or to place an order with us, a government issued ID such as a photocopy of your passport or driving licence, etc certified by a solicitor or bank plus an original copy of a utility bill showing your current address).
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.
We may withhold processing a rights request where it is considered excessive to the extent permitted by law. We will not normally charge a fee for processing your instructions. 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 in these circumstances.
You may instruct us not to process your personal information for marketing purposes, by updating your consent details by sending an email to us or informing us in writing. In practice, you will have expressly agreed in advance to our use of your personal information for marketing purposes, and we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes, each time we contact you.
You have the right to lodge a complaint about the processing of your personal data to the Information Commissioner’s Office, details can be obtained at www.ico.org.uk or contact their helpline on 0303 123 1113.
(11) Updating information
Please let us know if the personal information that we hold about you needs to be corrected or updated.