Privacy NoticeThis is the privacy notice of ISM TECH LTD. In this document, "we", "our", or "us"refer to ISM TECH LTD
We are company number 08110810 registered in UK.

Introduction
1.

This is a notice to inform you of our policy about all information that we record
about you. It sets out the conditions under which we may process any
information that we collect from you, or that you provide to us. It covers
information that could identify you (“personal information”) and informationthat could not. In the context of the law and this notice, “process” means
collect, store, transfer, use or otherwise act on information.

2.

We regret that if there are one or more points below with which you are nothappy, your only recourse is to leave our website or software immediately.

3.

We take seriously the protection of your privacy and confidentiality. We
understand that all visitors to our website are entitled to know that theirpersonal data will not be used for any purpose unintended by them, and will
not accidentally fall into the hands of a third party.

4.

We undertake to preserve the confidentiality of all information you provide tous, and hope that you reciprocate.

5.

Our policy complies with UK law accordingly implemented, including that
required by the EU General Data Protection Regulation (GDPR).

6.

The law requires us to tell you about your rights and our obligations to you in
regards to the processing and control of your personal data. We do this now,by requesting that you read the information provided atwww.knowyourprivacyrights.org

7.

Except as set out below, we do not share, or sell, or disclose to a third party,
any information collected through our website or software.

The bases on which we process information about you
The law requires us to determine under which of six defined bases weprocess different categories of your personal information, and to notify you ofthe basis for each category.
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If a basis on which we process your personal information is no longer relevant
then we shall immediately stop processing your data.
If the basis changes then if required by law we shall notify you of the change
and of any new basis under which we have determined that we can continue
to process your information.

1.

Information we process because we have acontractual obligation with you
When you create an account on our website or software, buy a product orservice from us, or otherwise agree to our terms and conditions, a contract isformed between you and us.
In order to carry out our obligations under that contract we must process theinformation you give us. Some of this information may be personal
information.
We may use it in order to:
1.1.

verify your identity for security purposes

1.2.

sell products to you

1.3.

provide you with our services

1.4.

provide you with suggestions and advice on products, services andhow to obtain the most from using our website

We process this information on the basis there is a contract between us, orthat you have requested we use the information before we enter into a legal
contract.
Additionally, we may aggregate this information in a general way and use it toprovide class information, for example to monitor our performance withrespect to a particular service we provide. If we use it for this purpose, you as
an individual will not be personally identifiable.
We shall continue to process this information until the contract between us
ends or is terminated by either party under the terms of the contract.

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2.

Information we process with your consent
Through certain actions when otherwise there is no contractual relationshipbetween us, such as when you browse our website or use our software or ask
us to provide you more information about our business, including our products
and services, you provide your consent to us to process information that may
be personal information.
Wherever possible, we aim to obtain your explicit consent to process thisinformation, for example, by asking you to agree to our use of cookies.
Sometimes you might give your consent implicitly, such as when you send us
a message by e-mail to which you would reasonably expect us to reply.
Except where you have consented to our use of your information for a specificpurpose, we do not use your information in any way that would identify you
personally. We may aggregate it in a general way and use it to provide class
information, for example to monitor the performance of a particular page on
our website.
If you have given us explicit permission to do so, we may from time to time
pass your name and contact information to selected associates whom weconsider may provide services or products you would find useful.
We continue to process your information on this basis until you withdraw yourconsent or it can be reasonably assumed that your consent no longer exists.
You may withdraw your consent at any time by instructing us
support@intellectsystems.co.uk. However, if you do so, you may not be able
to use our website,software or our services further.

3.

Information we process for the purposes of legitimate
interests
We may process information on the basis there is a legitimate interest, either
to you or to us, of doing so.
Where we process your information on this basis, we do after having given
careful consideration to:whether the same objective could be achieved through other meanswhether processing (or not processing) might cause you harm3

© Andrew Taylor and Net Lawman Ltdwhether you would expect us to process your data, and whether you
would, in the round, consider it reasonable to do so

For example, we may process your data on this basis for the purposes of:4.

record-keeping for the proper and necessary administration of ourbusiness

responding to unsolicited communication from you to which we believe
you would expect a response

protecting and asserting the legal rights of any party

insuring against or obtaining professional advice that is required to
manage business risk

protecting your interests where we believe we have a duty to do soInformation we process because we have a legal
obligation
We are subject to the law like everyone else. Sometimes, we must process
your information in order to comply with a statutory obligation.
For example, we may be required to give information to legal authorities ifthey so request or if they have the proper authorisation such as a search
warrant or court order.
This may include your personal information.

Specific uses of information you provide to us
5.

Information provided on the understanding that it will
be shared with a third party
Our website or software allows you to post information with a view to that
information being read, copied, downloaded, or used by other people.
Examples include:
5.1.

posting a message our forum4© Andrew Taylor and Net Lawman Ltd

5.2.

tagging an image

5.3.

clicking on an icon next to another visitor’s message to convey youragreement, disagreement or thanks

In posting personal information, it is up to you to satisfy yourself about theprivacy level of every person who might use it.
We do store it, and we reserve a right to use it in the future in any way we
decide.
Once your information enters the public domain, we have no control over what
any individual third party may do with it. We accept no responsibility for theiractions at any time.
Provided your request is reasonable and there is no legal basis for us to retain
it, then at our discretion we may agree to your request to delete personal
information that you have posted. You can make a request by contacting us at
support@intellectsystems.co.uk

6.

Complaints regarding content on our website orsoftwareOur website and software is a publishing medium. Anyone may register andthen publish information about himself, herself or some other person.
We do not moderate or control what is posted.
If you complain about any of the content on our website or software, we shallinvestigate your complaint.
If we feel it is justified or if we believe the law requires us to do so, we shallremove the content while we investigate.
Free speech is a fundamental right, so we have to make a judgment as towhose right will be obstructed: yours, or that of the person who posted thecontent that offends you.
If we think your complaint is vexatious or without any basis, we shall notcorrespond with you about it.

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7.

Information relating to your method of payment
Payment information is never taken by us or transferred to us either throughour website or otherwise. Our employees and contractors never have accessto it.
At the point of payment, you are transferred to a secure page on the websiteof our provider or some other reputable payment service provider. That page
may be branded to look like a page on our website, but it is not controlled byus.

8.

Information about your direct debit
When you agree to set up a direct debit arrangement, the information you give
to us is passed to our own banking provider for processing according to our
instructions. We do not keep a copy.

9.

Job application and employment
If you send us information in connection with a job application, we may keep it
for up to three years in case we decide to contact you at a later date.
If we employ you, we collect information about you and your work from time totime throughout the period of your employment. This information will be used
only for purposes directly relevant to your employment. After youremployment has ended, we will keep your file for six years before destroying
or deleting it.

10. Sending a message to our support team
When you contact us, whether by telephone, through our website or by e-mail,we collect the data you have given to us in order to reply with the information
you need.
We record your request and our reply in order to increase the efficiency of ourbusiness.
We keep personally identifiable information associated with your message,
such as your name and email address so as to be able to track ourcommunications with you to provide a high quality service.

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11. Complaining
When we receive a complaint, we record all the information you have given tous.
We use that information to resolve your complaint.
If your complaint reasonably requires us to contact some other person, we
may decide to give to that other person some of the information contained inyour complaint. We do this as infrequently as possible, but it is a matter forour sole discretion as to whether we do give information, and if we do, whatthat information is.
We may also compile statistics showing information obtained from this source
to assess the level of service we provide, but not in a way that could identify
you or any other person.

12. Affiliate and business partner information
This is information given to us by you in your capacity as an affiliate of us or
as a business partner.
It allows us to recognise visitors that you have referred to us, and to credit to
you commission due for such referrals. It also includes information that allows
us to transfer commission to you.
The information is not used for any other purpose.
We undertake to preserve the confidentiality of the information and of theterms of our relationship.
We expect any affiliate or partner to agree to reciprocate this policy.

Use of information we collect through automated systems
when you visit our website or use our software
13. Cookies
Cookies are small text files that are placed on your computer's hard drive by
your web browser when you visit any website. They allow information
gathered on one web page to be stored until it is needed for use on another,7© Andrew Taylor and Net Lawman Ltdallowing a website to provide you with a personalised experience and thewebsite owner with statistics about how you use the website so that it can be
improved.
Some cookies may last for a defined period of time, such as one day or until
you close your browser. Others last indefinitely.
Your web browser should allow you to delete any you choose. It also should
allow you to prevent or limit their use.
Our website uses cookies. They are placed by software that operates on ourservers, and by software operated by third parties whose services we use.
When you first visit our website, we ask you whether you wish us to use
cookies. If you choose not to accept them, we shall not use them for your visit
except to record that you have not consented to their use for any otherpurpose.
If you choose not to use cookies or you prevent their use through yourbrowser settings, you will not be able to use all the functionality of our
website.
We use cookies in the following ways:
13.1. to track how you use our website
13.2. to record whether you have seen specific messages we display on our
website13.3. to keep you signed in our site
13.4. to record your answers to surveys and questionnaires on our site while
you complete them
13.5. to record the conversation thread during a live chat with our support
team[We provide more information about the cookies we use in our cookie policy].

14. Personal identifiers from your browsing activity orsoftware usage
Requests by your web browser or software to our servers for web pages ordata and other content on our website or software are recorded.

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We may record information such as your geographical location, your Internet
service provider and your IP address. We also record information about thesoftware you are using to browse our website, such as the type of computeror device and the screen resolution.
We use this information in aggregate to assess the popularity of the
webpages on our website and how we perform in providing content to you.
If combined with other information we know about you from previous visits,
the data possibly could be used to identify you personally, even if you are notsigned in to our website.

15. Our use of re-marketing
Re-marketing involves placing a cookie on your computer when you browse
our website in order to be able to serve to you an advert for our products orservices when you visit some other website.
We may use a third party to provide us with re-marketing services from time totime. If so, then if you have consented to our use of cookies, you may see
advertisements for our products and services on other websites.

Disclosure and sharing of your information
16. Information we obtain from third parties
Although we do not disclose your personal information to any third party(except as set out in this notice), we sometimes receive data that is indirectly
made up from your personal information from third parties whose services weuse.
No such information is personally identifiable to you.

17. Third party advertising on our website or software
Third parties may advertise on our website or software. In doing so, thoseparties, their agents or other companies working for them may use technologythat automatically collects information about you when their advertisement isdisplayed on our website or software.
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They may also use other technology such as cookies or JavaScript topersonalise the content of, and to measure the performance of their adverts.
We do not have control over these technologies or the data that these parties
obtain. Accordingly, this privacy notice does not cover the information
practices of these third parties.

18. Credit reference
To assist in combating fraud, we share information with credit reference
agencies, so far as it relates to clients or customers who instruct their credit
card issuer to cancel payment to us without having first provided an
acceptable reason to us and given us the opportunity to refund their money.

19. Data may be processed outside the European Union
Our websites are hosted in UK.
We may also use outsourced services in countries outside the European
Union from time to time in other aspects of our business.
Accordingly data obtained within the UK or any other country could beprocessed outside the European Union.
For example, some of the software our website uses may have beendeveloped in the United States of America or in Australia.
We use the following safeguards with respect to data transferred outside theEuropean Union:
19.1. the processor is within the same corporate group as our business ororganisation and abides by the same binding corporate rules regarding
data processing.
19.2. the data protection clauses in our contracts with data processors
include transfer clauses written by or approved by a supervisory
authority in the European Union [, specifically that in the country of …]
19.3. we comply with a code of conduct approved by a supervisory authority
in the European Union [, specifically that in the country of …]
19.4. we are certified under an approved certification mechanism asprovided for in the GDPR
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19.5. both our organisation and the processor are public authorities between
whom there is either a legally binding agreement or administrative
arrangements approved by a supervisory authority in the European
Union relating to protection of your information

Access to your own information
20. Access to your personal information
20.1. At any time you may review or update personally identifiable
information that we hold about you, by signing in to your account on
our website or software.
20.2. To obtain a copy of any information that is not provided on our website
you may send us a request at support@intellectsystems.co.uk.
20.3. After receiving the request, we will tell you when we expect to provide
you with the information, and whether we require any fee for providing
it to you.

21. Removal of your information
If you wish us to remove personally identifiable information from our website,
you may contact us at support@intellectsystems.co.uk
This may limit the service we can provide to you.

22. Verification of your information
When we receive any request to access, edit or delete personal identifiable
information we shall first take reasonable steps to verify your identity before
granting you access or otherwise taking any action. This is important tosafeguard your information.

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Other matters
23. Use of site by children
23.1. We do not sell products or provide services for purchase by children,nor do we market to children.
23.2. If you are under 18, you may use our website or software only withconsent from a parent or guardian

24. Encryption of data sent between us
We use Secure Sockets Layer (SSL) certificates to verify our identity to yourbrowser and to encrypt any data you give us.

25. How you can complain
25.1. If you are not happy with our privacy policy or if have any complaint
then you should tell us by email. Our address is
support@intellectsystems.co.uk
25.2. You can get further information about our complaint handlingprocedures by emailing us on support@intellectsystems.co.uk
25.3. If a dispute is not settled then we hope you will agree to attempt toresolve it by engaging in good faith with us in a process of mediation or
arbitration.
25.4. If you are in any way dissatisfied about how we process your personal
information, you have a right to lodge a complaint with the Information
Commissioner's Office. This can be done at https://ico.org.uk/concerns/

26. Retention period for personal data
Except as otherwise mentioned in this privacy notice, we keep your personal
information only for as long as required by us:
26.1. to provide you with the services you have requested;

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26.2. to comply with other law, including for the period demanded by our tax
authorities;
26.3. to support a claim or defence in court.

27. Compliance with the law
Our privacy policy has been compiled so as to comply with the law of every
country or legal jurisdiction in which we aim to do business. If you think it fails
to satisfy the law of your jurisdiction, we should like to hear from you.
However, ultimately it is your choice as to whether you wish to use our
website or software.

28. Review of this privacy policy
We may update this privacy notice from time to time as necessary. The terms
that apply to you are those posted here. We advise you to print a copy foryour records.
If you have any question regarding our privacy policy, please contact us.

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Explanatory notes
Privacy policy notice

General notes
The EU Data Protection Directive (95/46/EC), implemented as the General Data
Protection Regulation, or the GDPR, comes into force from May 2018.
In the UK, the Data Protection Bill enshrines the law in the GDPR, making it
applicable even after the UK leaves the European Union.
The requirements under the new law are similar in extent to existing data protection
law in the UK. If your business complies with existing law, then the changes youneed to make are likely to be small.
The possible implications for non-compliance are now much more severe. In theory,
the Information Commissioner’s Office (the ICO) has the power to fine a business
4% of its annual worldwide turnover.
However, as with other EU law regarding selling to consumers we believe that the
ICO in practice is unlikely to fine many small businesses and organisations without
having first given a warning. Having a privacy notice (such as one based on thistemplate) that shows some effort to comply with the law is likely, in our opinion, togenerate enough goodwill with the ICO to avoid a fine in the first instance.
Updating your website privacy notice is not the only requirement for compliance with
the GDPR. You are also likely to need to change how customers and visitors canaccess personal data held about them, and create new procedures for obtaining
compliance to collect and use personal data.
You may also need to update other legal documents, in particular, your website
terms and conditions. Free versions of these are also available from our website.
More information can be found at: https://www.netlawman.co.uk/ia/gdpr
Using this template as the basis for your privacy noticeYour privacy policy should be concise (while also being comprehensive),transparent, easy to understand and easily accessible.
We aim to balance those qualities in this document. However, we cannot know
exactly how your business works, so you may need to edit the document significantly
in certain places.
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We offer this template free as an example of a Net Lawman document. We hope thatyou like it, and that you may buy other documents and services from us in the future.
Regardless of the price, we assert our copyright in the document. Our standard
licence terms apply. While you may not distribute the template without including our
copyright, you may remove our copyright notice from the version you edit and use.
In addition to these paragraph specific guidance notes to help you edit the template,
we also publish a free, more general guide to editing our legal documents, which you
can download at: https://www.netlawman.co.uk/uploads/Editing Legal Document
Templates.pdf
If you have any questions, please contact us at support@netlawman.co.uk

Paragraph specific notes
Numbered notes refer to specific numbered paragraphs in the template.
Identification of the owner of the website
The GDPR requires that you identify the business or the organisation that operates
the website. Using the domain name as the business name is not enough. You needto provide a business or organisation name and an address.
In practice, you may decide that you do not want to provide your name and address(for your own privacy reasons). You may be more likely to get away with doing this if
you don’t trade from your website.
If you have appointed a data protection officer, you should name that person here
using words such as “Our Data Protection Officer is [Name]”. Most businesses ororganisations that use this template will not be large enough to require one.
Introduction
Leave these items in place unless there is a good reason to edit or remove. Each ofthese items has been carefully considered in the context of this document and has
been included for a purpose.
1.

This paragraph sets out the purpose of the document and explains terms
used throughout it.

2.

If a visitor is not happy with your privacy policy, there is little he or she can do
except leave your website. This paragraph reminds him or her of thatrecourse.

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3.

This is a statement of intent, designed to reassure visitors, but also any
regulator.

4.

As above.

5.

This statement demonstrates awareness of the GDPR and compliance. It
should also reassure visitors.

6.

A key requirement of the law is that you tell your visitors and customers thatthey have rights with respect to how their personal information is processed.
Rather than cluttering your privacy notice with an explanation of the law, we
recommend referring your visitors to this explanatory website.

7.

A statement designed to reassure site visitors.

The bases on which we process information about you
A requirement of the GDPR is that you tell the data subject why you process
the data and which legal basis you have chosen to use as the justification toprocess his or her data.
Most websites will process different types of data on different bases. The twomost likely to apply are “Contract” (after the visitor has accepted your terms
and conditions) and “Consent” (after the visitor has agreed to your use of hisor her data – usually by taking some affirmative action such as clicking on abutton). Some data may also be processed because of a legal requirement ora legitimate interest.
All the bases are described at:
http://www.knowyourprivacyrights.org/legitimate-uses/
The reasons why you process the data arise as a result of the basis. If there isa contract, there is a contractual obligation to carry out the service. If the basis
is consent, then there will probably be some benefit to the data subject of you
using the information.
You may want to edit these sections in minor ways (certainly where we havehighlighted in blue).
More importantly, you should make design changes to how your website
works so as to obtain explicit consent, or have a visitor agree to your terms
earlier in your relationship.
For most websites, contract is the strongest basis for processing. If you candesign your website experience such that a visitor agrees to your terms earlyon, before providing personal information, you will have fewer grounds forcomplaints. For example, you might reduce the requirement to provide
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detailed information when a visitor registers a basic account on your website,
but place more content or functionality in an area of the website that requires
the visitor to have such an account. At the registration point, the visitor musttick a box to say that he or she has read and agrees to your terms andconditions.
If you are relying on consent, then you might design a banner to appear whena visitor first arrives at your site (for example, encouraging him or her to readyour cookies policy). That banner might have two buttons – one that gives
explicit agreement and one that doesn’t. If the visitor does not give explicit
consent, then you redirect him or her to another “safe” website or state thatcertain functionality will be limited.
Positive action needs to be taken by the visitor when agreeing to anything –pre-ticked boxes or close buttons don’t count as affirmative action.
Legitimate Interests is a basis that is fairly subjective. For it to be used, youmust have decided that there is a legitimate interest, that processing the datais necessary to protect that interest, and that the data subject’s interests (orother interests) do not override it. In some circumstances, it is mostappropriate, but if possible, we would recommend using Contract or Consent
as better alternatives. The reason is simply that the data subject is less likely
to complain if he or she has clearly asked you to process his or her data.
Data subjects have a legal right to see the personal information you holdabout them. You need both an internal process as to how to provide this, anda means for the data subject to request the information.
If the data subject is a registered visitor, then providing his or her data in an
account area is a good way of providing this data. You can also provide a wayof giving consent to use of the data in the same place.
If the data subject does not have an account, then you should give either an
e-mail address or a physical address to which the data subject can send arequest for his or her information.
Lastly, for each basis you need to state when you stop processing the data.
We suggest that you don’t edit our text.
Specific uses of information you provide to us
This section provides more information about specific types of information.
The paragraphs within it are as much designed to reassure a visitor reading
your policy than to aid compliance with the law.

17

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5Information provided on the understanding that it will be shared with athird party
This paragraph serves as a reminder that information that a visitor posts on
your website may be available for public viewing, and that you cannot be held
responsible if someone else copies it and uses it without the author’s
permission.
It creates a licence for you to use it in any way you wish, which may be useful.
You should provide a way for someone to contact you and request that
content is removed. This could be as simple as an e-mail address.

6

Complaints regarding content on our website
This paragraph is a reminder to visitors that moderation of all user generated
content is not always viable.
It shows that you take complaints about content seriously, and also that adecision to remove content remains with you.

7

Information relating to your method of payment
There are two options here. Delete whichever is not relevant.
The first covers the situation where you do record card information. You
should edit the “measures to protect your information” so that they are
relevant to your business.
The second covers the situation where card information stays with thepayment service provider.
If you don’t take payment at all, of course delete this paragraph completely.

8

Information about your direct debit
If you do not take payment by direct debit, delete this paragraph. Otherwise
edit the wording in blue appropriately.

9

Job application and employment
The purpose of this paragraph is to set out for how long personal information
is processed. It is a requirement of the GDPR.

10

Sending a message to our support team
We suggest you keep this paragraph in your notice. However, you should edit
it to suit how your organisation works.
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11Complaining
This paragraph deals with how information collected as a result of a complaintis used. It should not be confused with an explanation of how to complain(which is dealt with later). We suggest you leave this paragraph as is.

12

Affiliate and business partner information
Information relating to affiliates is not subject to the GDPR. This paragraphshould reassure business partners.

13

Cookies
The start of this paragraph is an explanation of what cookies are.
It is good practice to display a message when a visitor first comes to yourwebsite asking whether he or she accepts use of cookies. The paragraph inblue supports this.
We take the approach here of not listing every single cookie.
The reason is that you not know this information yourself, especially if you use
third party add-ons or plug-ins to your website. For example, Google provides
visitor tracking software (Analytics) that is popular. It could at any pointchange the name or purpose of the many cookies it uses without telling you.
There are so many cookies that software you use is likely to place that to list
them here would increase the size and complexity of the notice, and to keep
the notice up-to-date as they change would be time consuming.
Listing every cookie’s file name, purpose and expiration period could be donein a separate cookie notice, linked from this paragraph.
We prefer the approach of explaining in what ways they are used. Add ordelete to this list as appropriate.

14

Personal identifiers from your browsing activity
Most web servers log requests for pages. We suggest you leave thisparagraph as is, even if you don’t use this information.

15

Our use of re-marketing
Re-marketing is the name given to the practice of advertising your products
and services on third party websites based on pages on your website that thevisitor has already seen.

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It requires you as the website owner to be the client of an advertising service
provider.
When a visitor visits a page of your website, the advertiser’s software throughyour website places a cookie on the visitor’s computer. When he or she visits
another webpage on a third party website, you can choose whether or not to
pay to show him or her an advert for your product or service.
For example, you might sell fruit from your website. A visitor visits a pageabout the health benefits of eating a particular tropical fruit. Later, the same
visitor visits another website about cookery, and specifically a page that
describes a recipe that requires the tropical fruit. Both your website and thecookery website use the same advertising service provider. You can choose
to pay to have your adverts for that tropical fruit to be displayed on the
cookery website.
The advertising service provider usually allows you to specify exactly whatcriteria must be met in order to display your advert, making re-marketing a
cost efficient way of advertising.
Some people feel very strongly about re-marketing. It can elicit fears of “being
followed around the web”, particularly if the topic of the advert is sensitive.
You can choose to delete this paragraph entirely if you do not use remarketing. However, keeping it in place will allow you to experiment withdifferent types of display marketing later.
Disclosure and sharing of your information
16

Information we obtain from third parties
This paragraph is a reminder to visitors that you may use third party
information provision services. Delete if not appropriate to your organisation.

17

Third party advertising on our website
Delete if not appropriate to your organisation.

18

Credit reference
We suggest that you leave this paragraph in place even if you have no
immediate intention of liaising with debt collectors. It may be a useful“reminder” to users of your website.

19

Data may be processed outside the European Union

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It is a legal requirement to tell the visitor if his or her information is processed
outside the EU. It is especially important if you have your own business
operations outside the EU.
If you want to be as compliant as possible, you should also identify carefully
whether you use services outside the EU. You may use, for example, a USbased online software service to provide your chat system.
In practice, it might be very difficult to identify exactly where software has
been written, whether the software house processes your data in any way,
and where this might take place.
The clause giving examples (in blue) could be deleted entirely if you don’t
want possibly to mislead readers.
The safeguards (bullet points at the end of the paragraph) seem verbose, but
are copied verbatim from the legislation. Choose the most appropriate (one,maybe two) and delete the others.
Access to your own information
Under the GDPR, a data subject has a right to access information about him
or her, and a right for that information to be kept up-to-date and only for as
long as required.
You should leave these three paragraphs in place, editing the addresses.
Other matters
23

Use of site by children
Under UK law, you cannot form a contract with a child. So a child cannot
agree to your terms and conditions, which means that he or she cannot agree
to your terms regarding use of his or her information. Additionally, only aparent or guardian can give consent.
So it is very difficult to have a lawful basis for processing personal information
about children.
Additionally, personal information about children is regarded as moresensitive than the same information about an adult. The consequences fordata breaches could be much greater.
We suggest you edit this paragraph to suit your website and keep it in.

24

Encryption of data sent between us

21© Andrew Taylor and Net Lawman Ltd

This paragraph is included to reassure visitors. If you do not use SSL thenremove the paragraph.
25

How you can complain
This paragraph sets out standard wording that tells visitors how to make acomplaint.
It gives you a stronger argument to use arbitration or mediation as a means ofresolving a complaint, rather than going to court.
In any case, you must tell visitors to your site about their right to complain to
the supervisory body, the Information Commissioner’s Office.

26

Retention period for personal data
It is a requirement of the GDPR to tell data subjects for how long personal
information will be kept. This paragraph is a catch-all if the information is notprovided elsewhere.
Basic UK law relating to limitation for bringing a claim, contract matters, tax
and other areas often requires data to be retained for six years. You will be“safe” if you specify that period for commercial transactions.

27

Compliance with the law
Leave this paragraph in place.

28

Review of this privacy policy
Leave this paragraph in place.

End of notes22© Andrew Taylor and Net Lawman Ltd