Privacy Policy Coniston Ltd is a limited company registered in England & Wales. The statutory directors of Coniston Limited are John Rathbone, Steve Clarke, Andrew Wildgoose, Gary Evans and Mus Ulla. Registered no. 1688008 Registered office: Collingwood House, Schooner Court, Crossways, Dartford, Kent VAT no. 405 3265 81 Please send any questions or corrections to info@conistonltd.co.uk For the purposes of data protection law we are the controller of any personal information we hold about you. We have a legal duty to ensure that your rights are protected when we decide how and when to use the information we hold. This policy sets out how we will do this. Cookies are text files placed on your computer to gather standard internet log information and visitor behaviour information. The information is used to track visitor use of the website and to compile statistical reports on website activity. You can set your browser not to accept cookies. In this case some of our website features may not function if you remove cookies from your browser. This website uses cookies for analytical purpose, so we can continually update and monitor the site. By accessing these pages you are agreeing to the use of cookies for analytical purposes. Information tracked is not saved by the company nor will we ever rent, sell, share or otherwise disclose this information to third parties. DATA PRIVACY POLICY Coniston Limited Privacy Policy We know that you care about your personal data and how it is used, and we want you to trust that Coniston uses your personal data carefully. This Privacy Notice will help you understand what personal data we collect, why we collect it and what we do with it. Please take a moment to familiarise yourself with our privacy practices and let us know if you have any questions by submitting a request to info@conistonltd.co.uk Who is collecting it? Any personal data provided to or collected is controlled by Coniston. This Privacy Notice applies to personal data collected by Coniston in connection with the services we offer. This Privacy Notice also applies to Coniston’s marketing content, including offers and advertisements for Coniston services, which we (or a service provider acting on our behalf) send to you on third-party platforms and applications. These third-party websites generally have their own Privacy Notice and Terms and Conditions. We encourage you to read them before using those websites. What personal data is being collected? Personal data, 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, use, store and transfer different kinds of personal data about you which we have grouped together as follows: Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender. Contact Data includes billing address, delivery address, email address and telephone numbers. Financial Data includes bank account and payment card details. Transaction Data includes details about payments to and from you and other details of services you have commissioned from us. Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website. Marketing and Communications Data includes your preferences in receiving marketing from us or any third parties and your communication preferences. 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 services). In this case, we may have to cancel a service you have with us, but we will notify you if this is the case at the time. 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, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you; • Inquire or apply for our services; • request marketing to be sent to you; • enter or complete a competition, promotion or survey; • provide CV’s or other information about yourself for specific purposes; or • give us some feedback. 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, server logs and other similar technologies. How we use your data We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances: • Where we need to perform the contract, we are about to enter or have entered into with you. • Where we need to comply with a legal or regulatory obligation. • Where you have provided your consent to us to use your personal data in a certain way such as direct marketing by email. PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA We have set out below, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data on more than one lawful ground depending on the specific purpose for which we are using your data. We may also process your personal data without your knowledge or consent, in compliance with this policy, where this is required or permitted by law. Purpose/Activity: To register you as a new client Type of data: Identity, Contact details and Marketing and Communications Lawful basis for processing including the basis of legitimate interest: Performance of a contract with you and necessary for our legitimate interest Purpose/Activity: To process and deliver our services including: Manage payments, fees and charges Collect and recover money owed to us Type of data: Identity, Contact and Financial Transaction Lawful basis for processing including basis of legitimate interest: Performance of a contract with you and necessary for our legitimate interests (to recover debts due to us) Purpose/Activity: To manage our relationship with you which will include: Notifying you about changes to our terms or privacy policy or asking you to leave a review or take a survey Type of data: Identity, Contact and Marketing and communications Lawful basis for processing including basis of legitimate interest: Performance of a contract with you, necessary to comply with a legal obligation and necessary for our legitimate interests (to keep our records updated and to study how clients use our services) Purpose/Activity: To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) Type of data: Identity, Contact and Technical Lawful basis for processing including basis of legitimate interest: Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation) and necessary to comply with a legal obligation Purpose/Activity: To deliver content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you Type of data: Identity, Contact, Usage, Marketing and Communications and Technical Lawful basis for processing including basis of legitimate interest: Necessary for our legitimate interests (to study how customers use our services, to develop them, to grow our business and to inform our marketing strategy) Purpose/Activity: To use data analytics to improve our website, products/services, marketing, customer relationships and experiences Type of data: Technical and Usage Lawful basis for processing including basis of legitimate interest: Necessary for our legitimate interests (to define types of client for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy). MARKETING We may use your personal data to provide you with information about our services, awards or news which we consider may be of interest to you. Where we do this via email, we will not do so without your prior consent except for when you have previously used services from us, in which case, you will receive marketing from us unless you have told us that you do not wish to receive that marketing. OPTING OUT You can opt out of receiving email communication from us by notifying us via email. It may take up to 28 days for the changes to come into effect. THIRD-PARTY MARKETING We will never sell your personal data to third parties for the purposes of marketing. COOKIES You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. Disclosure of your personal data We may have to share your personal data with other parties/organisations such as: Third parties or sub-contractors to whom we may choose to transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners and/or employees may use your personal data in the same way as set out in this privacy policy. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. International Transfers We share your personal data within Coniston. In general, the personal data that we collect from you will be stored at a destination within the UK or European Economic Area (EEA). However, we reserve the right to transfer your data outside the EEA. Please note that some countries outside of the EEA have a lower standard or protection for personal data, including lower security requirements and fewer rights for individuals. Where your personal data is transferred, stored and/or otherwise processed outside the EEA, we will take all reasonable steps necessary to ensure that the recipient implements appropriate safeguards (such as by entering into standard contractual clauses) designed to protect your personal data and to ensure that your personal data is treated securely and in accordance with this policy. No transmission of your personal data over the internet can be guaranteed to be 100% secure. However, your personal data is only accessible by appropriately trained staff and contsultants and stored on secure server with features enacted to prevent unauthorised access. For your Data Security we have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. In general, unless still required in connection with the purpose(s) for which it was collected and/or is processed, we remove your personal data from our records seven years after the date it was collected unless different retention periods apply. However, if before that date (i) your personal data is no longer required in connection with such purpose(s), (ii) we are no longer lawfully entitled to process it or (iii) you validly exercise your right of erasure, we will remove or anonymise from our records at the relevant time. In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you. If you request to receive no further contact from us, we will keep some basic information about you to comply with your request and avoid sending you unwanted materials in the future. Your Legal 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. Note, however, that we may be unable to supply certain pieces of information that you have requested, if it is subject to legal privilege or relates to management planning. This will be notified to you, if applicable, at the time of your request. You can submit a subject access request to Coniston using the contact details below. To assist us in processing your request, you will need to provide the following information: – Full name – Telephone number – Email address – Information sought (Please describe, in as much detail as possible, the information you wish to have access to and if appropriate, any dates relevant to the information sought.) – 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 personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete your personal data where you have successfully exercised your right to object to processing, 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 or as soon as possible thereafter. We may also anonymise rather than delete your data. If you would like to exercise any of the rights below, you can email, call or write to us, on the contact details provided below. Please provide your full name, contact telephone number and email address. – 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 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. – Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent. If you would like to opt out from receiving marketing messages from us, please see section above on OPTING OUT. WHAT WE WILL NEED FROM YOU We will need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. TIME LIMIT TO RESPOND We try to respond to all legitimate requests within one month. In the event that it will take longer we will notify you and keep you updated. THIRD-PARTY LINKS Our websites may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit. CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES This version was last updated on 17th July 2019. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us. CONTACT DETAILS Coniston Ltd, Collingwood House, Schooner Court, Crossways, Dartford, Kent, DA2 6QQ – tel 01322 223231, email info@conistonltd.co.uk 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. TERMS OF USE By accessing these pages you agree to be bound by these terms of use which shall be governed by and interpreted in accordance with the laws of England and Wales.We reserve the right to amend these terms from time to time. We may notify you of changes by any reasonable means including by posting the revised version of these terms on this website. You should check them whenever accessing our website. Your use of this website following changes to these terms will constitute your acceptance of such changes. No copying of any words, images, graphic representations or other information contained in this web site is permitted without the prior written permission of the Coniston. LEGAL DISCLAIMER Coniston has taken all reasonable steps to ensure that the information contained within the pages of this site is accurate and current. All the information on this website is published in good faith and for general information purpose and no warranty is given and no representation is made regarding the accuracy of or completeness of the content of this site. Coniston accepts no responsibility for any losses or damages arising out of errors or omissions contained in the site or arising from reliance on information contained in the site. The links to other websites does not imply that we approve or endorse the content of those sites and Coniston accepts no responsibility for the information made available via such sites. If you follow a link which takes you away from our website, please be aware that other websites have different privacy policies and terms which are beyond our control. © Copyright 2019 Coniston Ltd. All Rights Reserved. Website by delego Limited Get in touch We use cookies and similar technologies to ensure that the site works optimally. If you continue on the site, we assume that you agree. View our Privacy Policy. ACCEPT