WeCOMPLETE Privacy & Cookies Policy
WE TAKE YOUR PRIVACY SERIOUSLY:
We may update this policy from time to time by publishing a new version on our website, so you should check this page occasionally to ensure you are happy with any changes we have made to this policy. We may also notify you of changes to this policy by email.
We are committed to using your personal information in accordance with our responsibilities. We are required to provide you with the information in this Privacy Notice under applicable legislation which includes:
• Data Protection Act 2018
• General Data Protection Regulations 2018
• Privacy and Electronic Communications (EC Directive) Regulations 2003
Processing of your personal information is carried out by or on behalf of WeCOMPLETE.
This policy tells you about how we collect, use and protect your personal information.
If you have any queries about our Privacy Notice, please get in touch with our Data Protection Officer at firstname.lastname@example.org.
- How we use your personal data
In this Section we have set out:
(a) the general categories of personal data that we may process;
(b) the purposes for which we may process personal data;
(c) the legal bases of the processing.
1.1 USAGE DATA
We may process data about your use of our website and from the services we provide to you (“usage data”). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing and pattern of your service use. The source of the usage data is Google Analytics and our Software. This usage may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.
1.2 SERVICE DATA
We may process your personal data that is provided in the course of our services (“service data”). The service data may include your name, email address, postal address, service preferences, and identification information. The source of the service data comes from you when you provide it to us. The service data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is the performance of a contract between you and us and/or taking steps at your request, to enter into such a contract and our legitimate interests, namely our interest in the proper administration of our website and business.
1.3 ENQUIRY DATA
We may process information contained in any enquiry you submit to us regarding our products and services (“enquiry data”). The enquiry data may be processed for the purposes of offering, marketing and selling relevant products and/or services to you in the future. We may also process information relating to how you have interacted with our website and any marketing we have sent you in order that we may send you any relevant communications. The legal basis for this processing is consent.
1.4 TRANSACTION DATA
We may process information relating to transactions, including the purchase of goods and services that you enter into with us whether by email, over the phone or through our website (“transaction data”). The transaction data may include your contact details, your card details, and the transaction details. The transaction data may be processed for supplying the purchased goods and services and the keeping of proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely our interest in the proper administration of our website and business.
1.5 NOTIFICATION DATA
We may process information that you provide to us for subscribing to our email notifications and/or newsletters (“notification data”). The notification data may be processed for the purposes of sending you relevant notifications and/or newsletters. The legal basis for this processing is consent.
1.6 CORRESPONDENCE DATA
We may process information contained in or relating to any communication that you send to us (“correspondence data”). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business, and communication with users.
1.7 THE ESTABLISHMENT, EXERCISE, OR DEFENCE OF LEGAL CLAIMS
We may process any of your personal data identified in the other provisions of this policy where necessary for the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative, or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
1.8 COMPLIANCE WITH A LEGAL OBLIGATION
In addition to the specific purposes for which we may process your personal data set out in Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or to protect your interests or the interests of another natural person.
1.9 OTHER PEOPLE’S PERSONAL DATA
Please do NOT supply any other person’s personal data to us, unless we ask you to do so.
- Providing your personal data to others
In this section we provide you with information about which third parties we may pass your data onto.
2.1 OTHER SERVICE PROVIDERS
We may disclose your personal data to any service providers for contractual purposes, for example conveyancing solicitors and parties directly involved in property transaction.
2.2 PROFESSIONAL ADVISORS
We will disclose your personal data to financial advisers and/or legal advisers only if you request that we do so.
We may disclose your personal data to our insurers and/or professional advisors insofar as is reasonably necessary for the purposes of obtaining and maintaining insurance coverage, managing risks, obtaining professional advice, and managing legal disputes.
2.3 OUR TECHNICAL PROVIDERS
We may disclose your personal data to our data centre, telephone and server administration providers but only insofar as is reasonably necessary for the safe and efficient storage of your data.
2.4 OUR PAYMENT PROVIDERS
Financial transactions relating to our website and services may be handled by our payment services providers who are Stripe. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing payments, refunding such payments or parts thereof, and dealing with complaints and queries relating to such payments and refunds.
You can find our payment providers’ privacy policies in the following places:
2.5 OUR PRODUCTIVITY AND COMMUNICATION APPLICATION PROVIDERS
We may disclose your personal data while using our internal productivity and communication applications insofar as is reasonably necessary for the purposes of proper administration of our website and business.
2.6 FOR COMPLIANCE WITH A LEGAL OBLIGATION
We may also disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
2.7 ACKNOWLEDGEMENT OF PERSONAL DATA SPECIFICALLY SUBMITTED FOR PUBLICATION
You acknowledge that personal data that you submit specifically for publication for example testimonials through our website or services may then be available, via the internet, around the world. We cannot prevent the use or misuse of such personal data by others.
- Retaining and deleting personal data
This section sets out our data retention policies and procedure. These are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
3.1 LENGTH OF RETENTION
The periods for which we keep your information depend on the purpose for which your information was collected and the use to which it is put. Personal data that we process for any purposes shall not be kept for longer than is necessary for that purpose or purposes.
3.2 RETENTION RELATING TO A LEGAL OBLIGATION
Notwithstanding the other provisions of this section, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
4. Security of personal data
4.1 APPROPRIATE MEASURES
We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse, or alteration of your personal data.
4.2 SECURE STORAGE
We will store all your personal data on secure servers, personal computers, and mobile devices, and in secure manual record-keeping systems.
4.3 PASSWORD STORAGE
Any passwords you provide us will be stored by us in encrypted form. You should ensure that your password is not susceptible to being guessed, whether by a person or a computer programme. You are responsible for keeping the password you use for accessing your account confidential and we will not ask you for your password (except when you log in).
4.4 FINANCIAL TRANSACTIONS
Any data relating to financial transactions that is sent from your web browser to our web server, or from our web server to your web browser will be protected using encryption technology.
4.5 ACKNOWLEDGEMENT OF YOU TRANSMITTING UNENCRYPTED DATA
You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure and we cannot guarantee the security of that data sent over the internet.
5. Your Rights
In this Section we have summarised the rights that you have under data protection law. Some of the rights are complex and not all the details have been included in this summary. You should therefore familiarise yourself with relevant laws and guidance given under the General Data Protection Regulation (GDPR).
5.1 PRINCIPAL RIGHTS
Your principal rights under the GDPR are:
(a) the right to access
(b) the right to rectification
(c) the right to erasure
(d) the right to restrict processing of your personal data
(e) the right to object to processing of your personal data
(f) the right to data portability
(g) the right to complain to a supervisory authority
(h) the right to withdraw consent
5.2 RIGHT TO ACCESS
You have the right to confirmation as to whether we process your personal data and, where we do, access to that personal data together certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights of others are not affected, we will supply to you a copy of your personal data. There is a charge for providing this information of £10 plus VAT.
5.3 RIGHT TO RECTIFICATION
You have the right to have any inaccurate personal data about you rectified and, considering the purposes of the processing, to have any incomplete personal data about you completed.
5.4 RIGHT TO ERASURE
In some circumstances you will have the right to the erasure of your personal data. Those circumstances include:
(a) the personal data is no longer necessary in relation to the purposes for which it was collected or processed.
(b) you withdraw consent to consent-based processing.
(c) the processing is for direct marketing purposes.
(d) the personal data has been unlawfully processed.
There are certain general exclusions to the right of erasure. These general exclusions include where the processing is necessary for exercising the right of freedom of expression and information, for compliance with a legal obligation or for the establishment, exercise or defence of legal claims.
5.5 RIGHT TO RESTRICT PROCESSING
In some circumstances, you have the right to restrict the processing of your personal data. Those circumstances are:
(a) where you contest the accuracy of the personal data or where the processing is unlawful, but you oppose erasure.
(b) we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims.
(c) where you have objected to processing, pending the verification of that objection.
Where processing has been restricted on this basis, we may continue to store your personal data. We will, however, only otherwise process it with your consent.
5.6 RIGHT TO OBJECT TO PROCESSING
You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for:
(a) the performance of a task carried out in the public interest or in the exercise of any official authority vested in us.
(b) the purposes of the legitimate interests pursued by us or by a third party.
If you make such an objection, we will cease to process the personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
5.7 RIGHT TO OBJECT TO DIRECT MARKETING
You have the right to object to our processing your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection we will cease to process your personal data for this purpose.
5.8 RIGHT TO DATA PORTABILITY
To the extent that the legal basis for our processing of your personal data is consent, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. This right does not apply however, where it would adversely affect the rights and freedoms of others.
5.9 RIGHT TO COMPLAIN TO A SUPERVISORY AUTHORITY
If you consider that our processing of your personal data infringes current data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence or the place of the alleged infringement. In the UK the supervisory authority is the Information Commissioner’s Office at https://ico.org.uk
5.10 RIGHT TO WITHDRAW CONSENT
To the extent that the legal basis for our processing of your personal data is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing carried out before the withdrawal of consent.
5.11 PROVIDING US WITH WRITTEN NOTICE
You may exercise any of your rights in relation to your personal data by giving written notice to us at our postal address or by email to email@example.com
- Third Party Websites
Our website includes hyperlinks to and details of third-party websites. We have no control over and are not responsible for, the privacy policies and practices of third parties.
- Personal data of children
Our website and services are targeted at persons over the age of 18 years. If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.
- Updating Information
WHAT TO DO IF YOU WANT YOUR DATA UPDATED
If you wish to correct or update the personal information that we hold about you then you should let us know by email to firstname.lastname@example.org or by post to our postal address.
9.1 WHAT A COOKIE IS
A cookie is a file containing an identifier i.e. a string of letters and numbers, that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
9.2 TYPES OF COOKIE
Cookies may be either “persistent” or “session” cookies. A persistent cookie will be stored by a web browser and will remain until set expiry date, unless deleted by the user before the expiry date. A session cookie will expire at the end of the user session, when the web browser is closed.
Cookies do not usually contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
9.3 THE COOKIES WE USE
(a) necessary cookies – we use these cookies to help make our website usable by enabling basic functions like page navigation and access to pages which require visitors to create an account and login. Our website cannot function properly without these cookies.
WHAT ARE OURS?
- Our details
Our website address is www.we-complete.com