We are committed to safeguarding the privacy of our website visitors and service users.
This policy applies where we are acting as a data controller with respect to the personal data of our
and service users; in other words, where we determine the purposes and means of the processing of that
How we use your personal data
In this Section 2 we have set out: (a) the general categories of personal data that we may
(b) in the case of personal data that we did not obtain directly from you, the source and specific
categories of that data; (c) the purposes for which we may process personal data; and
d) the legal bases of the processing.
We may process data about your use of our website and services ("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,
frequency and pattern of your service use. The source of the usage data is our analytics tracking
This usage data 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.
We may process your account data ("account data"). The account data may include your name, your
company name, your telephone number and your email address. The source of the account data is you or
your employer. The account data may be processed for the purposes of 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 our legitimate interests, namely the proper administration of our website,
the application system and business OR the performance of a contract between you and us or taking steps,
at your request, to enter into such a contract.
We may process information that you post for publication on our website or through our services
("publication data"). The publication data may be processed for the purposes of enabling such
publication and administering our website and services. The legal basis for this processing is consent.
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 communications with users.
We may process any of your personal data identified in 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.
In addition to the specific purposes for which we may process your personal data set out in this
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 in order to protect your vital interests
or the vital interests of another natural person.
Please do not supply any other person's personal data to us, unless we prompt you to do so.
Providing your personal data to others
We may disclose your personal data to our insurers or professional advisers insofar as reasonably
necessary for the purposes of obtaining professional advice, defence of legal claims, whether in court
proceedings or in an administrative or out-of-court procedure.
In addition to the specific disclosures of personal data set out in this Section 3, we may 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. We may also disclose your personal data where such disclosure is necessary for the
establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative
or out-of-court procedure.
International transfers of your personal data
In this Section 4, we provide information about the circumstances in which your personal data may be
transferred to countries outside the European Economic Area (EEA).
You acknowledge that personal data that you submit for publication through our website or services
may 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 5 sets out our data retention policies and procedure, which are designed to help ensure
that we comply with our legal obligations in relation to the retention and deletion of personal data.
Personal data that we process for any purpose or purposes shall not be kept for longer than is
necessary for that purpose or those purposes.
We will retain your personal data as follows: (a) usage data, account data, publication data and
correspondence data The data will be retained for a minimum period of one years following the date we
have obtained, and for a maximum period of five years following the date of last communication.
In some cases it is not possible for us to specify in advance the periods for which your personal
data will be retained. In such cases, we will determine the period of retention based on the following
criteria: (a) the period of retention of usage data, account data, publication data and correspondence
data will be determined based on possible legal procedures.
Notwithstanding the other provisions of this Section 5, 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.
We may update this policy from time to time by publishing a new version on our website.
You should check this page occasionally to ensure you are happy with any changes to this policy.
In this Section 7, we have summarised the rights that you have under data protection law. Some of the
rights are complex, and not all of the details have been included in our summaries. Accordingly, you
should read the relevant laws and guidance from the regulatory authorities for a full explanation of
Your principal rights under data protection law are: (a) the right to access; (b) the right
to rectification; (c) the right to erasure; (d) the right to restrict processing; (e) the
right to object to processing; (f) the right to data portability; (g) the right to complain to a
supervisory authority; and (h) the right to withdraw consent.
You have the right to confirmation as to whether or not we process your personal data and, where we
do, access to the personal data, together with 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 and freedoms of others are not
affected, we will supply to you a copy of your personal data. The first copy will be provided free of
charge, but additional copies may be subject to a reasonable fee.
You have the right to have any inaccurate personal data about you rectified and, taking into account
the purposes of the processing, to have any incomplete personal data about you completed.
In some circumstances you have the right to the erasure of your personal data without undue delay.
Those circumstances include: the personal data are no longer necessary in relation to the purposes for
which they were collected or otherwise processed; you withdraw consent to consent-based processing; you
object to the processing under certain rules of applicable data protection law; the processing is for
direct marketing purposes; and the personal data have been unlawfully processed. However, there are
exclusions of the right to erasure. The general exclusions include where 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.
In some circumstances you have the right to restrict the processing of your personal data. Those
circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose
erasure; 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; and 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. However, we will only otherwise process it: with
your consent; for the establishment, exercise or defence of legal claims; for the protection of the
rights of another natural or legal person; or for reasons of important public interest.
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: the performance of a task carried out in the public interest or in the
exercise of any official authority vested in us; or 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 information
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
You have the right to object to our processing of 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.
You have the right to object to our processing of your personal data for scientific or historical
research purposes or statistical purposes on grounds relating to your particular situation, unless the
processing is necessary for the performance of a task carried out for reasons of public interest.
To the extent that the legal basis for our processing of your personal data is: (a) consent;
or (b) that the processing is necessary for the performance of a contract to which you are party or
in order to take steps at your request prior to entering into a contract, 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. However, this right does not apply where it would adversely
affect the rights and freedoms of others.
If you consider that our processing of your personal information infringes 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, your place of work or the place of the
To the extent that the legal basis for our processing of your personal information is consent, you
have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of
processing before the withdrawal.
You may exercise any of your rights in relation to your personal data [by written notice to us.
A cookie is a file containing an identifier (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.
Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored
by a web browser and will remain valid until its set expiry date, unless deleted by the user before the
expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the
web browser is closed.
Cookies do not typically 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 that we use
analyse the use and performance of our website and services;
Cookies used by our service providers
We use Google Analytics to analyse the use of our website. Google Analytics gathers information about
website use by means of cookies. The information gathered relating to our website is used to create