PRIVACY POLICY

PRIVACY POLICY

 

1      INTRODUCTION

 

We are Universally Speaking Limited (“Universally Speaking”, “us”, “we”, “our”). We are a limited company registered in England and Wales under registration number 05431888 and we have our registered office at Knowledge Centre, Wyboston Lakes, Wyboston, Bedfordshire, England, MK44 3BY We are registered with the UK supervisory authority, Information Commissioner’s Office (“ICO”), in relation to our processing of Personal Data under registration number ZB245891.

Universally Speaking and its affiliates, subsidiaries and related entities is committed to protecting the privacy and security of the personal data we collect about end customers and users of our services (“you/your”).

The purpose of this privacy notice is to explain what personal data we collect about you, including when and why it is collected, how it is used and how it is kept secure. When we do this, we are the data controller.

For more information regarding our collection and processing of your personal data as part of our job application process, please see our Job Applicant Privacy Notice.

If you visit our website, we will collect information about your engagement with us online via our cookies and similar technologies such as your IP address and geographical location. See our Cookie Notice for more information on our use of cookies and similar technologies.

Please read this privacy notice carefully as it provides important information about how we handle your personal information and your rights. If you have any questions about any aspect of this privacy notice you can contact us using the information provided below or by emailing us at GDPR@universallyspeaking.com.

 

2      WHAT IS PERSONAL DATA?

 

‘Personal data’ is any information from which you can be identified, either directly or indirectly. For example, your name or an online identifier.

‘Special category personal data’ is more sensitive personal data and includes information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data for the purposes of uniquely identifying someone, data concerning physical or mental health or data concerning someone’s sex life or sexual orientation.

 

3      PERSONAL DATA WE COLLECT

 

We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. We are also subject to the EU General Data Protection Regulation (EU GDPR) in relation to goods and services we offer to individuals in the European Economic Area (EEA).

3.1      Personal data you give to us: 

This is information about you that you have given to us by entering information via our websites, our social media pages, or by corresponding with us by phone, email or otherwise.

The information is provided by you voluntarily, or where we need the information to fulfil a contract with you.

The information you give to us includes your name, date of birth, contact details (such as telephone number, home address, delivery address, email address), enquiry details and your opinion of our products.

In other circumstances you may provide additional information about you such as your photograph and other images and identifying information, your interests and hobbies, posts and preferences.

You may also give us information when you visit our premises. You may provide, car details, phone, email and address.

You may also give us information about you when you submit reviews, profiles, images, videos, instructions, comments, feedback, ideas, suggestions or other information or materials via the web sites or social media, whether relating to our products, or other matters upon which you wish to comment (“Contributions”).

3.2      Personal information we collect about you:

We may automatically collect the following personal information about you from our website:

  • your browser and operating system
  • the website or search engine from which you visit our website
  • the pages that you visit on our website
  • the date and time of your visit
  • for security reasons, e.g. to identify attacks on our website, the Internet protocol (IP) address assigned to you by your internet service.

 
We collect some of the above information by using cookies – please see our Cookies Policy for further information.

We may also collect any personal information which you allow to be shared, that is part of your public profile on a third-party social network.

Other information we collect includes:

  • the full Uniform Resource Locators (URL) clickstream to, through and from the Sites (including date and time)
  • products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs)
  • methods used to browse away from the page
  • phone number used to call our customer service team
  • how many times you have been on the website
  • information about your order including the items you have purchased and details you input when making your purchase including your name, email address delivery address and telephone number (this will be linked to the email address you use when you contact us).

 
 

4      PURPOSES FOR WHICH WE USE PERSONAL DATA
        AND THE LAWFUL BASIS

 

When providing services to you, we may use your personal data for the following purposes and on the following lawful bases:

Purpose Lawful Basis for processing
To provide you with products and services that you request from us. This may require disclosure to third parties for example, banks, shipping providers and carriers, fraud protection agencies and suppliers of gifts. Performance of Contract
To provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired, by telephone, email, SMS and post. Legitimate interests and/or consent. Where we rely on legitimate interests, this is to provide you with information on products and services that we believe are relevant to you. This is also necessary for our legitimate interests to study how you use our goods and services and inform our marketing strategy.
Inform you about our services, events we are attending or company news Consent
To interact with you using Social Media features such as the “like”, “retweet”, “repost” and “share” on Social Media, may allow us to enable integration and/or access to your accounts on Social Media. Consent
We may share your information with selected third parties, where we need to fulfil the contract, including:
Business partners, suppliers and sub-contractors for example, our carriers that deliver Items to you, our card and payment processing companies that process your payments for items
Performance of contract
For analysis, and profiling to inform our marketing strategy, and to enhance and personalise your customer service or visitor experience Legitimate interests. This is necessary for our legitimate interests to define the types of customers for our goods and services.
For network security, in order for us to take steps to protect your information against loss or damage, theft or unauthorised access; Legitimate interests – this is necessary for the provision and administration of IT Services, network security and to prevent fraud.
Legal obligation
For general administration including managing your queries, complaints, or claims and to send service messages to you. Legitimate interests – this is necessary to respond to your queries.

 
Where personal data is processed because it is necessary for the performance of a contract to which you are a party, we will be unable to provide our services without the required information.

 

5      SHARING YOUR DATA

 

It is unlikely that we’ll ever share your personal data outside the UK, European Union or European Economic Area. If, however, it becomes necessary for the purposes of providing our services to you, we will only share it with organisations in countries benefiting from a UK adequacy regulation or on the basis of an International Data Transfer Agreement (or other equivalent measure) approved by the ICO, and where applicable Standard Contractual Clauses approved by the European Commission. These measures contractually oblige the recipient to process and protect your personal data to the standard expected within the UK and EU/EEA, respectively.

 

6      HOW LONG WE KEEP YOUR DATA

 

We will retain your personal data for as long as is necessary to provide you with our services and for a reasonable period thereafter to enable us to meet our contractual and legal obligations and to deal with complaints and claims.

At the end of the retention period, your personal data will be securely deleted or anonymised, for example by aggregation with other data, so that it can be used in a non-identifiable way for statistical analysis and business planning.

 

7      HOW WE PROTECT YOUR DATA

 

We implement appropriate technical and organisational measures to protect data that we process from unauthorised disclosure, use, alteration or destruction.

In addition to the technical and organisational measures we have put in place, there are a number of simple things you can do to in order to further protect your personal information;

      1. Never share a One Time Passcode (OTP).
      2. Never enter your details after clicking on a link in an email or text message.
      3. Always send confidential information by encrypted email where possible this reduces the risk of interception.
      4. If you’re logged into any online service do not leave your computer unattended.
      5. Close down your internet browser once you’ve logged off.
      6. Never download software or let anyone log on to your computer or devices remotely, during or after a cold call.

 
7.1      Secure Online Services

You can easily identify secure websites by looking at the address in the top of your browser which will begin https:// rather than http://.

 

8      YOUR RIGHTS AND OPTIONS

 

You have the following rights in respect of your personal data:

  • You have the right of access to your personal data and can request copies of it and information about our processing of it.
  • If the personal data we hold about you in incorrect or incomplete, you can ask us to rectify or add to it.
  • Where we are using your personal data with your consent, you can withdraw your consent at any time.
  • Where we are using your personal because it is in our legitimate interests to do so, you can object to us using it this way.
  • Where we are using your personal data for direct marketing, including profiling for direct marketing purposes, you can object to us doing so.
  • You can ask us to restrict the use of your personal data if:
    • It is not accurate.
    • It has been used unlawfully but you do not want us to delete it.
    • We do not need it any-more, but you want us to keep it for use in legal claims; or
    • if you have already asked us to stop using your data but you are waiting to receive confirmation from us as to whether we can comply with your request.
       
  • In some circumstances you can compel us to erase your personal data and request a machine-readable copy of your personal data to transfer to another service provider.
  • You have the right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you.

 
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

If you wish to exercise your rights, please contact us at GDPR@universallyspeaking.com.

You can also lodge a complaint with the Information Commissioner’s Office. They can be contacted using the information provided at:
https://ico.org.uk/concerns/

 

9      CONTACT US

 

If you have any questions, or wish to exercise any of your rights, then you can contact:

Sarah Pownall
Data Protection Officer
Universally Speaking
The Knowledge Centre
Wyboston Lakes
Great North Road
Wyboston
Bedfordshire
MK44 3BY

Alternatively, you can email us at GDPR@universallyspeaking.com

 

10      CHANGES TO THIS PRIVACY NOTICE

 

We may update this notice (and any supplemental privacy notice), from time to time as shown below. We will notify of the changes where required by applicable law to do so.

Last modified 31st May 2024.
 
 

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