1 ABOUT THIS POLICY
1.1 We appreciate your interest in our products and services and your visit to this website. Your privacy is important to us and we want you to feel comfortable with how we use and share your personal information.
1.2 This policy sets out how Universally Speaking Limited handle your personal information, including when and why it is collected, used and disclosed and how it is kept secure.
1.3 You will find our contact details at the end of this policy which you can use if you have any questions, including how to update or access your personal information or to make a complaint.
1.4 This policy may change, so please check from time to time to ensure that you’re happy with any changes. Please see “Changes to this policy” in Section 10.
1.5 This policy was last updated on 25th April 2018.
2 WHO WE ARE
2.1 When you deal with Universally Speaking Limited, we will be the ‘controller’ of your personal information. A ‘controller’ is a company that decides why and how your personal information is processed.
Where this policy refers to “we” “our” or “us” below, unless it mentions otherwise, it’s referring to Universally Speaking Limited.
3 HOW AND WHAT PERSONAL INFORMATION WE COLLECT
3.1 We may collect and process the following personal information about you
Personal information you give to us:
This is information about you that you have given to us by entering information via our websites or our social media pages or by corresponding with us by phone, email or otherwise and 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.
You may also give us information about you when you fill in forms on Third Party platforms or when you correspond with us on Social Media or our website, for example when you register to subscribe to our emails. In such 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”).
You must ensure in all instances that the information you provide is personal to you and no one else (for example you must only provide an email address that is only accessible by you and not any other person. You should not use another person’s email address or a generic email address). You must also ensure that the information you provide is accurate and up to date. By providing information about you to us you warrant that the information you provide is personal to you and is accurate and up to date, and that you will keep us informed of any changes.
3.2 Personal information we collect about you:
How many times you have been on the web site and 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 HOW WE USE YOUR PERSONAL INFORMATION
4.1 Where you have provided CONSENT
We may use and process your personal information where you have given consent for us to do so for the following purposes:
to carry out our obligations arising from any contracts or transactions entered into between you and us for example, to process your order.
to provide you with the information, 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.
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. Please note we do not control your profile/account on Twitter, Facebook, or LinkedIn (“Social Media Sites”), we do not modify your account or your privacy settings on the Social Media Sites and we do not establish rules about how your personal information will be used when you use the Social Media Sites. You and the relevant provider of the Social Media Sites will be in control of those issues and not us. You are encouraged to read all policies and information on the applicable Social Media Sites to learn more about how they handle your information before using the Social Media Sites and any features on the Social Media Sites;
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. You can unsubscribe from our mailing list by writing to our team at email@example.com or Universally Speaking, The Knowledge Centre, Wyboston Lakes, Great North Road, Wyboston, Bedfordshire, MK44 3BY.
If you consent to our Marketing preferences, you can expect to receive the following.
- Information about our services or events we are attending
- Company news
You may withdraw your consent for us to use your information in any of these ways at any time. Please see “Withdrawing your Consent” in Section 7.4 for further details.
4.2 Where required to perform a CONTRACT with you
We may use and process your personal information where it is necessary for the performance of a contract with you or in order to take steps at your request before entering into a contract with you, including for the following purposes:
- Ability to contact
- Accurate billing
We may share your information with selected third parties, where we need to in order 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 and suppliers of those items and prizes for our promotions.
4.3 Where it is in your VITAL INTEREST
We may use your personal information to contact you if there are any urgent safety or product recall notices to communicate to you or where we otherwise reasonably believe that the processing of your personal information will prevent or reduce any potential harm to you. It is in your vital interests for us to use your personal information in this way.
4.4 Where required to comply with our LEGAL OBLIGATIONS
We will use your personal information to comply with our legal obligations including:
- to assist HMRC, the Police or any other public authority or criminal investigation body;
- to identify you when you contact us;
- to verify the accuracy of data that we hold about you.
4.5 Where there is a LEGITIMATE INTEREST
We may use and process your personal information where it is necessary for us to pursue our legitimate interests as a business for the following purposes:
- for analysis, and profiling to inform our marketing strategy, and to enhance and personalise your customer service or visitor experience;
- for market research in order to continually improve the products and services that we deliver to you;
- to administer our websites for internal operations, including troubleshooting, testing, statistical purposes;
- for marketing activities (other than where we rely on your consent) e.g. to tailor marketing communications or send targeted marketing messages via social media and other third-party platforms;
- for the prevention of fraud and other criminal activities;
- to correspond and communicate with you;
- to create a better understanding of you as a customer or visitor;
- for network security, in order for us to take steps to protect your information against loss or damage, theft or unauthorised access;
- to comply with a request from you in connection with the exercise of your rights (for example where you have asked us not to contact you for marketing purposes, we will keep a record of this on our suppression lists in order to be able to comply with your request);
- for the purposes of corporate restructure or reorganisation or sale of our business or assets;
- for efficiency, accuracy or other improvements of our databases and systems e.g. by combining systems or consolidating records we hold about you;
- to enforce or protect our contractual or other legal rights or to bring or defend legal proceedings; and
- for general administration including managing your queries, complaints, or claims and to send service messages to you.
5 OTHERS WHO MAY RECEIVE OR HAVE ACCESS TO YOUR PERSONAL INFORMATION
5.1 Our suppliers and service providers
We may disclose your information to our third-party service providers, agents, subcontractors and other organisations for the purposes of providing services to us or directly to you on our behalf. Such third parties may include cloud services providers (such as hosting and email management) or advertising agencies, administrative services or other third parties who provide services to us.
When we use third party service providers, we only disclose to them any personal information that is necessary for them to provide their service and we have a contract in place that requires them to keep your information secure and not to use it other than in accordance with our specific instructions.
5.2 Other ways we may share your personal information
We may transfer your personal information to a third party as part of a sale of some or all of our business and assets to any third party or as part of any business restructuring or reorganisation. We may also transfer your personal information if we’re under a duty to disclose or share it in order to comply with any legal obligation (e.g. by sharing your personal information with HMRC), to detect or report a crime, to enforce or apply the terms of our contracts or to protect the rights, property or safety of our visitors and customers.
However, we will always take steps with the aim of ensuring that your privacy rights continue to be protected.
6 HOW LONG WE KEEP YOUR PERSONAL INFORMATION FOR
6.1 If we collect your personal information, the length of time we retain it is determined by a number of factors including the purpose for which we use that information and our obligations under law.
6.2 We do not retain personal information in an identifiable format for longer than is necessary.
6.3 We may need your personal information to establish, bring or defend legal claims, in which case we will retain your personal information for 7 years after the last occasion on which we have used your personal information in one of the ways specified in “How we use your personal information” in Section 4.
The only exceptions to this are where the law requires us to hold your personal information for a longer period, or delete it sooner;
6.4 You exercise your right to have the information erased (where it applies) and we do not need to hold it in connection with any of the reasons permitted in this section 6, or because we are required under the law (see further “Erasing your personal information or restricting its processing” in Section 7.6); and
6.5 In limited cases, the law permits us to keep your personal information indefinitely provided we put certain protections in place.
7 YOUR RIGHTS
7.1 Your ‘data subject’ rights:
You have a number of rights in relation to your personal information under data protection law. In relation to certain rights, we may ask you for information to confirm your identity and, where applicable, to help us to search for your personal information. Except in rare cases, we will respond to you within 30 days after we have received this information or, where no such information is required, we will respond on receipt of your request.
7.2 Accessing your personal information
You have the right to ask for a copy of the information that we hold about you by emailing or writing to us at the address at the end of this policy. We may not provide you with a copy of your personal information if this concerns other individuals or we have another lawful reason to withhold that information.
7.3 Correcting and updating your personal information
The accuracy of your information is important to us and we are working on ways to make it easier for you to review and correct the information that we hold about you.
In the meantime, if you change your name or address/email address, or you discover that any of the other information we hold is inaccurate or out of date, you may change your details either in person, or by contacting us at the address provided at the end of this policy.
7.4 Withdrawing your consent
Where we rely on your consent as the legal basis for processing your personal information, as set out under “How we use your personal information” in Section 4, you may withdraw your consent at any time by contacting us using the details provided at the end of this policy. If you would like to withdraw your consent to receiving any direct marketing to which you previously opted-in, you can also do so by using our unsubscribe tool.
7.5 Objecting to our use of your personal information and automated decisions made about you
Where we rely on our legitimate business interests as the legal basis for processing your personal information for any purpose(s), as laid out under “How we use your personal information” in Section 4, you may object to us using your personal information for these purposes by emailing or writing to us at the address provided at the end of this policy. Except for the purposes for which we are sure we can continue to process your personal information, we will temporarily stop processing your personal information in line with your objection until we have investigated the matter. If we agree that your objection is justified in accordance with your rights under data protection laws, we will permanently stop using your data for those purposes. Otherwise we will provide you with our justification as to why we need to continue using your data.
You may object to us using your personal information for direct marketing purposes and we will automatically comply with your request. If you would like to do so, please use our unsubscribe tool.
You may also contest a decision made about you based on automated processing by contacting the data protection department at the address provided at the end of this policy
7.6 Erasing your personal information or restricting its processing
In certain circumstances, you may ask for your personal information to be removed from our systems by emailing or writing to us at the address at the end of this policy. Unless there is a reason that the law allows us to use your personal information for longer, we will make reasonable efforts to comply with your request.
You may also ask us to restrict processing your personal information in the following situations:
- where you believe it is unlawful for us to do so,
- you have objected to its use and our investigation is pending or you require us to keep it in connection with legal proceedings.
In these situations, we may only process your personal information whilst its processing is restricted if we have your consent or are legally permitted to do so, for example for storage purposes, to protect the rights of another individual or company or in connection with legal proceedings.
7.7 Transferring your personal information in a structured data file
Where we rely on your consent as the legal basis for processing your personal information or need to process it in connection with your contract, as set out under Section 4 “How we use your personal information”, you may ask us to provide you with a copy of that information in a structured data file. We will provide this to you electronically in a structured, commonly used and machine-readable form, such as a CSV file.
You can ask us to send your personal information directly to another service provider, and we will do so if this is technically possible. We may not provide you with a copy of your personal information if this concerns other individuals or we have another lawful reason to withhold that information.
7.8 Complaining to the UK data protection regulator
You have the right to complain to the Information Commissioners Office (ICO) if you are concerned about the way we have processed your personal information. Please visit the ICO’s website for further details.
8 SECURITY / COOKIES / LINKS / SOCIAL PLUGINS
8.1 Security measures we put in place to protect your personal information
Universally Speaking use technical and organisational security measures to protect the personal information supplied by you and managed by us against manipulation, loss, destruction, and access by third parties. Our security measures are continually improved in line with technological developments.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your information whilst in transit to our website and any transmission is at your own risk.
Where we have given (or where you have chosen) a password which enables you to access an account, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
8.2 Use of ‘cookies’
‘Cookies’ are small pieces of information sent to your device and stored on its hard drive to allow our websites to recognise you when you visit.
Our cookies don’t store sensitive information such as your name, address or payment details: they simply hold the ‘key’ that, once you’re signed in, you are associated with this information. However, if you’d prefer to restrict, block or delete cookies from our site, or any other website, you can use your browser to do this. Each browser is different, so check the ‘Help’ menu of your particular browser (or your mobile phone’s handset manual) to learn how to change your cookie preferences. Users have the opportunity to set their devices to accept all cookies, to notify them when a cookie is issued, or not to receive cookies at any time.
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These cookies enable the function of Google Analytics. This software helps us take and analyse visitor information such as browser usage, new visitor numbers, response to marketing activity. That information helps us to improve the website, and to make our marketing campaigns relevant. The data stored by these cookies can be seen only by Universally Speaking and Google and never shows any confidential information.
8.3 Links to other websites
In addition, if you linked to our website from a third-party website, we cannot be responsible for the privacy policies and practices of the owners and operators of that third-party website and recommend that you check the policy of that third-party website.
8.4 Social plugins
We use so-called social plugins (buttons) of social networks such as Facebook, Twitter and LinkedIn.
When you visit our websites, these buttons are deactivated by default, i.e. without your intervention they will not send any data to the respective social networks. Before you are able to use these buttons, you must activate them by clicking on them. They then remain active until you deactivate them again or delete your cookies.
After their activation, a direct link to the server of the respective social network is established. The contents of the button are then transmitted from the social network directly to your browser and incorporated in the website.
After activation of a button, the social network can retrieve data, independently of whether you interact with the button or not. If you are logged on to a social network, the network can assign your visit to the website to your user account
If you are a member of a social network and do not wish it to combine data retrieved from your visit to our websites with your membership data, you must log out from the social network concerned before activating the buttons.
We have no influence on the scope of data that is collected by the social networks through their buttons. The data use policies of the social networks provide information on the purpose and extent of the data that they collect, how this data is processed and used, the rights available to you and the settings that you can use to protect your privacy.
9.1 We may collect your preferences to send you marketing information directly from us by email/SMS (where applicable) including:
- When you register with us on our website
We will only do so if you have consented to receiving such marketing information directly from us.
9.2 We may contact you with targeted advertising delivered online through social media and platforms (operated by other companies) by using your personal information, or use your personal information to tailor marketing to improve its relevance to you, unless you object.
9.3 From time to time, we may ask you to refresh your marketing preferences by asking you to confirm that you consent to continue receiving marketing information from us.
9.4 You have the right to opt-out of our use of your personal information to provide marketing to you in any of the ways mentioned above. Please see “Withdrawing your Consent” in Section 7.4 and “Objecting to our use of your personal information and automated decisions made about you” in Section 7.5 for further details on how you can do this.
10 CHANGES TO THIS POLICY
We may review this policy from time to time and any changes will be notified to you by posting an updated version on our website and/or by contacting you by email. Any changes will take effect 7 days after the date of our email or the date on which we post the modified terms on our website, whichever is the earlier. We recommend you regularly check for changes and review this policy when you visit our website. If you do not agree with any aspect of the updated policy, you must promptly notify us.
11 CONTACT US
If you have any questions, suggestions or complaints about the processing of your personal information or wish to contact us to amend/update your marketing preferences with Universally Speaking Limited, please contact:
Data Protection Officer
The Knowledge Centre
Great North Road
Telephone: 01480 210621