Privacy Policy

Data Protection is a priority issue for Love Air Limited (“Love Air”). Therefore, we want to inform you in accordance with the applicable data protections provisions about the personal data used when you visit our website (regardless of where you visit from) and tell you about your privacy rights and how the law protects you. Love Air respects your privacy and is committed to protecting your personal data.


Scope of Privacy Policy

  1. When This Privacy Policy Applies
  2. Name and Address of The Controller
  3. How We Collect Your Personal Data
  4. Legal Basis for Usage of Personal Data
  5. Disclosure of Your Information
  6. International Transfers
  7. Cookies
  8. Subscription to Our Newsletters
  9. Online Services – Links to Third Party Sites, Services and Content
  10. Period for Which Personal Data Are Stored
  11. Security
  12. Rights of The Data Subject
  13. Existence of Automated Decision-Making, Profiling
  14. Status of This Privacy Policy

 

  1. WHEN THIS PRIVACY POLICY APPLIES

 

This Privacy Policy applies:

  • to your use of any of our services where we are performing a data controller function;
  • where you apply to us for a job or work placement; 
  • to your supply of services to us where this involves any personal data; and/or
  • to any personal information collected from third parties where we are the controller of such information.

 

This Privacy Policy additionally applies to our website and online services, including www.Love- Air.com and any other website, mobile app or other online service created or hosted by us from time to time on which this Privacy Policy appears (together, our "online services") through which we may collect certain details if, for example, you want to subscribe to any publications or newsletters that we may periodically issue. 

The website is not intended for children and we do not knowingly collect data relating to children.

This Privacy Policy does not apply to, and Love Air is not responsible for, any third-party websites which may be accessible through links from this website, plug-ins or applications. 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.  (please see section 9 (ONLINE SERVICES - LINKS TO THIRD PARTY SITES, SERVICES AND CONTENT) below for more information).

Love Air is part of a group of entities (the “Group”). This Privacy Policy is issued on behalf of the Group. 

 

  1. NAME AND ADDRESS OF THE CONTROLLER

We have appointed a data protection officer (“DPO”) who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact DPO using the details 

International House

10 Beaufort Court

Admirals Way

London

E149XL 

Email: hello@Love-Air.com (FAO: DPO)


We keep our Privacy Policy under regular review. 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.

 

  1. HOW WE COLLECT YOUR PERSONAL DATA

 

This Privacy Policy is based on the European General Data Protection Regulation (GDPR) and the UK’s Data Protection Act 2018 (“Data Privacy Laws”).

Subject to this Privacy Policy are personal data. Personal data means any information relating to an identified or identifiable natural person (“data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, financial data, technical data, usage data, marketing and communications data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.


Where you use our services, we will collect personal data directly from you that you voluntarily provide to us, including when you communicate with us via email or other channels; when you sign up for or request that we send you newsletters, alerts, or other materials; when you sign up for a webinar or event; and when you respond to our communications or requests for information.


The information you provide may include current and historical personal data including your name, contact details, title, identification, employment, positions held and enquiry/complaint details and information about the organisation with which you are affiliated. We may also collect personal data about your other dealings with us and our clients, including any contact we have with you in person, by telephone, email or online.


When you use our online services, we collect a series of general data and information when a data subject or automated system calls up the website. This general data and information are stored in the server log files. Collected may be (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our website (so-called referrers), (4) the sub-websites, (5) the date and time of access to the Internet site, (6) an Internet protocol address (IP address), (7) the Internet service provider of the accessing system, and (8) any other similar data and information that may be used in the event of attacks on our information technology systems.


We may also collect personal data from third parties such as your employing organisation, regulatory authorities, recruitment agencies, credit reporting agencies, information or service providers, publicly available records, and the third parties described in the section 5 (DISCLOSURE OF YOUR INFORMATION).


We may collect information from other sources, such as social media platforms that share information about how you interact with our social media content, and any information gathered through these channels will be governed by the privacy settings, policies, and/or procedures of the applicable social media platform, which we strongly encourage you to review.


We will handle any unsolicited information in accordance with the Data Privacy Laws, including destroying or de-identifying such information where we are required to do so.

We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.


Where we need to collect personal data by law, or under the terms of a contract we have with you, and you are unable 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 goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

 

  1. LEGAL BASIS FOR USAGE OF PERSONAL DATA

 

Where we intend to use your personal data, we rely on the following legal grounds:


Performance of a contract: We may need to collect and use your personal data to enter into a contract with you or to perform a contract that you have with us and where we respond to your requests and provide you with services in accordance with our terms and conditions or other applicable terms of business agreed with you or with your employing organisation.


Legitimate interests: Where we consider use of your information as being (a) non-detrimental to you, (b) within your reasonable expectations, and (c) necessary for our own, or a third party’s legitimate purpose, we may use your personal data, which may include:

  • for our own direct marketing or continued communication;
  • the prevention of fraud;
  • our own internal administrative purposes;
  • personalisation of the service(s) we provide to you;
  • ensuring network and information security, including preventing unauthorised access to electronic communications networks and stopping damage to computer and electronic communication systems; and/or
  • reporting possible criminal acts or threats to public security to a competent authority.

Compliance with a legal obligation: We may be required to process your information due to legal requirements, including employment laws, tax laws and other regulatory provisions applicable to Love Air.


Consent: You may be asked to provide your consent in connection with certain services that we offer, for example subscribing to our newsletter, or in respect of any processing of your personal data for our marketing purposes where you or your employing organisation is not a client of Love Air. Where we are reliant upon your consent, you may withdraw this at any time by contacting us using the contact details above, however, please note that we will no longer be able to provide you with the products or services that rely on having your consent.

If at any time we intend to change the purpose for which we hold your personal data, for example to offer you with a complimentary service that we may provide in the future, we will give you prior information of that new purpose, so you are aware of this.

Purposes for which we will use your personal data

We have set out below, in a table format, 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 for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below. 

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To register you as a new customer

(a) Identity 

(b) Contact

Performance of a contract with you

To process and deliver your order including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

(a) Identity 

(b) Contact 

(c) Financial 

(d) Transaction 

(e) Marketing and Communications

(a) Performance of a contract with you 

(b) Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

(c) Managing product recalls on your behalf

(a) Identity 

(b) Contact 

(c) Profile 

(d) Marketing and Communications

(a) Performance of a contract with you 

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To enable you to partake in a competition or complete a survey

(a) Identity 

(b) Contact 

(c) Profile 

(d) Usage 

(e) Marketing and Communications

(a) Performance of a contract with you 

(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)  

(a) Identity

(b) Contact

(c) Technical

(a) 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 or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

(a) Identity 

(b) Contact 

(c) Profile 

(d) Usage 

(e) Marketing and Communications 

(f) Technical 

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

(a) Technical 

(b) Usage 

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

To make suggestions and recommendations to you about goods or services that may be of interest to you

(a) Identity 

(b) Contact 

(c) Technical 

(d) Usage 

(e) Profile 

(f) Marketing and Communications

Necessary for our legitimate interests (to develop our products/services and grow our business)


Change of purpose 

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. 

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.


  1. DISCLOSURE OF YOUR INFORMATION

We may, in providing our services and operating our business, allow access to your personal data to the different entities within the Group for our internal administrative purposes such as billing, promoting our events and services, and providing you or your organisation with services, provided in all instances that such processing is consistent with section 4 (LEGAL BASIS FOR USAGE OF PERSONAL DATA) above and applicable law.

We may exchange your personal data with third-party service providers contracted to Love Air where any of the following apply:

  • You have expressly consented to us sharing your personal data in this way.
  • We deem it reasonably necessary to provide you with the services that you have required at any particular time.
  • Such sharing is provided for under contract, including our terms and conditions  for any particular service that we may provide to you.
  • Such sharing is to law enforcement bodies or other government authority.
  • We need to enforce or apply our terms and conditions  to which you have agreed (or other terms that have been agreed to apply to our relationship with you or your employing organisation).
  • It is necessary to protect the rights and interests, property, or safety of Love Air, our clients or others.
  • It is relevant in the circumstances to disclose the information to parties with whom we have co-promotional arrangements (such as jointly sponsored events, external venues, or caterers).
  • Our agents or contractors who assist us in providing our services require such information, for example in fulfilling requests for information, receiving and sending communications, updating marketing lists, analysing data, providing support services or in other tasks from time to time. Our agents and contractors will only use your information to the extent necessary to perform their functions.
  • We use third party service providers to provide services that involve data processing, for example archival, web-hosting, analytics providers in connection with the operation of our online services, event hosting, information technology providers, auditing, reference checking, professional advisory (including legal, accounting, financial and business consulting), mailing vendor, delivery, technology, website, research, banking, payment, client contact, data processing, insurance, forensic, litigation support, marketing and security services. Our service providers include Google Analytics, Facebook, Shopify, MailChimp & Paypal.
  • All, or most, of the assets of Love Air or any single business unit within Love Air are merged with or acquired by a third party, or we expand or re-organise our business, in which case your personal data may form part of the transferred or merged assets.
  • We are under a legal, regulatory or professional obligation to do so (for example, in order to comply with a Court Order). 

 

Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to fulfil the service they provide you on Love Air’s behalf. When such third parties no longer need your personal data to fulfil this service, they will dispose of such details in line with Love Air’s procedures unless they are themselves under a legal obligation to retain information (provided that this will be in accordance with applicable data privacy laws). If we wish to pass your sensitive personal data onto a third party, we will only do so once we have obtained your consent unless we are legally required to do otherwise.


We also provide anonymous statistical information about users of our websites and related usage information to reputable third parties, including analytics and search engine providers. The anonymous data of the server log files are stored separately from all personal data provided by a data subject.


We own the database rights in the information collected via our online services. We do not sell, rent, or otherwise share information that reasonably identifies you or your organisation with unaffiliated entities for their independent use except as expressly described in this Privacy Policy or with your express prior permission.


We may disclose your data to an actual or potential buyer (and its agents and advisers) in connection with any actual or proposed purchase, merger, acquisition, restructuring or insolvency of any part of our business, provided that we inform any recipient that it must use your personal information only for the purposes disclosed in this Privacy Policy.


We may share information that does not reasonably identify you or your organisation as permitted by applicable law.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by contacting us at any time. 

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.


 

  1. INTERNATIONAL TRANSFERS

 

Where you are submitting personal data from within the European Economic Area (“EEA”), such information may be transferred to countries outside the EEA to Canada and the United States of America. By way of example, this may happen if one or more of our third-party service providers with whom we share personal data in accordance with section 5 (DISCLOSURE OF YOUR INFORMATION) are located, or have their servers located, outside your country or the country from which the data were provided. 


If we transfer your information outside the EEA in this way, we will take steps to ensure that your privacy rights continue to be protected by entering in to appropriate data transfer agreements including the Standard Contractual Clauses.

 

  1. COOKIES

 

Our website and services delivered use cookies and other similar technologies. Cookies are text files that are stored in a computer system by websites that you visit. 


Cookies may contain a so-called cookie ID. A cookie ID is a unique identifier of the cookie. It consists of a character string through which Internet pages and servers can be assigned to the specific Internet browser in which the cookie was stored. This allows visited Internet sites to identify the internet browser used.


Through the use of cookies, we can provide the users of this website with more user-friendly services that would not be possible without the cookie setting. Cookies enable us to optimize the use of our websites for the users. An example is a cookie of a shopping cart in an online shop that remembers the articles a customer has placed in the virtual shopping cart.


The data subject may, at any time, prevent the setting of cookies through our website by setting the browser preferences accordingly, and may thus permanently avoid the setting of cookies. Furthermore, cookies already set may be deleted at any time in the browser preferences or by other software programs. If the user deactivates cookies in his internet browser, not all functions of our website may be entirely usable.


Which cookies we use

On this website we use Google Analytics (with the anonymiser function). Google Analytics is a web analytics service. Web analytics is the collection, gathering, and analysis of data about the behaviour of visitors to websites. A web analysis service collects, inter alia, data about the website from which a person has come (the so-called referrer), which sub-pages were visited, or how often and for what duration a sub-page was viewed. Web analytics are mainly used for the optimization of a website and in order to carry out a cost-benefit analysis of Internet advertising.


The operator of the Google Analytics component is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, United States. 


For the web analytics through Google Analytics the controller uses the application "_gat. _anonymizeIp". The IP address of the Internet connection of the data subject is abridged by Google and anonymized when accessing our websites from a Member State of the European Union or another Contracting State to the Agreement on the European Economic Area.


The purpose of the Google Analytics component is to analyse the traffic on our website. Google uses the collected data and information, inter alia, to evaluate the use of our website and to provide online reports, which show the activities on our websites, and to provide other services concerning the use of our Internet site for us.


Google Analytics places a cookie on the information technology system of the data subject. The definition of cookies is explained above. With the setting of the cookie, Google is enabled to analyse the use of our website. With each visit your Internet browser will automatically submit data through the Google Analytics component for the purpose of online advertising and the settlement of commissions to Google and Google gains knowledge of personal information, such as the IP address of the data subject, which serves Google, inter alia, to understand the origin of visitors and clicks, and subsequently create commission settlements.


The cookie is used to store personal information, such as the access time, the location from which the access was made, and the frequency of visits of our website by the data subject. With each visit to our Internet site, such personal data, including the IP address of the Internet access used by the data subject, will be transmitted to Google in the United States of America. These personal data are stored by Google in the United States of America. Google may pass these personal data collected through the technical procedure to third parties.


The data subject may, as stated above, prevent the setting of cookies through our website at any time by setting the browser preferences accordingly and thus permanently avoid the setting of cookies. Such an adjustment to the Internet browser used would also prevent Google Analytics from setting a cookie on the information technology system of the data subject. In addition, cookies already in use by Google Analytics may be deleted at any time via a web browser or other software programs.


In addition, the data subject may object to a collection of data that are generated by Google Analytics, which is related to the use of this website, as well as the processing of this data by Google. For this purpose, the data subject must download a browser add-on at https://tools.google.com/dlpage/gaoptout  and install it. This browser add-on instructs Google Analytics through a JavaScript, that any data and information about the visits of Internet pages may not be transmitted to Google Analytics. The installation of the browser add-ons is considered an objection by Google. 


If the information technology system of the data subject is later deleted, formatted, or newly installed the data subject must reinstall the browser add-ons to disable Google Analytics. If the browser add-on was uninstalled by the data subject or any other person who is attributable to their sphere of competence, or is disabled, the reinstallation or reactivation of the browser add-ons may be initiated.


Further information and the applicable data protection provisions of Google may be retrieved at https://www.google.com/intl/en/policies/privacy/ and at http://www.google.com/analytics/terms/us.html. Google Analytics is further explained at https://www.google.com/analytics/.

 

  1. SUBSCRIPTION TO OUR NEWSLETTERS

 

On our website users may subscribe to our newsletter. The input mask shows what personal data are transmitted.


In the newsletter Love Air informs its customers and business partners regularly about enterprise news and offers. A confirmation e-mail will be sent to the e-mail address entered by a data subject asking him/her to conform the e-mail address.


The registration for the newsletter includes the storage of the IP address of the computer system assigned by the Internet service provider (ISP) and used by the data subject at the time of the registration, as well as the date and time of the registration. The collection of this data is necessary in order to retrace a possible misuse of an e-mail address of a data subject, and it therefore serves the aim of the legal protection of the controller.


The personal data collected as part of a registration for the newsletter will only be used to send our newsletter. In addition, subscribers to the newsletter may be informed by e-mail in the event of modifications to the newsletter offer or of a change in technical circumstances. These data collected in the context of the newsletter subscription will not be transferred to third parties. The subscription to our newsletter may be terminated by the data subject at any time, by clicking the respective link contained in each newsletter, unsubscribing at our website or communicating the revocation of the consent in a different was using the contact data given above.


The newsletter of Love Air contains so-called tracking pixels. A tracking pixel is a miniature graphic embedded in such e-mails, which are sent in HTML format to enable log file recording and analysis. This allows a statistical analysis of the success or failure of online marketing campaigns, optimise the newsletter and adjust it in order to meet the readers’ interests. Based on the embedded tracking pixel, Love Air may see if and when an e-mail was opened by a data subject, and which links in the e-mail were clicked by data subjects. These personal data will not be passed on to third parties. Data subjects are at any time entitled to object this use of the data. 

 

  1. ONLINE SERVICES – LINKS TO THIRD PARTY SITES, SERVICES AND CONTENT

 

In addition to our online services, which we control directly, we also use and provide links to websites which are controlled by third parties, which may include:


  • Twitter, LinkedIn and YouTube, where we have certain Love Air accounts and profiles.
  • Facebook ans Instagram where we have a social page.
  • Mailchimp
  • Paypal

If you use or follow a link to any of these third-party websites, please be aware that these websites have their own privacy policies and that we cannot accept any responsibility for their use of information about you.


Our online services may include integrated content or links to content provided by third parties (such as video materials). This Privacy Policy does not address the privacy, security, or other practices of the third parties that provide such content.


We engage third parties that support the operation of our online services, such as analytics providers. These third parties may use technologies to track your online activities over time and across different websites and online platforms. Please see section 7 (COOKIES POLICY) above for more information.

 

  1. PERIOD FOR WHICH PERSONAL DATA ARE STORED

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see [Rights of the Data Subject] below for further information.

In some circumstances we will 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. 


The data controller shall process and store the personal data of the data subject only for the period necessary to achieve the purpose of storage and in line with Data Privacy Laws.


If the storage purpose is fulfilled, or if the controller is not permitted under Data Privacy Laws to retain your personal data, it shall be erased in accordance with our internal data retention policy or legal and regulatory obligations. 


Newsletter data are deleted once the user unsubscribes. Data sent in connection with requests send to us via our website are deleted once the purpose of the communication is fulfilled.  

 

  1. SECURITY

 

We take steps to hold information securely in electronic or physical form.


Our information security policy is supported by a variety of processes and procedures, and we store information in access-controlled premises or electronic databases requiring logins and passwords. All employees, officers, or contractors of Love Air and third-party providers with access to confidential information are subject to access controls and confidentiality obligations, and we require our third-party data storage providers to comply with appropriate information security industry standards.


Whilst we continually strive to ensure that our systems and controls are updated to reflect technological changes, the transmission of information via the internet is not completely secure, and as such we cannot guarantee the security of your data transmitted to our online services which is at your own risk.


If you communicate with us using non-secure web platforms, you assume the risks that such communications between us are intercepted, not received, delayed, corrupted or are received by persons other than the intended recipient.


Once we have received your information, we will take reasonable steps to use procedures and security features to try to prevent unauthorised access, modification or disclosure.


You can help us to keep your information secure by ensuring that any username or password in relation to our online services is kept strictly personal to you and not made available to any other person. You should stop using your username and password and notify us immediately if you suspect that someone else may be using your user details or password.

 

  1. RIGHTS OF THE DATA SUBJECT

 

Under Data Privacy Laws, we have a duty of care to ensure that your personal data is accurate and up to date. Therefore, please contact us to update or correct your information if this changes or if you believe that any information that we have collected about you is inaccurate at hello@Love-Air.com.

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.

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 or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), 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. 

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 particular 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: 

  • If you want us to establish the data's accuracy.
  • Where our use of the data is unlawful but you do not want us to erase it.
  • 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. 
  • 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 products or services to you. We will advise you if this is the case at the time you withdraw your consent.


If you would like to exercise any of the rights set out in this section, please contact us using the details set out in section 2 (NAME AND ADDRESS OF THE CONTROLLER).  We may refuse to provide access where we have legitimate reasons for doing so under applicable Data Privacy Laws, and in exceptional circumstances may charge a fee for access if the relevant legislation allows us to do so, in which case we will provide reasons for our decision.

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 is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

We may 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.

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. 


You may submit a complaint to the Information Commissioners Office, details of which can be found at https://ico.org.uk/global/contact-us.


If you make a privacy complaint, we will respond to let you know how your complaint will be handled. We may ask you for further details, consult with other parties and keep records regarding your complaint.

 

  1. EXISTENCE OF AUTOMATED DECISION-MAKING, PROFILING

 

We do not use your data for profiling purposes or automatic decision-making.

 

  1. STATUS OF THIS PRIVACY POLICY

 

Your provision of personal data to us or use of our online services constitutes your acceptance of the terms of this Privacy Policy.


As technologies and information governance practices develop, and data privacy laws (and surrounding guidance) evolve, we may need to revise this Privacy Policy. You should therefore review this page regularly to ensure that you are aware of any changes to its terms.


We will post any Privacy Policy changes on this page and, if the changes are significant or may materially impact upon your rights, we will provide a more prominent notice or contact you by other means (including, for certain services, email notification of Privacy Policy changes).


Date of last update: May 18th, 2022