The right to privacy is a fundamental human right. We protect it not just because it is the law, but because it is the right thing to do. We respect and value the privacy of everyone who visits this website, (“Our Site”) and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
In this Policy the following terms shall have the following meanings:
Our Site is owned and operated by SR2 Communications Limited, a limited company registered in Scotland under company number SC692687.
E-Mail Address: firstname.lastname@example.org.
Registered Office: 4-5 The James Gregory Centre, Campus Two, Aberdeen, AB22 8GU.
We are registered with the Information Commissioners Office, registration number ZB036723.
We are registered for VAT in the United Kingdom, number GB377479732.
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
Under the Data Protection Legislation, you have the following rights, which we will always work to uphold, regardless of your geographical location or citizenship (we will not refuse requests solely on the basis that you are not in the European Union):
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 15.
It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau. You can also learn more about digital privacy at the EFF's website.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 15.
|Data Collected||How We Collect the Data|
|Identity Information: name, title, gender, pronouns.||We do not attempt to capture this information deliberately through your use of Our Site, however it may be collected as a side-effect when you contact us through Caller ID, e-mail headers or signatures, or other communications metadata.|
|Contact information: address, email address, telephone number.||We do not attempt to capture this information deliberately through your use of Our Site, however it may be collected as a side-effect when you contact us through Caller ID, e-mail headers or signatures, or other communications metadata.|
|Business information: business name, job title, profession.||We do not attempt to capture this information deliberately through your use of Our Site, however it may be collected as a side-effect when you contact us through Caller ID, e-mail headers or signatures, or other communications metadata.|
|Technical information: IP address, browser type and version, operating system.||This information may be provided by your browser during your use of Our Site.|
Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes how we may use your personal data, and our lawful bases for doing so:
|What We Do||What Data Do We Use||Our Lawful Basis|
|Communicating with you.||Identity information, contact information, and technical information.||Legitimate Interests: responding to communcations that you have initiated.|
|Supplying you with information by email, post, or messaging service that you have opted-in-to (you may opt-out at any time by using the contact details in Part 15).||Identity information, contact information, and technical information.||Consent.|
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email, post or messaging service with information, news, and offers on our products and services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.
Third Parties whose content appears on Our Site may use third-party Cookies, as detailed below in Part 14. Please refer to Part 14 for more information on controlling cookies. Please note that we do not control the activities of such third parties, nor the data that they collect and use themselves, and we advise you to check the privacy policies of any such third parties.
We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 15. If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so. In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):
|Type of Data||How Long We Keep It|
|Identity Information: name, title, gender, pronouns.||Two years since last contact.|
|Contact information: address, email address, telephone number.||Two years since last contact.|
|Business information: business name, job title, profession.||Two years since last contact.|
|Technical information: IP address, browser type and version, operating system.||Three months since collection.|
We will store or transfer some of your personal data within the UK. This means that it will be fully protected under the Data Protection Legislation.
We will store or transfer some of your personal data within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the Data Protection Legislation, GDPR, and/or to equivalent standards by law.
We will not share any of your personal data with any third parties for any purposes, subject to the following exception:
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
In addition to your rights under the Data Protection Legislation, set out in Part 5, when you submit personal data via Our Site, you may be given options to restrict our use of your personal data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails and at the point of providing your details).
You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
You may access certain areas of Our Site without providing any personal data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
13. How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”. All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 15.
To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
By using Our Site, you may also receive certain third-party Cookies on your computer or device.
Third-party Cookies are those placed by websites, services, and/or parties other than us. Third-party Cookies are used on Our Site for nothing. For more details, please refer to the table below. These Cookies are not integral to the functioning of Our Site and your use and experience of Our Site will not be impaired by refusing consent to them.
All Cookies used by and on Our Site are used in accordance with current Cookie Law.
Before Cookies are placed on your computer or device, you will be shown a prompt requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended.
Certain features of Our Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown in the table below. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below, but please be aware that Our Site may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.
The following first-party Cookies may be placed on your computer or device:
|Name of Cookie||Purpose||Strictly Necessary|
|No cookies are currently used.|
If you spot a first- or third-party cookie being installed on your computer by this website that is not included in this list, please send a message to the contact email address in Part 15. The first report received in each calendar month for an unlisted cookie will be eligible for a £10 reward. Reports will require confirmation by us before the reward is made.
In addition to the controls that we provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.
It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details:
E-Mail Address: email@example.com.
Postal Address: 4-5 The James Gregory Centre, Campus Two, Aberdeen, AB22 8GU.
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.