Effective date: 1st September 2020

I am an individual, and just like you, I value my privacy. I will always respect your privacy and your right to be forgotten. I have employed an ethical approach to your data privacy.

Collecting personally identifiable information

I do not use this website to collect any personally identifiable information, without your express permission for which I will clearly ask. The only area where such a request will be made is via any contact, purchase or order forms.

Any data that is received in this way is held securely and will not be shared with any third party, at any time, unless required to do so by law.

This privacy notice aims to inform you about how I collect and process any information that I collect from you, or that you provide to us. It covers information that could identify you (“personal information”) and information that could not. In the context of the law and this notice, “process” means collect, store, transfer, use or otherwise act on information. It tells you about your privacy rights and how the law protects you.

I am committed to protecting your privacy and the confidentiality of your personal information. My policy is not just an exercise in complying with the law, but a continuation of my respect for you and your personal information.

I undertake to preserve the confidentiality of all information you provide to me, and hope that you reciprocate.

My policy is designed to comply with the Data Protection Act 2018 (Act) accordingly incorporating the EU General Data Protection Regulation (GDPR).

The law requires me to tell you about your rights and my obligations to you in regard to the processing and control of your personal data. I do this now, by requesting that you read the information provided at http://www.knowyourprivacyrights.org

Except as set out below, I do not share, or sell, or disclose to a third party, any information collected through my website.

1. Data Protection Officer

I have appointed myself as the protection officer (DPO) and am responsible for ensuring that my policy is followed.
If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact our DPO, John Stutely at [email protected].

2. Data I process

I may collect, use, store, and transfer different kinds of personal data about you. I have collated these into groups as follows:
Your identity may include information such as first name, last name, title, and other identifiers that you may have provided at some time.
Your contact information includes information such as billing address, delivery address, email address, telephone numbers, and any other information you have given to me for the purpose of communication or meeting.

Your financial data includes information such as your bank account and payment card details.

Transaction data includes details about payments or communications to and from you and information about products and services you have purchased from me.

Technical data includes your internet protocol (IP) address, browser type, and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website. Your profile includes information such as your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.

Marketing data includes your preferences in receiving marketing from me; communication preferences; responses and actions in relation to your use of my services.

I may aggregate anonymous data such as statistical or demographic data for any purpose. Anonymous data is data that does not identify you as an individual. Aggregated data may be derived from your personal data but is not considered personal information in law because it does not reveal your identity. For example, I may aggregate profile data to assess interest in a product or service. However, if I combine or connect aggregated data with your personal information so that it can identify you in any way, I treat the combined data as personal information and it will be used in accordance with this privacy notice.

3. Special personal information

Special personal information is data 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. It also includes information about criminal convictions and offences. I do not collect any special personal information about you.

4. If you do not provide personal information that I need

Where I need to collect personal data by law, or under the terms of a contract I have with you, and you fail to provide that data when requested, I may not be able to perform that contract. In that case, I may have to stop providing a service to you. If so, I will notify you of this at the time.

The bases on which I process information about you

The law requires me to determine under which of six defined bases I process different categories of your personal information, and to notify you of the basis for each category. If a basis on which I process your personal information is no longer relevant then I shall immediately stop processing your data. If the basis changes then if required by law I shall notify you of the change and of any new basis under which I have determined that I can continue to process your information.

5. Information I process because I have a contractual obligation with you

When you create an account on my website, buy a product or service from me, or otherwise agree to my terms and conditions, a contract is formed between you and us.
In order to carry out my obligations under that contract I must process the information you give us. Some of this information may be personal information.

• I may use it in order to:
• verify your identity for security purposes
• sell products to you
• provide you with my services
• provide you with suggestions and advice on products, services and how to obtain the most from using my website

I process this information on the basis there is a contract between us, or that you have requested I use the information before I enter into a legal contract. I shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.

6. Information I process with your consent

Through certain actions when otherwise there is no contractual relationship between us, such as when you browse my website or ask me to provide you more information about my business, including my products and services, you provide your consent to me to process information that may be personal information. Wherever possible, I aim to obtain your explicit consent to process this information, for example, by asking you to agree to my use of cookies. If you have given me explicit permission to do so, I may from time to time pass your name and contact information to selected associates whom I consider may provide services or products you would find useful.

I continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists.
You may withdraw your consent at any time by instructing me by writing to [email protected]. However, if you do so, you may not be able to use my website or my services further.

7. Information I process for the purposes of legitimate interests

I may process information on the basis there is a legitimate interest, either to you or to us, of doing so.
Where I process your information on this basis, I do after having given careful consideration to:

• whether the same objective could be achieved through other means
• whether processing (or not processing) might cause you harm
• whether you would expect me to process your data, and whether you would, in the round, consider it reasonable to do so

For example, I may process your data on this basis for the purposes of:

• record-keeping for the proper and necessary administration of my business
• responding to unsolicited communication from you to which I believe you would expect a response
• protecting and asserting the legal rights of any party
• insuring against or obtaining professional advice that is required to manage risk
• protecting your interests where I believe I have a duty to do so

8. Information I process because I have a legal obligation

Sometimes, I must process your information in order to comply with a statutory obligation. For example, I may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order. This may include your personal information.

Specific uses of information you provide to us

9. Information relating to your method of payment

Payment information is never taken by me or transferred to either through my website or otherwise.
At the point of payment, you are either:

• transferred to a secure page on the website of PayPal or some other reputable payment service provider. That page may be branded to look like a page on my website, but it is not controlled by me.
  or,
• you may opt to pay by BACS, bank transfer or Faster Payments. In this case, I will send you my bank details for the purposes of payment. I do not have any access to your financial details.

10. Job application and employment

If you send me information in connection with a job application, I may keep it for up to three years in case I decide to contact you at a later date. If I employ you, I collect information about you and your work from time to time throughout the period of your employment. This information will be used only for purposes directly relevant to your employment. After your employment has ended, I will keep your file for six years before destroying or deleting it.

11. Communicating with me

When you contact me, whether by telephone, through my website or by e-mail, I collect the data you have given to me in order to reply with the information you need. I record your request and my reply in order to increase the efficiency of my business. I keep personally identifiable information associated with your messages, such as your name and email address so as to be able to track my communications with you to provide a high-quality service.

12. Complaining

If I receive a complaint, I record all the information you have given to us. I use that information to resolve your complaint. If your complaint reasonably requires me to contact some other person, I may decide to give to that other person some of the information contained in your complaint. I do this as infrequently as possible, but it is a matter for my sole discretion as to whether I do give information, and if I do, what that information is. I may also compile statistics showing information obtained from this source to assess the level of service I provide, but not in a way that could identify you or any other person.

13. Affiliate and business partner information

This is information given to me by you in your capacity as an affiliate of myself or as a business partner. It allows me to recognise visitors that you have referred to me, and to credit to your commission due for such referrals. It also includes information that allows me to transfer the commission to you. The information is not used for any other purpose. I undertake to preserve the confidentiality of the information and of the terms of our relationship. I expect any affiliate or partner to agree to reciprocate this policy.

Use of information I collect through automated systems when you visit my website

14. Cookies

I take an ethical approach to Cookies. When you first visit my website, unlike many webites, I do not ask you whether you wish to use cookies. This website uses a single essential ‘technical’ Cookie. This Cookie is named __cfuid, it is set for security purposes and no personally identifiable information is collected. As it is a technical cookie on which the operation of my website depends, I am not required to provide an opt-out under GDPR.

I use cookies in the following ways:

• to ensure the integrity and security of my website and the data passed within.

I do NOT use cookies to:

• track your personal information
• pass your data to any third party

15. Personal identifiers from your browsing activity

Requests by your web browser to my server for web pages and other content on my website are recorded anonymously. The only data recorded is the page visited and the referring domian, such a as Google, where appropriate. I do not record information such as your geographical location, your Internet service provider or your IP address. Additionally, I do not record information about the software you are using to browse my website, such as the type of computer or device and the screen resolution.

Because of the way I treat your privacy when browsing my website I have no way of identifying you personally.

Disclosure and sharing of your information

16. Information we obtain from third parties

Although I do not disclose your personal information to any third party (except as set out in this notice), I sometimes receive data that is indirectly made up from your personal information from third parties whose services I use.
No such information is personally identifiable to you.

17. Third-party advertising on my website

There is no third-party advertising or re-marketing on my website.

18. Credit reference

To assist in combating fraud, I may share information with credit reference agencies, so far as it relates to clients or customers who instruct their credit card issuer to cancel payment to me without having first provided an acceptable reason to me and given me the opportunity to refund their money.

19. Data may be processed outside the European Union

My website is hosted in the United Kingdom. No data is passed outside of the European Union.

Control over your own information

20. Your duty to inform me of changes

It is important that the personal data I hold about you is accurate and current. Please keep me informed if your personal data changes.

21. Access to your personal information

At any time you may review or update personally identifiable information that I hold about you, by signing in to your account on my website where appropriate.
To obtain a copy of any information that is not provided on my website you should contact e to make that request.
After receiving the request, I will tell you when I expect to provide you with the information, and whether I require any fee for providing it to you.

22. Removal of your information

If you wish me to remove personally identifiable information from my website, you should contact me to make your request.
This may limit the service I can provide to you.

23. Verification of your information

When I receive any request to access, edit or delete personal identifiable information I shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.

Other privacy matters

24. Use of site by children

I do not sell products or provide services for purchase by children, nor do I market to children. If you are under 18, you may use my website only with consent from a parent or guardian I collect limited session data about all users of and visitors to these areas regardless of age, and I anticipate that some of those users and visitors will be children.

25. Encryption of data sent between us

I use Secure Sockets Layer (SSL) certificates to verify my identity to your browser and to encrypt any data you provide me.
Whenever information is transferred between us, you can check that it is done so using SSL by looking for a closed padlock symbol or other trust mark in your browser’s URL bar or toolbar.

26. How you can complain

If you are not happy with my privacy policy or if you have any complaint then you should tell me by writing to [email protected]
If a dispute is not settled then I hope you will agree to attempt to resolve it by engaging in good faith with me in a process of mediation or arbitration.
If you are in any way dissatisfied about how I process your personal information, you have a right to lodge a complaint with the Information Commissioner’s Office (ICO). This can be done at https://ico.org.uk/make-a-complaint/. I would, however, appreciate the opportunity to talk to you about your concern before you approach the ICO.

27. Retention period for personal data

Except as otherwise mentioned in this privacy notice, I keep your personal information only for as long as required by me:

• to provide you with the services you have requested;
• to comply with other law, including for the period demanded by tax authorities;
• to support a claim or defence in court.

28. Compliance with the law

My privacy policy has been compiled so as to comply with the law of every country or legal jurisdiction in which I aim to do business. If you think it fails to satisfy the law of your jurisdiction, I would like to hear from you. However, ultimately it is your choice as to whether you wish to use my website.

29. Review of this privacy policy

I may update this privacy notice from time to time as necessary. The terms that apply to you are those posted here on my website on the day you use my website.
If you have any question regarding my privacy policy, please contact us.

Additional steps that I take to protect your data

To protect the security of this site, and your data, this site uses standard and advanced security features:

• 2048 bit TLS1.3 SSL (Secure Socket Layer data encryption) to encrypt data sent over the internet
• HTTP Security Headers: A+ Rating
• Content Security Policy
• X-XSS-Protection
• HSTS – HTTP Strict Transport Security (HTTPS)
• X-Frame Options
• X-Content-Type-Options
• Referrer Policy
• Global Content Delivery Network (CDN)
• Unmetered mitigation of DDOS attacks
• Web Application Firewall (WAF)
• Lastest TLS 1.3 protocol
• Server-side excludes
• System obfuscation
• Malware scanning
• Brute Force attack protection
• Strong password enforcement
• Blacklist referral for known scammers/hackers