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Appendix 1: Legal Bases of Processing

Categories of Personal data processing 

1. Personal details such as your name, gender, age, date of birth, email address, postal address, telephone or mobile number and identifiers such as passport number;

2. Family, lifestyle and social circumstances such as details about current marriage and partnerships and marital history, details of family and dependents;

3. Technical information and other information about your visits to our website/Pensions Portal.

Processing Purpose

1. To notify you about our services and changes to our services; T conduct member satisfaction surveys; For internal record keeping.

2. To carry out our obligations arising from any agreement that we have with, or concerning, you and to provide you with the information, benefits and services that you request from us.

3. To improve the services we provide to you and the way our website and Pensions Portal works.

Legal Basis

1. Performance of a contract. Legitimate interest to run an effective business.

2. Performance of a contract. Legitimate interests to run an effective business.

3. Legitimate interest to ensure our website and Pensions Portal is operating effectively.

Cookies

Cookies may be either “persistent” cookies or “session” cookies. A persistent cookie consists of a text file sent by a web server to a web browser, which will be stored by the browser and will remain valid until its set expiry date (unless deleted by the user before the expiry date). A session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

[Strictly Necessary Cookies. These Cookies are required for the operation of the website. They include, for example, Cookies that enable users to log into secure areas of the website.]

[Analytical/performance Cookies. They allow website providers to recognise and count the number of visitors and to see how visitors move around a website when they are using it. This helps website providers to improve the way the website works, for example, by ensuring that users are finding what they are looking for easily.]

[Functionality Cookies. These are used to recognise users when users return to the website. This enables website providers to personalise content for you, greet users by name and remember a user’s preferences (for example, a user’s choice of language or region).]

[Targeting Cookies. These Cookies record a user’s visit to the website, the pages a user has visited and the links a user has followed. Website providers will use this information to make a website more relevant to users. Website providers may also share this information with third parties for this purpose.]

1. Introduction

1.1 We are committed to safeguarding the privacy of our website visitors.

1.2 This policy applies where we are acting as a data controller with respect to the personal data of our website visitors, in other words, where we determine the purposes and means of the processing of that personal data.

1.3 We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website and services, we will ask you to consent to our use of cookies when you first visit our website.

1.4 Our website incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can specify whether you would like to receive direct marketing communications and limit the publication of your information.

1.5 In this policy, “we”, “us” and “our” refer to  Colourpoint Litho Limited t/a Vidioh.

2. How we use your personal data

2.1 In this Section 2 we have set out:

(a) the general categories of personal data that we may process;

(b) the purposes for which we may process personal data; and

(c) the legal bases of the processing.

2.2 We may process data about your use of our website and services “usage data“. The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.

2.3 We may process information contained in any enquiry you submit to us regarding goods and/or services (“enquiry data“). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.

2.4 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data“). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is our legitimate interests, namely communications with our website visitors and service users.

2.5 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

2.6 In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data]where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

2.7 Please do not supply any other person’s personal data to us, unless we prompt you to do so.

3. Providing your personal data to others

3.1 We may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

4. International transfers of your personal data

4.1 You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

5. Retaining and deleting personal data

5.1 This Section 5 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

5.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

5.3 We will retain your personal data as follows:

(a) usage data will be retained for a minimum period of 3 months following the date of collection, and for a maximum period of 6 months following that date;

(b) enquiry data will be retained for a minimum period of 3 months following the date of the enquiry, and for a maximum period of 1 year following that date];

5.4 Notwithstanding the other provisions of this Section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

6. Your rights

6.1 In this Section 6, we have listed the rights that you have under data protection law.

6.2 Your principal rights under data protection law are:

(a) the right to access – you can ask for copies of your personal data;

(b) the right to rectification – you can ask us to rectify inaccurate personal data and to complete incomplete personal data;

(c) the right to erasure – you can ask us to erase your personal data;

(d) the right to restrict processing – you can ask use to restrict the processing of your personal data;

(e) the right to object to processing – you can object to the processing of your personal data;

(f) the right to data portability – you can ask that we transfer your personal data to another organisation or to you;

(g) the right to complain to a supervisory authority – you can complain about our processing of your personal data; and

(h) the right to withdraw consent – to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.

6.3 These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by visiting https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.

6.4 You may exercise any of your rights in relation to your personal data [by written notice to us, using the contact details set out below].

7. About cookies

7.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

7.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

7.3 Cookies do not typically contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.

8. Cookies that we use

8.1 We use cookies for the following purposes:

(a) authentication and status – we use cookies to identify you when you visit our website and as you navigate our website, and to determine if you are logged into the website;

(b) personalisation – we use cookies to store information about your preferences and to personalise the website for you;

(c) analysis – we use cookies to help us to analyse the use and performance of our website and services; and

(d) cookie consent – we use cookies to store your preferences in relation to the use of cookies more generally.

9. Cookies used by our service providers

9.1 Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

9.2 We use Google Analytics. Google Analytics gathers information about the use of our website by means of cookies. The information gathered is used to create reports about the use of our website. You can find out more about Google’s use of information by visiting https://www.google.com/policies/privacy/partners/ and you can review Google’s privacy policy at https://policies.google.com/privacy

10. Managing cookies

10.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

(a) https://support.google.com/chrome/answer/95647 (Chrome);

(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);

(c) https://help.opera.com/en/latest/security-and-privacy/ (Opera);

(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);

(e) https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac (Safari); and

(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).

10.2 Blocking all cookies will have a negative impact upon the usability of many websites.

10.3 If you block cookies, you will not be able to use all the features on our website.

11. Amendments

11.1 We may update this policy from time to time by publishing a new version on our website.

11.2 You should check this page occasionally to ensure you are happy with any changes to this policy.

12. Our details

12.1 This website is owned and operated by MB3 Vidioh Ltd t/a Vidioh.

12.2 We are registered in England and Wales under registration number 13148053 and our registered office is at Units A&B, Wessex Industrial Park, Wessex Road, Bourne End, Buckinghamshire, SL8 5DT, United Kingdom.

12.3 Our principal place of business is at Units A&B, Wessex Industrial Park, Wessex Road, Bourne End, Buckinghamshire, SL8 5DT, United Kingdom.

12.4 You can contact us

(a) by post, to the postal address given above;

(b) using our website contact form;

(c) by telephone, on the contact number published on our website; or

(d) by email, using the email address published on our website.

13. Data protection officer

13.1 Our data protection officer’s contact details are: Alicia Phelan.

Contact

If you have any questions, comments or requests regarding any aspect of this Privacy Notice, please do not hesitate to contact us at:

By post: Colourpoint Litho Limited t/a Vidioh. Units A&B, Wessex Industrial Park, Wessex Road, Bourne End, Bucks SL8 5DT, United Kingdom

By email: openyoureyes@vidioh.co.uk

By phone: from within the UK:+44 (0) 1628 880 880

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