Privacy Policy | ROI index

1. Introduction

1.1

We are committed to protecting the privacy of visitors to our website and users of our services.

1.2

This policy applies wherever we act as the controller of personal data of visitors to our website and users of our services, in other words, where we determine the purposes and means of processing such personal data.

1.3

During your first visit to our website, we ask for your consent to the use of cookies in accordance with the terms of this policy.

2. How We Use Personal Data

2.1

In this Section 2, we set out:

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

(b) the source and category of data, in cases where we did not obtain the data directly from you;

(d) the legal bases for processing.

2.2

We may process data about your use of our website and services (“usage data”). Usage data may include your IP address, geographical location, web browser and browser 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 use of our services.

The source of usage data is Google Analytics. This usage data may be processed for the purpose of analysing the use of our website and services. The legal basis for this processing is consent and our legitimate interests, namely monitoring and improving our website and services.

2.3

We may process information that you publish on our website or through the data you use when using our services (“publication data”). Publication data may be processed for the purposes of publishing and administering our website and services. The legal basis for this processing is consent.

2.4

We may process information contained in any enquiry or questionnaire (“enquiry data”) where such data relates to goods and/or services. The legal basis for this processing is consent.

2.5

We may process information that you provide to us for the purpose of subscribing to our email offers and/or newsletter (“notification data”). Notification data may be processed for the purpose of sending you relevant notifications and/or newsletters. The legal basis for this processing is consent.

2.6

We may process information contained in or relating to any communication that you send to us (“contact data” or “correspondence data”). Correspondence data may include the content of the communication and metadata associated with the communication.

Our website may generate metadata related to communications made through website contact forms. Correspondence data may be processed for the purposes of communicating with you and keeping records. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business, communication with users, and/or the performance of a contract between you and us, and/or taking steps to enter into such a contract.

2.7

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, administrative proceedings or out-of-court proceedings. The legal basis for this processing is our legitimate interests, namely the protection and enforcement of our legal rights, your legal rights and the legal rights of others.

2.8

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.

3. Providing Your Personal Data to Others

3.1

In addition to the specific disclosures of personal data set out in this Section 3, 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.

We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings, administrative proceedings or out-of-court proceedings.

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 accessible via the internet worldwide. 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 procedures, which are designed to help ensure compliance with our legal obligations regarding 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 personal data as follows:

(a) usage data, publication data, enquiry data, notification data and correspondence data will be retained for a maximum period of 10 years.

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. Amendments

6.1

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

6.2

You should occasionally check this page to ensure that you are satisfied with any changes to this policy.

6.3

We may notify you of changes to this policy by email.

7. Your Rights

7.1

In this Section 7, we have summarised the rights that you have under data protection law. Some of these rights are complex and not all details have been included in our summaries. You should therefore read the relevant laws and guidance from regulatory authorities for a full explanation of these rights.

7.2

Your main rights under data protection law are:

(a) the right of access;

(b) the right to rectification;

(d) the right to restrict processing;

(e) the right to object to processing;

(f) the right to data portability;

(g) the right to lodge a complaint with a supervisory authority; and

(h) the right to withdraw consent.

7.3

You have the right to confirm whether we process your personal data and, where we do, to access that data together with certain additional information. This additional information includes details of the purposes of processing, the categories of personal data concerned and the recipients of the personal data.

Provided that the rights and freedoms of others are not affected, we will provide you with a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.

You may request your personal data by contacting us at the email address listed in the contact section.

7.4

You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of processing, to have any incomplete personal data about you completed.

7.5

In certain circumstances, you have the right to the erasure of your personal data without undue delay. These circumstances include cases where the personal data is no longer necessary for the purposes for which it was collected or otherwise processed; you withdraw consent to consent-based processing; you object to processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; or the personal data has been unlawfully processed.

However, there are exclusions from the right to erasure. General exclusions apply where processing is necessary for exercising the right of freedom of expression and information, for compliance with a legal obligation, or for the establishment, exercise or defence of legal claims.

7.6

In certain circumstances, you have the right to restrict the processing of your personal data. These circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require the personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending verification of that objection.

Where processing has been restricted on this basis, we may continue to store your personal data. However, we will otherwise process it only with your consent, for the establishment, exercise or defence of legal claims, for the protection of the rights of another natural or legal person, or for reasons of important public interest.

7.7

You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing allows this.

This applies where processing is necessary for the performance of a task carried out in the public interest or in the exercise of any official authority vested in us, or for the purposes of legitimate interests pursued by us or by a third party.

If you make such an objection and we cannot demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms, or if the processing is not necessary for the establishment, exercise or defence of legal claims, we will stop processing the personal data.

7.8

You have the right to object to the processing of your personal data for direct marketing purposes, including profiling for direct marketing purposes. If you make such an objection, we will stop processing your personal data for this purpose.

7.9

You have the right to object to the processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

7.10

Where the legal basis for the processing of your personal data is:

(a) consent; or

(b) where processing is necessary for the performance of a contract to which you are a party, or in order to take steps at your request before entering into a contract,

and such processing is carried out by automated means, you have the right to receive your personal data in a structured, commonly used and machine-readable format.

However, this right does not apply where it would adversely affect the rights and freedoms of others.

7.11

If you believe that our processing of your personal data violates data protection laws, you have the legal right to lodge a complaint with a supervisory authority responsible for data protection.

You may do so in the EU member state of your habitual residence, place of work or the place of the alleged infringement.

7.12

To the extent that the legal basis for our processing of your personal data is consent, you have the right to withdraw that consent at any time.

7.13

You may exercise any of your rights in relation to your personal data by written notice to us.

8. About Cookies

8.1

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

8.2

Cookies may be either “persistent” cookies or “session” cookies. A persistent cookie is stored by a web browser and remains valid until its set expiry date, unless deleted by the user before the expiry date. A session cookie expires at the end of the user session, when the web browser is closed.

8.3

Cookies usually do not contain any information that personally identifies a user. However, personal information that we store may be linked to information stored in and obtained from cookies.

9. Cookies That We Use

9.1

We use cookies for the following purposes:

(a) authentication – we use cookies to identify you when you visit our website and as you navigate our website;

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

10. Cookies Used by Our Service Providers

10.1

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

10.2

We use Google Analytics to analyse the use of our website. Google Analytics collects information about website use by means of cookies. The information collected in relation to our website is used to create reports about the use of our website.

Google’s privacy policy is available at:
https://policies.google.com/privacy?hl=en

10.3

We use Facebook Pixel to analyse the use of our website. This service uses cookies to ensure that our advertisements are shown to the right people and to create advertising audiences.

You can view the privacy policy of this service provider at:
https://www.facebook.com/privacy/explanation/

11. Managing Cookies

11.1

Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for managing cookies vary depending on the browser and browser version. You can obtain up-to-date information about blocking and deleting cookies via the following links:

(a) Chrome:
https://support.google.com/chrome/answer/95647?hl=en

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

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

(e) Safari:
https://support.apple.com/

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