TransformELT considers that protecting your information is very important and we recognise that you have an interest in how we may collect, use and share such information. This Data Protection Statement outlines how we use and protect your information and states the principles which reflect our commitment to safeguarding that information. Note that this policy is updated for the 2018 introduction of the GDPR.
Data Protection: Our Principles
- Comply with obligations under the UK Data Protection Act 1998, the GDPR of May 2018 and other relevant legislation;
- Keep your personal information and the business you do with us in strict confidence;
- Obtain your personal information lawfully and fairly;
- Maintain appropriate procedures to ensure that personal information in our possession is accurate and, where necessary, kept up to date;
- Choose ethical and legal third party data processing companies when such services are required;
- Maintain appropriate safeguards to protect personal information against loss, theft, unauthorised access, disclosure, copying, use or modification;
- Not sell your personal information.
1.1 We are committed to safeguarding the privacy of our website visitors and service users.
1.2 This policy applies where we are acting as a data controller with respect to the personal data of [our website visitors and service users]; in other words, where we determine the purposes and means of the processing of that personal data.
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. These controls are available by following the link in any mailing you have received from us.
1.5 In this policy, “we”, “us” and “our” refer to TransformELT Ltd. [ For more information about us, see Section 12 below.]
- 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 that you post for publication on our website or through our services (“publication data”). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is consent and/or our legitimate interests, namely the proper administration of our website and business and/or[the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
2.4 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 consent.
2.5 We may process information relating to our customer relationships, including customer contact information (“customer relationship data”). The customer relationship data may include [your name, your employer, your job title or role, your contact details, and information contained in communications between us and you or your employer. The source of the customer relationship data is you or your employer. The customer relationship data may be processed for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications and promoting our products and services to customers. The legal basis for this processing is consent and/or [our legitimate interests, namely the proper management of our customer relationships.
2.6 We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website (“transaction data”). The transaction data may include your contact details, and the transaction details, but we will never process your card or Square details ourselves – these financial transactions are described in 3.1 below. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely the proper administration of our website and business.
2.7 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 consent and/or the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract].
2.8 We may process information contained in or relating to any communication that you send to us (“correspondence data”). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
2.9 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.
2.10 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.
2.11 Please do not supply any other person’s personal data to us, unless we prompt you to do so.
- Providing Your Personal Data to Others
3.1 Data collected on this website for the purposes of paying for services provided bu us is processed by our secure payment processor Square. For more on their privacy and security, please see here.
3.2 We may disclose your personal data to one of our mailing list service provider Mailchimp, with your consent, given at the time of opting in to mailings.
3.3 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 or in an administrative or out-of-court procedure.]
- International Transfers of Your Personal Data
4.1 In this Section 4, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA)].
4.2 We have offices and facilities in the United Kingdom. The European Commission has made an “adequacy decision” with respect to the data protection laws of this country. Transfers to other countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission.
4.3 The hosting facilities for our website are situated in the UK, and managed by SiteGround.
4.4 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.
- 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 In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on our data processing needs.
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.
6.1 We may update this policy from time to time by publishing a new version on our website.
6.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
6.3 We may notify you of significant changes to this policy by email, through our mailing list software (MailChimp), or via an update on this site.
- Your Rights
7.1 In this Section 7, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
7.2 Your principal rights under data protection law are:(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
7.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you 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.
7.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
7.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include 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 some circumstances you have the right to restrict the processing of your personal data. Those 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 personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: 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 is that the 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 the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
7.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
7.9 You have the right to object to our 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 To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, and such processing is carried out by automated means, you have the right to receive your personal data from us 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 consider that our processing of your personal information infringes data protection laws, you have a 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, your 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 information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
7.13 You may exercise any of your rights in relation to your personal data by written notice to us, in addition to the other methods specified in this Section 7.
8.1 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.
8.2 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.
8.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
- Cookies That We Use
- Cookies Used by Our Service Providers
10.4 We use WooCommerce and Square cookies to help you purchase goods and services on our website. During these transaction, we only store the personal information you provide to us in the course of shopping with us, and we never have direct access to any credit or debit card information, nor any information related to payment options. All this data is handled by our secure payment gateway Square (see 3.1 above).
- Managing Cookies
11.1 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?hl=en (Chrome);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(e) https://support.apple.com/kb/PH21411 (Safari); and
(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
11.2 Blocking all cookies will have a negative impact upon the usability of many websites.
11.3 If you block cookies, you will not be able to use all the features on our website
- Our Details
12.1 This website is owned and operated by TransformELT Ltd
12.2 We are registered in England and Wales under registration number 010684195
12.3 Our principal place of business is at 25 Robin Hood Road, Norwich, NR4 6BS, UK
12.4 You can contact us:
– by post, at the address in 12.3 above
– using our website contact form
– by telephone using the number found on our contact page
– by email using the address found on our contact form
– by WhatsApp using the link found on our contact form
- Data Protection Officer
13.1 Our Data Protection Officer is Sarah Mount smount@transformELT.com
- External Libraries
14.1 Our website uses external libraries to add design elements and functionality. These external libraries include (but may not be limited to): JQuery from the Google CDN, Font Awesome from Max CDN and Vue.js from UNPKG. Each of these sources is GDPR compliant. No personal information is sent to any of these external sources at any point in your browsing of our website.
Cookies and How they Benefit You
- Make our website work as you’d expect
- Remember your settings during and between visits
- Improve the speed/security of the site
- Continuously improve our website for you
- Enable you to purchase goods and services from us
- Collect any personally identifiable information (without your express permission)
- Collect any sensitive information (without your express or implicit permission, e.g. during purchasing transactions)
- Pass personally identifiable data to third parties (without your express or implicit permission, e.g. during purchasing transactions)
- Pay sales commissions
OUR OWN COOKIES
The cookies we set provide the following functionality:
- Making our contact forms work
- Remembering if you have accepted our terms and conditions
There is no way to prevent these cookies being set other than to not use our site.
THIRD PARTY COOKIES
Social Network Cookies
So you can easily “Like” or share our content on the likes of Facebook and Twitter, and also have direct access to some of our social media channels, we have included sharing buttons on our site, and embedded social media posts and YouTube videos. Cookies may be set by any of the following services, but they do not identify you personally.
Cookies are set by: Facebook, LinkedIn, Flickr and YouTube. The privacy implications on this will vary from social network to social network and will be dependent on the privacy settings you have chosen on these networks. Disabling these cookies will likely break the functions offered by these third parties.
Mailing List Cookies
If you visit our mailing list page, MailChimp will set four cookies which it needs to help you sign up for our mailings.
Cookies are set by: MailChimp. Disabling these cookies will break the functions offered by MailChimp.
Anonymous Visitor Statistics Cookies
Cookies are set by: Google Analytics.
Shopping Statistics Cookies
Cookies are set by: WooCommerce, Square.
Turning Cookies Off
You can usually switch cookies off by adjusting your browser settings to stop it from accepting cookies (learn how here). Doing so however will likely limit the functionality of our’s and a large proportion of the world’s websites as cookies are a standard part of most modern websites. It may be that you concerns around cookies relate to so called “spyware”. Rather than switching off cookies in your browser you may find that anti-spyware software achieves the same objective by automatically deleting cookies considered to be invasive. Learn more about Spyware software here.