GDPR DATA PRIVACY NOTICE FOR EVRY LTD WEBSITES
We respect your privacy and are determined to protect your personal data. The purpose of this privacy notice is to inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from). We’ll also tell you about your privacy rights and how the data protection law protects you.
1. WHO WE ARE AND IMPORTANT INFORMATION
What is the purpose of this privacy notice?
This privacy notice aims to give you information on how we collect and process your personal data through your use of this website, including any data you may provide through this website when you submit your comments on the information provided on the website.
This website is not intended for children and we do not knowingly collect data relating to children.
You must read this privacy notice together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
Mr P Graves is the controller and responsible for your personal data (collectively referred to as “Evry Ltd”, “we”, “us” or “our” in this privacy notice). Our contact details are 4 Burland Road, Collier Row, Romford, Essex RM5 3RB; firstname.lastname@example.org; 01708 768421. For all data matters contact
Mr P Graves on email@example.com
Evry Ltd is the controller and responsible for this website.
2. THE PERSONAL DATA WE COLLECT ABOUT YOU
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
• Identity Data includes First Name/ Last Name/ Username/ Title/ Age/ Gender.
• Contact Data includes Address/ Email Address/ Telephone Numbers.
• Usage Data includes how you use this website and your feedback comments.
• Technical Data includes Browser Type and Version/ General Location/ Operating System and Platform Devices you use to access this website.
We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any Special Categories of Personal Data about you (this includes details 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). Nor do we collect any information about criminal convictions and offences.
If you fail to provide personal data
If you fail to provide personal data, we will not be able to provide any feedback concerning your comments even where you have given your consent.
3. HOW WE COLLECT YOUR PERSONAL DATA
We use different methods to collect data from you.
• You may give us your Identity, Contact Details and Feedback Data by submitting a Feedback Form or by corresponding with us by post, Freepost, phone, email or otherwise.
• As you interact with our website, we may automatically collect Usage Data and Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see “Cookies” below for further details
4. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
• Legitimate Interest this means the interest of our business in conducting and managing our business to enable us to give you the best service and the most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us at firstname.lastname@example.org
• Consent this means processing your data where it is necessary in order to contact.
• Comply with a legal or regulatory obligation this means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below, in a table format, a description of all the ways we plan to use your personal data, with the legal bases we rely on to do so.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us at email@example.com if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Type of data
Lawful basis for processing including basis of legitimate interest
To register you as a person with an interest in a proposed project; to assign a unique reference; to record your views
(a) Identity (b) Contact
Necessary for our Legitimate Interest (for running our business and to provide your Feedback to relevant parties)
To submit your Feedback to Evry Ltd
(a) Usage Data
Necessary for our Legitimate Interest (for running our business)
To provide a response and further information to you based on your submitted feedback
(a) Identity (b) Contact
To use data analytics to improve the website and to analyse the traffic on the website
(a) Usage Data (b) Technical Data
Necessary for our Legitimate Interest (for the running and development of our business and to measure the relevance of the website)
We do not share your information for Marketing Purposes.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us on firstname.lastname@example.org
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. WHO WE SHARE YOUR PERSONAL DATA WITH
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
• External Third Parties Service
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. INTERNATIONAL TRANSFERS
We do not transfer your personal data outside the European Economic Area (EEA).
7. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. DATA RETENTION
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances you can ask us to delete your data: see Your legal rights below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
9. YOUR LEGAL RIGHTS
Unless subject to an exemption under the data protection laws, you have the following rights with respect to your personal data:
• The right to request a copy of the personal data which we hold about you;
• The right to request that we correct any personal data if it is found to be inaccurate or out of date;
• The right to request your personal data is erased where it is no longer necessary to retain such data;
• The right to withdraw your consent to the processing at any time, where consent was the lawful basis for processing your data;
• The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), where applicable 9i.e. where our processing is based on consent or is necessary for the performance of our contract with you or where we process your data by automated means);
• The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
• The right to object to our processing of personal data, where applicable i.e. where processing is based on our legitimate interests (or in performance of a task in the public interest/exercise of official authority); direct marketing or processing for the purposes of scientific/historical research and statistics).
If you wish to exercise any of the rights set out above, please contact Mr P Graves at email@example.com
No fee required – with some exceptions
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable admin fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
10. CHANGES TO THIS NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
This Privacy Notice was created on 23rd May 2018. From 25th May 2018 there will be changes in data protection laws and we will then be able to respond to some of your requests (for example, a request for the transfer of your personal data). We are still working towards getting our systems ready for some of these changes. Please keep us informed if your personal data changes during your relationship with us. It is important that the personal data we hold about you is accurate and current.
11. QUERIES, REQUESTS OR CONCERNS
To exercise all relevant rights, queries or complaints in relation to this policy or any other data protection matter between you and us, please in the first instance contact Mr P Graves on firstname.lastname@example.org
If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 03031231113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England, UK.