Last revised: 25th May 2018.
For the purpose of the General Data Protection Regulations 2018 (GDPR), the data controller and data processor is C 2 Zero Ltd (we, us or our) of 2nd Floor, Hygeia House, 66 College Road, Harrow, Middlesex HA1 1BE.
Questions, comments and requests regarding this policy are welcomed and should be addressed to firstname.lastname@example.org.
The privacy and security of your personal information is very important to us. We want to assure you that your information will be properly managed and protected. The below outlines how we may collect, use and store your data and the rights you have to access all information we hold on you, and edit or remove it from our database.
Information we may collect
- Information you provide: This includes information you supply when you register on our site, purchase any job advertisement or directory listing, make a comment on a news article, participate in a survey or enter a competition, or correspond with us by phone, e-mail or otherwise. The information you give us may include your name, address, e-mail address and phone number, business details, and financial and credit card information.
- Information we collect about you: With regard to each of your visits to our site we may automatically collect the following information: technical information, including the IP address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; information about your visit, including the full URL clickstream to, through and from our site (including date and time); pages you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page;
- Information we receive from other sources: We may receive information about you if you use any other website we operate or other services we provide. We also work closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, analytics providers and search information providers) and may receive information about you from them.
How we use the information we gather
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:
- where you have given consent;
- to comply with our legal and regulatory obligations;
- for the performance of a contract with you or to take steps at your request before entering into a contract; or
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
We typically use information held about you in the following ways:
Information you give to us: We will use this information:
- to correspond with you;
- to provide our services to you ;
- to take payment from you for the provision of our services
- customer service;
- to register you and set you up on our site to enable you to access the services we provide;
- management of your account with us;
- to enable us to conduct checks to identify you and verify your identity;
- gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies;
- ensuring business policies are adhered to, e.g. policies covering security and internet use;
- preventing unauthorised access and modifications to systems;
- to display details about your business, for example in a Business Directory Listing or Promotional Listing on our site and/or other sites we operate that you opt to advertise on. These may include your business name and address, e-mail and web address, and the products and/or services you offer. You may edit or request removal of such information at any time by contacting us or by logging in to your ActSmart account;
- to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
- to provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about. You must opt in to receive these communications at the point of registration and you can opt out at any time;
- to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you by telephone and e-mail. If you are an existing customer, we will only contact you by electronic means with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you. If you are a new customer, and where we permit selected third parties to use your data (if you have opted in to this type of data processing), we (or they) will contact you by electronic means only if you have consented to this. If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, simply do not opt in to receive this where we collect your data or follow the instructions to unsubscribe in the relevant communication or through your ActSmart account;
- to notify you about changes to our service;
- to ensure that content from our site is presented in the most effective manner for you and for your computer.
Information we collect about you: We will use this information:
- to provide our services to you;
- to allow you to participate in interactive features of our service, when you choose to do so;
- as part of our efforts to keep our site safe and secure;
- to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
- to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
- to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.
Information we receive from other sources: We may combine this information with information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).
Special Category Personal Data
Special category person data includes personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership; genetic and biometric data (when processed to uniquely identify an individual); and data concerning health, sex life or sexual orientation.
Where we process special category personal data, we will also ensure we are permitted to do so under data protection laws, for example only where:
- we have your explicit consent;
- the processing is necessary to protect your (or someone else’s) vital interests where you are physically or legally incapable of giving consent; or
- the processing is necessary to establish, exercise or defend legal claims.
Disclosure of your information
You may request the personal information we hold on you at any time. You also have the right to request we edit or remove this information from our databases and published sites.
We may share your information with:
- Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them;
- Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers, but we may provide them with aggregate information about our users. We may also use such aggregate information to help advertisers reach the kind of audience they want to target;
- Analytics and search engine providers that assist us in the improvement and optimisation of our site;
- In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
- If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply any contract between us or other terms on our site; or to protect us, our customers or others.
How we store and protect your data
All of the information we hold about you is stored securely on our secure servers. Any payment transactions will be encrypted using SSL technology. Information may be transferred to and processed by staff operating outside the UK and/or EEA, as applicable, who work for us or for one of our suppliers. By submitting your personal data, you agree to this transfer, storing or processing.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
- The right to be informed.
- The right of access.
- The right to rectification.
- The right to erasure.
- The right to restrict processing.
- The right to data portability.
- The right to object.
- Rights in relation to automated decision making and profiling.
If you have a concern about the way we are handling your information you have the right to raise a concern with the Information Commissioner’s Office (ICO).
Retention of your data
We will not keep your personal data for longer than necessary. Different retention periods apply for different types of personal data. When it is no longer necessary to keep your personal data, we will delete or anonymise it.
If you have submitted your personal information for the purpose of applying for a job your data will be retained for no longer than is necessary. Once the job has expired your details will be made available to the employer for no more than 90 days after which time all your personal information will be removed unless you have opted in receive any further communications from us at the point of registration.
If you are a business your data will be retained so that we can maintain an up to date businesses directory. You may request to have your data removed from the public domain or deleted from our data records altogether at any time by contacting us. This will result in your business no longer being displayed on our business directory and you will have to register you business again to opt back in.
Third party links
Withdrawal of consent
Individuals must give consent for their data to be processed in certain ways, and that individual may withdraw their consent whenever they want. If you have provided us with your consent to process your data, for the purpose of using our services or displaying your business on our public directory, you have the right to withdraw this at any time. You can do this at any time by changing your contact preferences in your ActSmart account or by contacting us at email@example.com. We will fulfil this request within 30 days. If you do not opt in to receive communications please note we will still send you important information such as invoices or payment receipts.
What are cookies and how do they work?
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer when you access our site. Cookies contain information that is transferred to your computer’s hard drive.
We use the following cookies:
Strictly necessary cookies: These are cookies that are required for the operation of our site.
Analytical/performance cookies: They allow us to recognise and count the number of visitors and to see how visitors move around our site when they are using it. This helps us to improve the way our site works, for example, by ensuring that users are finding what they are looking for easily.
Functionality cookies: These are used to recognise you when you return to our site. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
Our site uses the following cookies for the specified purposes:
Expires after 1 year.No personal information is stored in this cookie.
PHP session cookie
To store a simple message when a form is submitted that can be displayed on a different page.For example, if an enquiry form is completed incorrectly, a message will be stored and presented to the user to indicate the errors in the submission.
When an enquiry form is submitted successfully, a message is stored and presented to the user thanking them for their enquiry.
Expires when the browser is closed.No personal information is stored in this cookie.
These help us measure and improve the performance of our site.
Google stores the information collected on servers in the United States. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf.Google will not associate your IP address with any other data held by Google.
These cookies expire between 10 minutes and 2 years after they are set.
For more information visit Google Analytics.
All cookies used on our site are ‘first party’ cookies, meaning they can only be read back from our site. We do not use ‘third party’ cookies which would permit other websites to read or access information set by our site.
Controlling or deleting cookies
How to make a complaint
Please contact us if you have any query or concern about our use of your information (see above “Contact us”). We hope we will be able to resolve any issues you may have.
You also have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk), or your relevant supervisory authority, as applicable. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.