Privacy Policy

Version: 3.0
Date: 24/05/18

Introduction

We are committed to protecting and respecting your data security and privacy and take all reasonable steps to ensure the security or your data.

We promote and support modern encryption, security and privacy practices wherever possible and implement functionality where possible to make these available to you.

Who We are

Edapt (UK) Limited, a company registered in England and Wales with company number 07830046 and whose registered office is at 111 Piccadilly, Piccadilly, Manchester, M1 2HY (We, Us, Our).

ICO Registration

We are the data controller and are registered with the Information Commissioner’s Office as such with registration number Z3268259.

Policy Summary

This Policy, together with any other documents referred to on www.edapt.org.uk or www.support.edapt.org.uk (Our Sites) set out the basis on which any personal data We collect from you, or that you provide to Us, will be processed by Us for the purpose of any and all applicable data protection legislation in force from time to time including but not limited to the Data Protection Act 2018, the Regulation of Investigatory Powers Act 2000, the Telecommunications (Lawful Business Practice) (Interception of Communications) Regulations 2000 (SI 2000/2699), the Electronic Communications Data Protection Directive (2002/58/EC), the Privacy and Electronic Communications (EC Directive) Regulations 2003 (SI 2426/2003) and any replacement legislation and all applicable laws and regulations relating to the processing of personal data and privacy, including where applicable the guidance and codes of practice issued by the Information Commissioner or any other supervisory authority, and the equivalent of any of the foregoing in any relevant jurisdiction (DP Legislation).

Please read the following carefully to understand Our views and practices regarding your personal data and how We will treat it. By continuing to use Our Sites or any of the functionalities displayed on them you are accepting and consenting to the practices described in this Policy.

Changes to this Policy and your duty to inform Us of Changes

This version was last updated on 24/05/18 and historic versions can be accessed be contacting Us. Any changes We may make to this Policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to this Policy.

It is important that the personal data We hold about you is accurate and current. Please keep Us informed if your personal data changes during your relationship with Us.

Information you give Us

You may give Us information about you by filling in forms on Our Sites or by corresponding with Us in any way. This includes information you provide to Us when you subscribe to Our service, access casework, or any way in which you interact with Us via Our Sites or social media platforms, enter a competition, promotion or survey, or use any services from time to time being offered or provided through Our Sites.

In order to provide Our subscription and casework services to you, the information you give Us may include without limitation your name, address, e-mail address and phone number, financial and credit card information, subscription details, lifestyle and social circumstances, family and associate details, education and employment details, racial or ethnic origin, religious or other beliefs of a similar nature, trade union membership, physical or mental health details, personal description and photograph.

Information We collect about you

Whenever you visit Our Sites We may automatically collect the following information:

technical information, including the Internet protocol (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 Uniform Resource Locators (URLs) clickstream to, through and from Our Sites (including date and time); products 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 and any phone number used to call Us.

Information We receive from other sources

We may receive information about you if you use any of the other websites We operate from time to time or the other services We provide. We may also work closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, survey and research organisations, professional advisors, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.

How We use your information

Information you give to Us. We will use this information:

to carry out Our obligations to you under any contract and to provide you with the information, products and services that you request or to notify you of any changes to them;
to maintain Our accounts and records, undertake research and to support and manage Our employees;
to provide you with information about other products and services We offer that are similar to those that you have already purchased or enquired about (where and to the extent that you have positively opted-in to receive the same);
(where and to the extent that you have positively opted-in to receive the same) to provide you, or permit selected third parties to provide you, with information about products or services We feel may be of interest to you or which are similar to those which you have already purchased but please be aware that We do not provide third parties with direct and unfettered access to your information;
to ensure that content from Our Sites is presented in the most effective manner for you and for your computer.

Information We collect about you. We will use this information:

to administer Our Sites and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
to improve Our Sites to ensure that content is presented in the most effective manner for you and for your computer;
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 Sites safe and secure;
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 Sites about products 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 Us this information and the combined information for the purposes set out above (depending on the types of information We receive and where applicable where and to the extent that you have positively opted-in to receive the same).

Where and to the extent that you have positively opted-in to permit Us to do so, We may share your personal information with any member of Our group from time to time, as defined in the Companies Act 2006.

Where and to the extent that you have positively opted-in to permit Us to do so, We may share your information with selected third parties including:

Business partners, suppliers and sub-contractors for the performance of any contract We enter into with them or you.
Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. Analytics and search engine providers that assist Us in the improvement and optimisation of Our Sites.
Credit reference agencies for the purpose of assessing your credit score where this is a condition of Us entering into a contract with you.

We may disclose your personal information to third parties:

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, where and to the extent that you have positively opted-in to permit Us to do so.
Where We are required to by law, or for the purposes of fraud protection and credit risk reduction.

Cookies

Our Sites use cookies to distinguish you from the other users and helps Us to provide you with a good experience and improve Our Sites. You can read more about the cookies We use at www.edapt.org.uk/cookie-policy

You can disable cookies in your browser if you wish to, although this may mean that some features of Our Sites will not work as they should.

How We transport and store your data

When you access Our sites, We transport all personal data, including payment information, using modern and best practice encryption technologies. This includes Secure Socket Layers (SSL/TLS), Once We have received your information, We store your data on secure servers and use strict procedures and security features to try to prevent unauthorised access.

Where possible we store data within the European Economic Area (EEA) however the data that We collect from you may be transferred to, and stored at, a destination outside the EEA. It may also be processed by staff operating outside the EEA who work for Us or for one of Our suppliers. Such staff maybe engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy and in the event that this ever becomes necessary shall ensure that this is carried out subject to a Data Transfer Agreement for compliance with the DP Legislation.

We understand that data privacy and security is incredibly important and We do take significant and necessary precautions to ensure that your data is secure and to recognise and then mitigate the risks to security and privacy, such as using modern encryption, two-factor authentication and other methods. However, like any website, it is not possible to 100% guarantee the security of any data transmitted or stored electronically.

Your responsibilities

Where We have given you (or where you have chosen) a password which enables you to access certain parts of Our Sites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

How Long We Keep Your Personal Data

We do not hold any personal data longer than necessary, having considered the purposes for processing.

Your rights

If you believe that any of the personal information that We hold about you is incorrect, you have the right to ask Us to rectify that information at any time.

You may also have the right, in certain circumstances, to request that We delete your personal information, to block any further processing of your personal information or to object to the processing of your personal information. There are some specific circumstances where these rights do not apply and We can refuse to deal with your request.

Where you have positively opted-in you have the right to ask Us not to continue to process your personal data for marketing purposes.

You can exercise your right to prevent such continued processing by contacting Us at [email protected].

If We are processing your personal information based upon your consent (e.g. as part of our marketing or promotional activities), you have the right to withdraw your consent at any time.

If you require any further information about your right to rectification, erasure, restriction of or object to processing or you wish to withdraw your consent please contact Us at [email protected].

Our Sites may, from time to time, contain links to and from third party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that We do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

If you think Our collection or use of personal information is unfair, misleading or inappropriate or if you have concerns about the security of your personal information, you also have the right to make a complaint to the Information Commissioner’s Office. You can contact the Information Commissioner’s Office at the following address:

Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.

Access to your information

You can find out if We hold any personal information about you by making a ‘subject access request’ under the DP Legislation. If We do hold information about you, We will:

Give you a description of it;
Tell you why We are holding;
Tell you who it has been disclosed to; and
Let you have a copy of the information in an intelligible form.

You may also have the right for your personal information to be transmitted electronically to another organisation in certain circumstances.

You can request access to the information we hold about you at any time by contacting us at [email protected].

Contact

Questions, comments and requests regarding this Policy are welcomed and should be addressed to [email protected]