Driving Lessons in Darlington, Newton Aycliffe,

Bishop Auckland, Durham and surrounding areas.                      

Cunningham Driving School                                                                                                       

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Data protection policy (GDPR compliant)

 

Aim and scope of policy

This policy applies to the processing of personal data in manual and electronic records kept by Cunningham Driving School in connection with the business operations and function as described below. It also covers the company’s response to any data breach and other rights under the General Data Protection Regulation.

 

This policy applies to the personal data of our/my customers, whether they are provisional licence holders or have full licence entitlement to drive. These are referred to in this policy as relevant individuals or clients.

 

“Personal data” is information that relates to an identifiable person who can be directly or indirectly identified from that information, for example, a person’s name, driving licence number, postal address and location, telephone number or an online identifier. It can also include pseudonymised data.

 

“Special categories of personal data” is data which relates to an individual’s health, sex life, sexual orientation, race, ethnic origin, political opinion, religion, and trade union membership. It also includes genetic and biometric data (where used for ID purposes). At present, my company does not hold or collect any special categories of personal data.

 

“Criminal offence data” is data which relates to an individual’s criminal convictions and offences. At present, my company does not hold or collect any special categories of personal data.

 

“Data processing” is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by manual or automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

 

Cunningham Driving School makes a commitment to ensuring that personal data, including special categories of personal data and criminal offence data (where applicable) is processed in line with GDPR and domestic laws and other related, policies. Where third parties process data on behalf of Cunningham Driving School, the company will ensure that the third party takes such measures in order to maintain the company’s commitment to protecting data. In line with GDPR, Cunningham Driving School understands that it will be accountable for the processing, management and regulation, and storage and retention of all personal data held in the form of manual records and/or on electronic devices.

 

Types of data held

Personal data is kept in personnel files or within Cunningham Driving School record keeping systems. The following types of data may be held by Cunningham Driving School, as appropriate, on relevant individuals or clients:

 

•Clients name

•Clients address

•Clients phone number(s)

•Clients driving licence number

•A clients signed copy of the driving school’s terms & conditions

•Clients progress records and reflective logs

•A clients number of unsuccessful attempts at either the theory or practical test

•The date a client started and left the driving school and stopped using the services of my driving school

 

 

Relevant individuals should refer to Cunningham Driving School privacy policy notice for more information on the reasons for its processing activities, the lawful bases it relies on for the processing and data retention periods including erasure policy.

 

Data protection principles

All personal data obtained and held by the Cunningham Driving School will:

 

•be processed fairly, lawfully and in a transparent manner

•be collected for specific, explicit, and legitimate purposes

•be adequate, relevant and limited to what is necessary for the purposes of processing

•be kept accurate and up to date. Every reasonable effort will be made to ensure that inaccurate data is rectified or erased without delay

•not be kept for longer than is necessary for its given purpose

•be processed in a manner that ensures appropriate security of personal data including protection against unauthorised or unlawful processing, accidental loss, destruction or damage by using appropriate technical or organisation measures

•where relevant, comply with the relevant GDPR procedures for international transferring of personal data.

 

In addition, personal data will be processed in recognition of an individuals’ data protection rights, as follows:

 

•the right to be informed

•the right of access

•the right for any inaccuracies to be corrected (rectification)

•the right to have information deleted (erasure)

•the right to restrict the processing of the data

•the right to object to the inclusion of any information

•the right to regulate any automated decision-making and profiling of personal data

•the right to data portability

 

Procedures

Cunningham Driving School has taken the following steps to protect the personal data of its clients, which it holds or to which it has access:

 

It appoints specific responsibilities for:

•the processing and controlling of data

•the comprehensive reviewing and auditing of its data protection systems and procedures

•overviewing the effectiveness and integrity of all the data that must be protected.

 

There are clear lines of accountability for these different roles, Cunningham Driving School.

 

•can provide upon request information to its clients on their data protection rights, how it uses their personal data, and how it protects it. The information includes the actions clients can take if they think that their data has been compromised in any way.

•can account for all personal data it holds on clients, where it comes from, who it is shared with and who it might be shared with.

•carries out risk assessments as part of its reviewing activities to identify any vulnerabilities in its personal data handling and processing, and to take measures to reduce the risks of mishandling and potential breaches of data security. The procedure includes an assessment of the impact of both use and potential misuse of client’s personal data.

•recognises the importance of seeking individuals’ consent for obtaining, recording, using, sharing, storing and retaining their personal data, and regularly reviews its procedures for doing so.

•understands that consent must be freely given, specific, informed and unambiguous. Cunningham Driving School will seek consent on a specific and individual basis where appropriate. Full information will be given regarding the activities about which consent is sought. Relevant individuals have the absolute and unimpeded right to withdraw that consent at any time.

•has the appropriate mechanisms for detecting, reporting and investigating suspected or actual personal data breaches, including security breaches? It is aware of its duty to report significant breaches that cause significant harm to the affected individuals to the affected individual and/or to the Information Commissioner, and is aware of the possible consequences.

 

Access to data

Relevant individuals have a right to be informed whether Cunningham Driving School processes personal data relating to them and to access the data that Cunningham Driving School holds about them. Requests for access to this data will be dealt with under the following summary guidelines:

 

•a form on which to make a subject access request is available from Cunningham Driving School

 

The request should be made to Cunningham Driving School.

Cunningham Driving School will not charge for the supply of data unless the request is manifestly unfounded, excessive or repetitive, or unless a request is made for duplicate copies to be provided to parties other than its clients making the request. Cunningham Driving School will respond to a request without delay. Access to data will be provided, subject to legally permitted exemptions, within one month as a maximum. This may be extended by a further two months where requests are complex or numerous.

 

Client must inform Cunningham Driving School immediately if they believe that their data is inaccurate, either as a result of a subject access request or otherwise. Cunningham Driving School will then take immediate steps to rectify the information.

 

For further information on making a subject access request, clients should refer to our subject access request policy, which is available from Cunningham Driving School.

 

 

Data security

Cunningham Driving School adopts procedures designed to maintain the security of data when it is stored and transported. More information can be found in the data transfer security policy, available from Cunningham Driving School.

 

In addition Cunningham Driving School :

 

•ensures that all files or written information of a confidential nature are stored in a secure manner and are only accessed by people who have a need and a right to access them.

•ensures that all files or written information of a confidential nature are not left where they can be read by unauthorised people.

•checks regularly on the accuracy of data being entered into computers or paper-based record keeping systems.

 

Where personal data is recorded on any device or means, it should be protected by:

 

•where data is recorded on such devices that such device(s) is password protected.

•ensuring that electronic devices or paper-based record keeping systems are not left lying around where they can be stolen.

 

Breach notification

Where a data breach is likely to result in a risk to the rights and freedoms of individuals, it will be reported to you and depending on the severity, also to the Information Commissioner within 72 hours of the company becoming aware of it and may be reported in more than one instalment.

 

Individuals will be informed directly in the event that the breach is likely to result in a high risk to the rights and freedoms of that individual.

 

Cunningham Driving School

21 Forster Close,

Newton Aycliffe,

County Durham

Dl5 4XJ

07879492116

Policy on data subject/client’s rights (GDPR compliant)

 

 

Aim and scope of this policy

Cunningham Driving School may process certain types of data for business operations purposes. Cunningham Driving School is fully aware of its obligations under the General Data Protection Regulation (GDPR) to process data lawfully and to ensure that the rights of data subjects, as set out in GDPR, are observed correctly. This policy sets out the rights of the aforementioned individuals as data subjects and the processes which should be followed in the event that the data subject wishes to exercise any such right.

 

Data subject rights

Under GDPR, you have the following rights in relation to your data:

 

•the right to be informed

•the right of access

•the right for any inaccuracies to be corrected

•the right to have information deleted

•the right to restrict the processing of the data

•the right to portability

•the right to object to the inclusion of any information

•the right to regulate any automated decision-making and profiling of personal data.

 

The right to be informed

You have the right to be told how Cunningham Driving School processes your data and the reasons for the processing. In order to provide this information to you, Cunningham Driving School has a privacy notice to explain what data we collect about you, how we collect and process it, what we process it for and the lawful basis which permits us to process it. You can obtain a copy of the privacy notice, at no cost, upon request to Cunningham Driving School.

 

If Cunningham Driving School intends to use data already collected from you for a different reason than that already communicated i.e. for marketing purposes, you will be informed of the new reason in advance and be given the decision to opt-out.

 

The right of access

You have the right to access your personal data which is held by Cunningham Driving School. More information on this is available in our Subject Access Request policy which is available from Cunningham Driving School upon request.

 

The right for data to be corrected

One of the fundamental principles underpinning data protection is that the data Cunningham Driving School processes about you will be accurate and up to date. You have the right to have your data corrected if it is inaccurate or incomplete.

 

If you wish to have your data rectified, you should do so by getting in touch with us and informing us what data you would like rectified.

 

Cunningham Driving School will respond to a data rectification request within one month. Where the data rectification request is complex, then we may extend the timescale for response from one month to three months. If this is the case, we will write to you within one month of receipt of the request explaining the reason for the extension.

 

If the response to your request is that Cunningham Driving School will take no action, you will be informed of the reasons for this and of your right to complain to the ICO.

 

Where any data which has been rectified was disclosed to third parties in its unrectified form, Cunningham Driving School will inform the third party of the rectification where possible. Cunningham Driving School will also inform you of the third parties to whom the data was disclosed.

 

The right to have information deleted

You have the right to have your data deleted and removed from any of our systems where there is no compelling business reason for Cunningham Driving School to continue to process it.

 

You have a right to have your data deleted in the following circumstances:

 

•where the personal data is no longer necessary in relation to the purpose for which Cunningham Driving School originally collected or processed it.

•where you have withdrawn your consent to the continued processing of the data and there is no other lawful basis for Cunningham Driving School to continue processing the data.

•where you object to the processing and Cunningham Driving School has no overriding legitimate interest to continue the processing.

•the personal data has been unlawfully processed.

•the personal data has to be deleted due to a legal obligation..

 

If you wish to make a request for data deletion, then please contact us.

 

Where the data which is to be deleted has been shared with third parties, Cunningham Driving School will inform those third parties where this is possible. However, where this notification will cause a disproportionate effect on Cunningham Driving School, this notification may not be carried out.

 

The right to restrict the processing of data

You have the right to restrict the processing of your data in certain circumstances. Restricting Cunningham Driving School from processing your data means that we will continue to hold the data but will stop processing it.

 

Cunningham Driving School will be required to restrict the processing of your personal data in the following circumstances:

 

•where you tell Cunningham Driving School that the data it holds on you is not accurate. Where this is the case, we will stop processing the data until we have taken steps to ensure that the data is accurate.

•when the data has been processed unlawfully.

•where Cunningham Driving School no longer need to process the data but you need the data in relation to a legal claim.

 

If you wish to make a request for data restriction, then please contact us informing us what data you would like to be restricted.

 

Where data processing is restricted, Cunningham Driving School will continue to hold the data but will not process it unless:

 

•you consent to the processing.

•processing is required in relation to a legal claim.

 

Where the data to be restricted has been shared with third parties, Cunningham Driving School will inform those third parties where this is possible. However, where this notification will cause a disproportionate effect on Cunningham Driving School, this notification may not be carried out.

 

Where Cunningham Driving School is to lift any restriction on processing, you will be informed in advance.

 

The right to data portability

You have the right to obtain the data that Cunningham Driving School processes on you and use it for your own purposes. This means you have the right to receive the personal data that you have provided to Cunningham Driving School in a structured machine-readable format and to transmit the data to a different data controller.

 

This right applies in the following circumstances:

 

•where you have provided the data to Cunningham Driving School

•where the processing is carried out because you have given Cunningham Driving School your consent to do so.

•where the processing is carried out in order to perform the services between you and Cunningham Driving School

•where processing is carried out by automated means.

 

If you wish to exercise this right, please contact Cunningham Driving School.

 

Where a request for data portability is received, Cunningham Driving School will respond without undue delay, and within one month at the latest. Where the request is complex or Cunningham Driving School receives a number of requests, Cunningham Driving School may extend the timescale for response from one month to three months. If this is the case, Cunningham Driving School will write to you within one month of receipt of the request explaining the reason for the extension.

 

If the response to your request is that Cunningham Driving School will take no action, you will be informed of the reasons for this and of your right to complain to the ICO.

 

The right to portability is different from the right to access. Although both involve a right to access your personal data, the personal data to be accessed is not the same. The right to access your data under the right to portability includes only personal data as described above. Access to data under the right of access includes all personal data relating to you, including that which has not been provided to Cunningham Driving School by you.

 

The right to object to the inclusion of data

You have a right to object to the processing of your data in certain circumstances. This means that you have the right to require Cunningham Driving School to stop processing your data. In relation to your services with Cunningham Driving School, you may object to processing where it is carried out:

 

•in relation to the driving school’s legitimate interests

•for the performance of a task in the public interest

•in the exercise of official authority or

•for profiling purposes.

 

If you wish to object, you should do so by contacting us.

 

Where you object to processing, Cunningham Driving School will stop the processing activity objected to unless:

 

•Cunningham Driving School can demonstrate compelling legitimate reasons for the processing which are believed to be more important than your rights

 

or

 

•the processing is required in relation to legal claims made by, or against, Cunningham Driving School.

 

If the response to your request is that Cunningham Driving School will take no action, you will be informed of the reasons.

 

Rights in relation to automated decision making

 

You have the right not to have decisions made about you solely on the basis of automated decision-making processes where there is no human intervention, where such decisions will have a significant effect on you.  However, Cunningham Driving School does not make any decisions based on such processes.

 

OR

 

We currently make decisions about you using automatic system involving no human intervention. You have the right not to have decisions made about you solely on the basis of automated processes where there is no human intervention.

 

If you wish to exercise this right, you should speak to Cunningham Driving School.

 

However, we may carry out automated decision making with no human intervention in the following circumstances:

 

•when it is needed for entering into or the carrying out of a contract with you

•when the process is permitted by law

•when you have given explicit consent.

 

Subject access request policy (GDPR compliant)

 

Introduction

Under the General Data Protection Regulation (GDPR), you have a right to receive confirmation that an organisation processes your personal data, and also a right to access that data so that you may be aware of it and are able to verify the lawfulness of the processing. The process for doing so is called a Subject Access Request and this policy sets out the procedure to be undertaken when such a request is made by you regarding data processed about you by Cunningham Driving School.

 

What is personal data?

“Personal data” is any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier, including your name.

 

“Special categories of personal data” includes information relating to:

 

•race

•ethnic origin

•politics

•religion

•trade union membership

•genetics

•biometrics (where used for ID purposes)

•health

•sex life or

•sexual orientation.

 

Information you are entitled to

When you make a subject access request, you will be informed of:

 

•whether or not your data is processed and the reasons for the processing of your data

•the categories of personal data concerning you

•where your data has been collected from if it was not collected from you

•anyone who your personal data has been disclosed to or will be disclosed to, including anyone outside of the EEA and the safeguards utilised to ensure data security

•how long your data is kept for (or how that period is decided)

•your rights in relation to data rectification, erasure, restriction of and objection to processing

•your right to complain to the Information Commissioner if you are of the opinion that your rights have been infringed

•the reasoning behind any automated decisions taken about you.

 

Making a subject access request

Subject access requests must be made in writing and can be made in either hard copy format or electronically. Cunningham Driving School can provide you with a form for making a request though making a request in this format is not a requirement. Including specific details of the data you wish to see in your request will enable a more efficient response from Cunningham Driving School. I/We may need to contact you for further details on your request if insufficient information is contained in the original request.

 

Requests may be made by you personally or by a third party eg a solicitor acting on your behalf. I/We will request evidence that the third party is entitled to act on your behalf if this is not provided at the same time as the request is made.

 

Upon receiving a subject access request

Cunningham Driving School will comply with your request without delay and at the latest within one month unless one of the following applies:

 

•in some cases, we will be unable to supply certain pieces of information that you have requested. This may be because it is subject to legal privilege. Where this is the case, Cunningham Driving School will inform you that your request cannot be complied with and an explanation of the reason will be provided

•I/we require extra time because the requests are complex or numerous. In these circumstances, Cunningham Driving School will write to you within one month of receipt of your request to explain why an extension is required. Where an extension is required, information will be provided within three months of the request.

 

Before supplying the data (where appropriate) I/we may contact you asking for proof of identity. You must produce this evidence for your request to be complied with.

Your request will normally be complied with free of charge. However, I/we may charge a reasonable fee if the request is manifestly unfounded or excessive, or if it is repetitive. In addition, I/we may charge a reasonable fee if you request further copies of the same information. The fee charged will be based on the administrative cost of providing the information requested.

 

 

Refusing a request

Cunningham Driving School may refuse to comply with a subject access request if it is manifestly unfounded or excessive, or if it is repetitive. In these circumstances, I/we will write to you without undue delay and at the latest within one month of receipt to explain why we are unable to comply. You will be informed of the right to complain to the Information Commissioner and to a judicial remedy.

 

 

 

Our Privacy Policy & Cookies Policy

Owner contact email: [email protected]

Overview

In order for us to operate our business and provide our services to you, it is sometimes necessary for us to collect or process information about you. In general terms, this information will take one or more of the following forms:

1.Information that you provide to us directly, such as in the situation where you complete an online form or send us a message via our website;

2.Information that is automatically sent to us by your computer’s internet browser when you visit our website, such as your computer’s technical address (or ‘IP address’) or information about which particular internet browser you are using and so on;

3.Information about how you use our website or our services, such as which pages you visit, how frequently you visit the site and so forth.

This privacy policy sets out the detail of what information we collect, as well as how that data is used and protected.

 

Our commitment to data privacy

In terms of your use of this website, We, Cunningham Driving School act in the capacity of Data Controller and comply with the GDPR best practices, and should you have any questions or concerns about the data we hold about you, we can be contacted using the information below:

Data Controller: Cunningham Driving School

Email correspondence: [email protected]

 

Definition of ‘personal data’

When we refer to ‘personal data’ we mean any information that allows us to identify you personally. Obvious examples include your name, email address, postal address etc. We will always seek to gain your explicit consent to providing this information before we collect it from you, although this may not be the only legal basis on which we collect the data.

Other types of information, such as your computer’s ‘IP’ address or broad geographical location do not, generally, allow us to identify you directly. However, because in their current form, European data privacy regulations (GDPR) are somewhat vague in this regard, we will cover the use of such data here also.

 

Who we share data with

We operate on a strict ‘need to know’ basis for all data that we work with, and that is particularly true for any personal data. The only people/organisations that are granted access to personal data are:

•Service providers who provide IT and system administration services.

•Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.

•HM Revenue & Customs, regulators and other authorities based in the United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances.

•Third parties to whom we sell, transfer, or merge parts of our business or our assets.

Note: Our authorised data processor has signed Data Privacy Agreements with all of the 3rd party technology suppliers above which detail our respective responsibilities for data security.

 

How your data is protected

We take the security of all personal data very seriously, and that data is protected in a number of ways:

•Access control: access to personal data is strictly limited in line with our policy detailed in the ‘who we share data with section’ on this page. Access is controlled by individual user accounts, where a strong password policy is enforced

•Dedicated security software: We operate dedicated security scanning and access control software on all of our websites and servers. This software is responsible for limiting login attempts to our site, blocking potentially malicious attempts to access our services, and regularly performing full file system scans.

•Data encryption: where data is stored in a cloud facility (specifically, the storage of website backup files), that data is encrypted both ‘in transit’ and ‘at rest’ – meaning that all data is securely obscured both during the process of transfer to the cloud provider, and then additionally when it is in storage at its final location.

•Selection of third party service providers: we use a very limited number of third party service providers, but some are essential for the provision of physical hosting environments and cloud services. One of the core factors in the selection of such providers is their ability to provide secure systems and processes. We have written Data Processing Agreements with each of our core service providers that sets out the requirements for data security.

Access to your personal data

In the situation where you have directly provided personal information to us (such as by completing an online form or contacting us for further information), you have a number of rights regarding the personal data that we hold:

•You have the right to obtain from us confirmation about whether any such data is being held;

•You have the right to require that we provide you with whatever data we are holding/processing about you, including the right for that data to be transferred to another data controller;

•Even if you have consented to us processing your personal data, you have the right to withdraw that permission at any time;

•You have the right to require us to rectify any incomplete or incorrect information held about you;

•You have the right to require us to erase the data held about you (the ‘right to be forgotten’);

In the situation where we collect personal data automatically (such as from your internet browser or via internet Cookies or other similar technologies):

•You have the right to object to the legal basis upon which we are collecting this data, and We have an obligation to consider and respond to that objection;

•You have the right to request the prevention of further processing of your data while your objection is considered;

•You have the right to make a complaint to the relevant data protection authority (which, in the UK, is the Information Commissioner’s Office or ‘ICO’)

•In most circumstances, you can exercise these rights without paying a fee to us.

 

Types of data collected

Website contact forms

When you complete one of the contact forms on our website, we will ask you for a number of pieces of personal information, such as your name, email address and other contact details. This is obviously required for us to respond to your request.

If you do not use or submit an online form on the website, no data will be collected in that regard.

Legal Basis:

Consent (GDPR Art 6(1)(a)): Generally, we will ask for your explicit permission to process this data before you are able to submit the contact form. We will also give you a link to our Privacy Policy (this document) that you may review before submitting your details.

Intent to contract (GDPR Art 6(1)(b)): Additionally, the information that you provide to us here is necessary for us to fulfil your request prior to entering into a contract.

Types of processing

•We will store the information you provide to us in our website database, and/or in our self-managed Customer Relationship Management system. Such storage allows us to efficiently access your data and respond to your requests;

•For the purpose of maintaining the integrity of our systems, we may also store this data in system backups, which are encrypted and held securely by our technology partner.

•We may use this information to contact you about other of our own services that we believe may be of genuine interest to you;

•We will NOT use this data for any further purpose without your express further consent;

•We will NEVER sell your information to any 3rd party.

 

Data minimisation:

We will only ask you for the minimum amount of information required to appropriately fulfil your request. This will usually be your name, one or more contact details, and any specific information about your request.

Retention

If we do not enter into a further contract or agreement with you, we will retain this data for a maximum of 12 months. If you choose to enter into a service agreement with us, we will retain the data for the length of our ongoing agreement plus a maximum of 12 months.

 

Technical data (such as ‘IP address’)

When you visit our website, our systems will log a record of your visit in our server logs, and typically this record will include the technical ‘IP’ address that is associated with your device and the browser type and version that you are using.

Such server logs are extremely common practice, and are used to monitor technical resources, monitor high-level server activity, and importantly to detect and prevent malicious or fraudulent activity on our systems. This data can also be used, if required, to diagnose reports of technical issues. The storage of IP addresses, allow us to identify patterns of behaviour (such as repeated malicious attempts to access a system).

IP addresses, in and of themselves, do not allow us in any way to identify you as an individual, especially given that it is very common for IP addresses to be dynamically allocated by your service provider, and will therefore often routinely change.

Furthermore, we do not and will not use the content of server access logs to attempt to determine an identifiable individual. We therefore do not consider that data held within server logs falls within the scope of ‘personal data’, and accordingly we do not seek your consent to collect it.

Legal Basis

In the event that such anonymous data is considered to fall within the scope of the applicable data protection regulations, the legal basis for processing such data is:

Our Legitimate interest (GDPR Art 6(1)(f)): The integrity, security and performance of our systems and infrastructure is a vital part of the services that we offer. We consider that it is in our legitimate interest to maintain and protect our systems to this end.

Types of processing

•We will store the information you provide to us in our website server logs

•For the purpose of maintaining the integrity of our systems, we may also store this data in infrastructure backups

•We will NOT use this data to attempt to identify an individual person

Retention

Server logs are automatically rotated on our systems, and are retained for a maximum of 12 months following the closure of the relevant log file.

 

Cookies & ‘similar technologies’

We have included cookies, web beacons and similar technologies into one section because they all perform similar functions even if, from a technical perspective, they work slightly differently. All of these technologies allow us to better understand how users are using our website and other related services. They can also be an essential part of providing certain online functionality.

They are all essentially small data files placed on your computer (or other device) that allow us to tell when you have visited a particular page, or performed a particular action (such as clicking a particular button) on our website. These technologies are used by most websites as they provide useful insight into how the services are being used, as well as improving speed, performance and security, and enabling us to improve our personalisation of your experience.

Cookies

These are small text files placed in the memory of your browser or device when you visit a website. Cookies allow a website to recognize a particular device or browser. There are several types of cookies:

•Session cookies expire at the end of your browser session and allow us to link your actions during that particular browser session.

•Persistent cookies are stored on your device in between browser sessions, allowing us to remember your preferences or actions across multiple sites.

•First-party cookies are set by the site you are visiting.

•Third-party cookies are set by a third party site separate from the site you are visiting.

There are a number of ways that you can influence how cookies are used on your particular device. Most commercial browsers (such as Chrome, Safari, Edge, Internet Explorer, Firefox etc) allow you to set preferences for whether to allow or block website cookies. They will also provide tools that allow you to remove any cookies that have already been set. Using the ‘Help’ functionality of your browser, or an internet search, will help you to understand how to use these features for your particular browser.

Web beacons

– Small graphic images (also known as “pixel tags” or “clear GIFs”) that may be included on our sites and services that typically work in conjunction with cookies to identify our users and user behaviour.

More detail about our use of cookies

Our uses of such technologies fall into the following general categories:

1.Operationally Necessary. We may use cookies, web beacons, or other similar technologies that are necessary to the operation of our sites, services, applications, and tools. This includes technologies that allow you access to our sites, services, applications, and tools; that are required to identify irregular site behaviour, prevent fraudulent activity and improve security; or that allow you to make use of our functions such as shopping-carts, saved search, or similar functions;

2.Performance Related. We may use cookies, web beacons, or other similar technologies to assess the performance of our websites, applications, services, and tools, including as part of our analytic practices to help us understand how our visitors use our websites, determine if you have interacted with our messaging, determine whether you have viewed an item or link, or to improve our website content, applications, services, or tools;

3.Functionality Related. We may use cookies, web beacons, or other similar technologies that allow us to offer you enhanced functionality when accessing or using our sites, services, applications, or tools. This may include identifying you when you sign into our sites or keeping track of your specified preferences, interests, or past items viewed so that we may enhance the presentation of content on our sites;

4.Advertising or Targeting Related.  We may use first-party or third-party cookies and web beacons to deliver content, including ads relevant to your interests, on our sites or on third party sites.  This includes using technologies to understand the usefulness to you of the advertisements and content that have been delivered to you, such as whether you have clicked on an advertisement.

The cookies currently in use on this site are as follows:

CookiePurpose

_ga, _gat, _gidPerformance Related – Analytics cookies set by Google Analytics

 

Legal Basis

Our Legitimate interest (GDPR Art 6(1)(f)): The integrity, security and performance of our systems and infrastructure is a vital part of the services that we offer. We consider that it is in our legitimate interest to maintain and protect our systems to this end.

For this, and website usability reasons, we do not explicitly seek your consent to place these particular cookies.

How do I change my cookie settings?

You can block most cookies by activating the setting on your browser that allows you to refuse all or some cookies. Please note, blocking all cookies may restrict access to all or parts of our website, or you may experience reduced functionality when accessing certain services. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies as soon you visit our website.

Learn how to turn off cookies for your web browser:

 

Adjust cookie settings in Chrome

Adjust cookie settings in Firefox 

•Adjust cookie settings in Internet Explorer

•Adjust cookie settings in Safari

•Adjust cookie settings in Microsoft Edge

 

Website Analytics

We use Google Analytics to better understand what people look at on our website. When people visit our site, information about their visit (such as which pages they look at, how long they spend on the site and so on) is sent in an anonymous form to Google Analytics (which is controlled by Google). The data contains information about anyone who uses our website from your computer, and there is no way to identify individuals from the data. As analytics information is not personal data, we do not specifically ask for your prior consent.

 

 

Changes to our privacy policy

This privacy policy may change from time to time in line with legislation or industry developments. We will not explicitly inform our clients or website users of these changes. Instead, we recommend that you check this page occasionally for any policy changes.

 

Your acceptance of these terms

By using this Site, you signify your acceptance of this policy. If you do not agree to this policy, please do not use our Site. Your continued use of the Site following the posting of changes to this policy will be deemed your acceptance of those changes.

 

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