Privacy policy

1. Introduction

1.1 We are committed to safeguarding the privacy of our website visitors; in this

policy we explain how we will treat your personal information.

1.2 [We will ask you to consent to our use of cookies in accordance with the

terms of this policy when you first visit our website. / By using our website

and agreeing to this policy, you consent to our use of cookies in accordance

with the terms of this policy.]

2. Credit

2.1 This document was created using a template from SEQ Legal

(http://www.seqlegal.com).

You must retain the above credit, unless you purchase a licence to use this

document without the credit. You can purchase a licence at:

http://www.website-contracts.co.uk/seqlegal- licences.html. Warning: use of

this document without the credit, or without purchasing a licence, is an

infringement of copyright.

3. Collecting personal information

3.1 We may collect, store and use the following kinds of personal information:

(a) [information about your computer and about your visits to and use of

this website (including [your IP address, geographical location,

browser type and version, operating system, referral source, length

of visit, page views and website navigation paths]);]

(b) [information that you provide to us when registering with our website

(including [your email address]);]

(c) [information that you provide when completing your profile on our

website (including [your name, profile pictures, gender, date of birth,

relationship status, interests and hobbies, educational details and

employment details]);]

(d) [information that you provide to us for the purpose of subscribing to

our email notifications and/or newsletters (including [your name and

email address]);]

(e) [information that you provide to us when using the services on our

website, or that is generated in the course of the use of those

services (including [the timing, frequency and pattern of service

use]);]

(f) [information relating to any purchases you make of our [goods /

services / goods and/or services] or any other transactions that you

enter into through our website (including [your name, address,

telephone number, email address and card details]);]

(g) [information that you post to our website for publication on the

internet (including [your user name, your profile pictures and the

content of your posts]);]

(h) [information contained in or relating to any communication that you

send to us or send through our website (including [the

communication content and metadata associated with the

communication]);]

(i) [any other personal information that you choose to send to us; and]

(j) [[provide details of other personal information collected].]

3.2 Before you disclose to us the personal information of another person, you

must obtain that person's consent to both the disclosure and the processing

of that personal information in accordance with this policy.

4. Using personal information

4.1 Personal information submitted to us through our website will be used for

the purposes specified in this policy or on the relevant pages of the website.

4.2 We may use your personal information to:

(a) [administer our website and business;]

(b) [personalise our website for you;]

(c) [enable your use of the services available on our website;]

(d) [send you goods purchased through our website;]

(e) [supply to you services purchased through our website;]

(f) [send statements, invoices and payment reminders to you, and

collect payments from you;]

(g) [send you non-marketing commercial communications;]

(h) [send you email notifications that you have specifically requested;]

(i) [send you our email newsletter, if you have requested it (you can

inform us at any time if you no longer require the newsletter);]

(j) [send you marketing communications relating to our business [or the

businesses of carefully-selected third parties] which we think may be

of interest to you, by post or, where you have specifically agreed to

this, by email or similar technology (you can inform us at any time if

you no longer require marketing communications);]

(k) [provide third parties with statistical information about our users (but

those third parties will not be able to identify any individual user from

that information);]

(l) [deal with enquiries and complaints made by or about you relating to

our website;]

(m) [keep our website secure and prevent fraud;]

(n) [verify compliance with the terms and conditions governing the use

of our website [(including monitoring private messages sent through

our website private messaging service)]; and]

(o) [[other uses].]

4.3 If you submit personal information for publication on our website, we will

publish and otherwise use that information in accordance with the licence

you grant to us.

4.4 Your privacy settings can be used to limit the publication of your information

on our website, and can be adjusted using privacy controls on the website.

4.5 We will not, without your express consent, supply your personal information

to any third party for the purpose of their or any other third party's direct

marketing.

4.6 All our website financial transactions are handled through our payment

services provider, [PSP name]. You can review the provider's privacy policy

at [URL]. We will share information with our payment services provider only

to the extent necessary for the purposes of processing payments you make

via our website, refunding such payments and dealing with complaints and

queries relating to such payments and refunds.

5. Disclosing personal information

5.1 We may disclose your personal information to [any of our employees,

officers, insurers, professional advisers, agents, suppliers or subcontractors]

insofar as reasonably necessary for the purposes set out in this policy.

5.2 We may disclose your personal information to any member of our group of

companies (this means our subsidiaries, our ultimate holding company and

all its subsidiaries) insofar as reasonably necessary for the purposes set out

in this policy.

5.3 We may disclose your personal information:

(a) to the extent that we are required to do so by law;

(b) in connection with any ongoing or prospective legal proceedings;

(c) in order to establish, exercise or defend our legal rights (including

providing information to others for the purposes of fraud prevention

and reducing credit risk);

(d) [to the purchaser (or prospective purchaser) of any business or asset

that we are (or are contemplating) selling; and]

(e) [to any person who we reasonably believe may apply to a court or

other competent authority for disclosure of that personal information

where, in our reasonable opinion, such court or authority would be

reasonably likely to order disclosure of that personal information.]

5.4 Except as provided in this policy, we will not provide your personal

information to third parties.

6. International data transfers

6.1 Information that we collect may be stored and processed in and transferred

between any of the countries in which we operate in order to enable us to

use the information in accordance with this policy.

6.2 Information that we collect may be transferred to the following countries

which do not have data protection laws equivalent to those in force in the

European Economic Area: [the United States of America, Russia, Japan,

China and India].

6.3 Personal information that you publish on our website or submit for

publication on our website may be available, via the internet, around the

world. We cannot prevent the use or misuse of such information by others.

6.4 You expressly agree to the transfers of personal information described in

this Section 6.

7. Retaining personal information

7.1 This Section 7 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 information.

7.2 Personal information that we process for any purpose or purposes shall not

be kept for longer than is necessary for that purpose or those purposes.

7.3 Without prejudice to Section 7.2, we will usually delete personal data falling

within the categories set out below at the date/time set out below:

(a) [personal data type] will be deleted [date/time; and]

(b) [repeat as necessary.]

7.4 Notwithstanding the other provisions of this Section 7, we will retain

documents (including electronic documents) containing personal data:

(a) to the extent that we are required to do so by law;

(b) if we believe that the documents may be relevant to any ongoing or

prospective legal proceedings; and

(c) in order to establish, exercise or defend our legal rights (including

providing information to others for the purposes of fraud prevention

and reducing credit risk).

8. Security of personal information

8.1 We will take reasonable technical and organisational precautions to prevent

the loss, misuse or alteration of your personal information.

8.2 We will store all the personal information you provide on our secure

(password- and firewall-protected) servers.

8.3 All electronic financial transactions entered into through our website will be

protected by encryption technology.

8.4 You acknowledge that the transmission of information over the internet is

inherently insecure, and we cannot guarantee the security of data sent over

the internet.

8.5 You are responsible for keeping the password you use for accessing our

website confidential; we will not ask you for your password (except when

you log in to our website).

9. Amendments

9.1 We may update this policy from time to time by publishing a new version on

our website.

9.2 You should check this page occasionally to ensure you are happy with any

changes to this policy.

9.3 We may notify you of changes to this policy [by email or through the private

messaging system on our website].

10. Your rights

10.1 You may instruct us to provide you with any personal information we hold

about you; provision of such information will be subject to:

(a) the payment of a fee (currently fixed at GBP 10); and

(b) the supply of appropriate evidence of your identity [(for this purpose,

we will usually accept a photocopy of your passport certified by a

solicitor or bank plus an original copy of a utility bill showing your

current address)].

10.2 We may withhold personal information that you request to the extent

permitted by law.

10.3 You may instruct us at any time not to process your personal information for

marketing purposes.

10.4 In practice, you will usually either expressly agree in advance to our use of

your personal information for marketing purposes, or we will provide you

with an opportunity to opt out of the use of your personal information for

marketing purposes.

11. Third party websites

11.1 Our website includes hyperlinks to, and details of, third party websites.

11.2 We have no control over, and are not responsible for, the privacy policies

and practices of third parties.

12. Updating information

12.1 Please let us know if the personal information that we hold about you needs

to be corrected or updated.

13. Cookies

13.1 Our website uses cookies.

13.2 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.

13.3 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.

13.4 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.

13.5 We use [only session cookies / only persistent cookies / both session and

persistent cookies] on our website.

13.6 The names of the cookies that we use on our website, and the purposes for

which they are used, are set out below:

(a) we use [cookie name] on our website to [recognise a computer when

a user visits the website / track users as they navigate the website /

enable the use of a shopping cart on the website / improve the

website's usability / analyse the use of the website / administer the

website / prevent fraud and improve the security of the website /

personalise the website for each user / target advertisements which

may be of particular interest to specific users / [describe

purpose(s)]];

(b) [repeat as necessary.]

13.7 Most browsers allow you to refuse to accept cookies; for example:

(a) in Internet Explorer (version 11) you can block cookies using the

cookie handling override settings available by clicking "Tools",

"Internet Options", "Privacy" and then "Advanced";

(b) in Firefox (version 39) you can block all cookies by clicking "Tools",

"Options", "Privacy", selecting "Use custom settings for history" from

the drop-down menu, and unticking "Accept cookies from sites"; and

(c) in Chrome (version 44), you can block all cookies by accessing the

"Customise and control" menu, and clicking "Settings", "Show

advanced settings" and "Content settings", and then selecting "Block

sites from setting any data" under the "Cookies" heading.

13.8 Blocking all cookies will have a negative impact upon the usability of many

websites.

13.9 If you block cookies, you will not be able to use all the features on our

website.

13.10 You can delete cookies already stored on your computer; for example:

(a) in Internet Explorer (version 11), you must manually delete cookie

files (you can find instructions for doing so at

http://windows.microsoft.com/en-gb/internet- explorer/delete-

manage-cookies#ie=ie- 11);

(b) in Firefox (version 39), you can delete cookies by clicking "Tools",

"Options" and "Privacy", then selecting "Use custom settings for

history" from the drop-down menu, clicking "Show Cookies", and

then clicking "Remove All Cookies"; and

(c) in Chrome (version 44), you can delete all cookies by accessing the

"Customise and control" menu, and clicking "Settings", "Show

advanced settings" and "Clear browsing data", and then selecting

"Cookies and other site and plug-in data" before clicking "Clear

browsing data".

13.11 Deleting cookies will have a negative impact on the usability of many

websites.

14. Data protection registration

14.1 We are registered as a data controller with the UK Information

Commissioner's Office.

14.2 Our data protection registration number is [number].

15. Our details

15.1 This website is owned and operated by [name].

15.2 We are registered in [England and Wales] under registration number

[number], and our registered office is at [address].

15.3 Our principal place of business is at [address].

15.4 You can contact us by writing to the business address given above, by using

our website contact form, by email to [email address] or by telephone on

[telephone number].

Drafting notes for free privacy policy

Our standard website privacy policy template, designed to aid compliance with data

protection legislation. This includes disclosures about the categories of personal

information that are collected, website cookies, the ways in which that personal

information may be used, the persons to whom the personal information may be

disclosed, the security measures used to protect the personal information, and

much else besides.

Our privacy policy document is designed for use in relation websites which collect

and process personal information. Its purpose is to help website operators meet

their obligations under UK data protection legislation.

The privacy policy document covers, amongst other things, the following matters:

details of personal information collected by the website; information about cookies

used by the site; details of how personal information is used; details of specific

situations in which personal information may be disclosed to third parties;

information about extra-EEA transfers of personal data; and information about data

security.

Please read the notes accompanying the privacy policy very carefully. You will of

course need to adapt the privacy policy to suit your website and business.

It may not be suitable for websites which collect or process large volumes of

personal information or sensitive personal information; nor may it be it suitable for

websites which make complex or unusual or unexpected uses of personal

information.

In relation to cookies, the privacy policy includes a statement to the effect that

users consent to the use of cookies. However, this will not necessarily satisfy the

cookies consent requirement under the new cookie laws.

Free privacy policy body (with cookies)

Section 1 – Introduction

Section 1.1

"Personal information": for day-to- day purposes, it is best to assume that all

information which relates to a living individual constitutes personal information.

Section 1.2

Optional element.

How will you gain users' consent to the use of cookies?

The inclusion of this statement in your privacy policy will not in itself satisfy the

requirements of the Privacy and Electronic Communications (EC Directive)

Regulations 2003 as regards consent to the use of cookies. Guidance concerning

methods of obtaining such consent is included on the Information Commissioner's

website (http://www.ico.gov.uk).

Section 2 – Credit

Optional element.

Section 3 – Collecting personal information

Section 3.1

What types of personal information will or might the website operator collect?

(a) – What analytics data will you collect?

(b) – What information will be collected from users who register with the website?

(c) – What profile information is collected through the website?

(d) – What information will be collected from users who subscribe to website

services, email notifications and/or newsletters?

(e) – What information is processed in connection with the provision of website

services?

(f) – What can be purchased through the website: goods, services or both? What

transactional data will be collected from users?

(g) – What personal information can a user publish through the website?

(h) – What communications information may be collected?

(j) – What other types of information might you collect?

Section 3.2

Optional element.

Section 4 – Using personal information

Section 4.2

For what purposes will the website operator use personal information collected

through the website?

(j) – Might marketing communications relate to third party businesses?

(n) – Will private messages sent by users be monitored to ensure compliance with

website terms and conditions?

(o) – For what other purposes might personal data collected through the website be

used?

You must list here the uses to which you will (or may in future) put personal data.

We have suggested some common categories.

As a general rule, where you plan to use personal information you have collected

for the purpose of direct marketing, this should be made clear on the page where

the information is collected, and you should ensure that this only happens if users

opt in to the marketing (eg "Click here if you would like us to send you information

by email about products which we think will interest you."). There are, however,

exceptions to this general rule. There are also rules about the content of direct

marketing communications. If you are in any doubt about complying with your legal

obligations in relation to direct marketing, you should seek professional advice.

Section 4.3

Will users have the opportunity to publish any personal information on the website?

Section 4.4

Optional element.

Section 4.5

Will the website undertake in this document not to supply any user's personal

information to a third party for the purpose of third party direct marketing?

Section 4.6

Will the website operator pass any personal information to any third party payment

services provider?

What is the name of the payment services provider that processes website

transactions? At what web address can the privacy policy of the payment services

provider be found?

Section 5 – Disclosing personal information

Section 5.1

To which categories of person may personal information collected through the

website be disclosed?

Section 5.2

Is the website operator part of a group of companies in circumstance where one or

more of those other group companies might need access to personal information

collected by reference to this document?

Section 5.3

(d) – Does the website operator need a right to disclose personal data to business

purchasers and potential business purchasers?

(e) – Does the website operator require a right to disclose personal data in

anticipation of a court judgment or regulatory action?

A website operator may be obliged to disclose personal data to a third party under

various laws. For example, under the Defamation Act 2013 and the Defamation

(Operators of Websites) Regulations 2013, a website operator may be required to

pass personal data between a complainant and a poster – i.e. a person who posts

on the website material which may be defamatory of the claimant.

Section 6 – International data transfers

Does the website operator, or might the website operator, transfer or have

transferred outside the European Economic Area (EEA) any personal information

that it controls?

Give as much detail as possible about any such international transfers. You need to

be aware that the inclusion of this provision will not be sufficient to ensure that all

international transfers of personal data are lawful. If in doubt, you should seek

professional advice on this point.

Section 6.2

Will any personal data be transferred outside the EEA?

To which countries outside the EEA may personal data be transferred?

Section 6.3

Will users have the opportunity to publish personal information on the website?

Section 6.4

This consent statement is unlikely to create an effective consent to extra-EEA

transfers on its own.

Section 7 – Retaining personal information

Section 7.1

Optional element.

Section 7.3

Does the website operator have any specific policies in place regarding time periods

for the deletion of personal data?

(a) – Specify a category of personal data. Specify the date/time when that personal

data will usually be deleted.

Section 8 – Security of personal information

Section 8.2

Optional element.

There is an obligation upon data controllers to store personal data securely.

Section 8.3

Optional element.

Section 8.4

Optional element.

Section 8.5

Optional element.

Section 9 – Amendments

Section 9.2

Optional element.

Section 9.3

Will you ever contact users to notify them of changes to the document?

How will users be notified of changes to the document?

Section 10 – Your rights

Section 10.1

(b) – What evidence of identity will you require before fulfilling a data protection

subject access request?

Section 10.4

Optional element.

Section 11 – Third party websites

Optional element.

Section 12 – Updating information

Optional element.

Section 13 – Cookies

Optional element.

Section 13.4

Optional element.

Section 13.5

What types of cookies will be used on the website?

Section 13.6

(a) – What is the name of the cookie? For what purpose is the cookie used?

Describe the purpose or purposes for which the cookie is used.

Section 13.9

Will the blocking of cookies have a negative effect upon the use of the website from

a user perspective?

Section 14 – Data protection registration

Optional element.

Section 14.2

What is the website operator's data protection registration number?

Section 15 – Our details

Optional element.

UK companies must provide their corporate names, their registration numbers,

their place of registration and their registered office address on their websites

(although not necessarily in this document).

Sole traders and partnerships that carry on a business in the UK under a "business

name" (i.e. a name which is not the name of the trader/names of the partners or

certain other specified classes of name) must also make certain website

disclosures: (i) in the case of a sole trader, the individual's name; (ii) in the case of

a partnership, the name of each member of the partnership; and (iii) in either case,

in relation to each person named, an address in the UK at which service of any

document relating in any way to the business will be effective. All websites covered

by the Electronic Commerce (EC Directive) Regulations 2002 must provide a

geographic address (not a PO Box number) and an email address. All website

operators covered by the Provision of Services Regulations 2009 must also provide

a telephone number.

Section 15.1

What is the name of the company, partnership, individual or other legal person or

entity that owns and operates the website?

Section 15.2

Is the website operator a company?

In what jurisdiction is the website operator registered? What is the website

operator's company registration number or equivalent? What is the website

operator's registered address?

Section 15.3

Optional element.

Where is the website operator's head office or principal place of business?

Section 15.4

Optional element.

What is the website operator's contact email address? What is the website

operator's contact telephone number?