FAIRWAYS COMMUNICATIONS LTD
This Privacy Notice aims to inform you about how I look after your personal data when you use my services or interact with me through, or browse, my website (“Website”), and your rights in relation to that data. The term ‘personal data’, also commonly referred to as personal information, means any information about an individual from which on its own or when combined with other information that person can be identified.
Information about me
For the purposes of data protection regulations, Fairways Communications Limited (“Fairways Communications”) is the data controller, which means the entity responsible for your personal data, and is also referred to in this Privacy Notice as “I”, “me” and “my”.
My contact details are:
Telephone: +44(0)1932 227457
If you have any questions about anything in this Privacy Notice, or you wish to request access to the data I hold about you, you can contact me using the details above.
It is important that the personal data I hold about you is accurate and up to date. Please do let me know if any of that data changes during the time I hold it.
What data I collect from you
I may from time-to-time collect, use, store and transfer the following personal data about you:
- Your full name (first name and surname)
- Your address
- Your contact details, including email addresses and telephone numbers
- Financial information, including bank account details
- Your IP address and other technical data based on that IP address e.g. time zone; location, browser type and settings, operating system and platform and other technology on the device you use to contact me
- Usage data from my Website, including information about how you have arrived at my Website
- Your communications preferences with regards to receiving any marketing and newsletters from me.
I may also collect aggregated or anonymised data (or both) for the purposes of Website performance and engagement analysis. This data may be derived from your personal data but as it does not directly or indirectly identify you, it is not considered ‘personal data’ in legal terms.
If I need to collect any personal data for any legal reason, or under the terms of a contract I have with you, and you do not provide that data when requested, then I may not be able to carry out my obligations under that contract. In such circumstances I may have to cancel my contract with you, but I will notify you if this is the case.
Third party links and websites
My Website may contain links to third-party websites, plug-ins or applications. By clicking on any of those links or enabling those connections, you may allow third parties to collect or share data about you. I do not control those third-party sites and I am not responsible for what they may do with data they collect about you. I recommend that you read the privacy notices of each third-party site in order to understand how they may collect and process your data.
How do I collect your data?
I collect data from and about you in various forms and circumstances, as set out below:
- When I interact with you directly – you may provide me with data such as name, address and email address when you correspond with me by post, phone, email or otherwise. This includes data you provide when you:
- engage me to provide my services to you
- enquire about my services
- subscribe to any newsletters
- contact me, request a quote or fill in any form on my Website
- Via automated technology – as you use my Website, I may automatically collect data about the device you are using to access my Website and your browsing activities and patterns. I collect this data by using cookies and other similar technologies. You can read more about what cookies are and how I use them by clicking here.
- Via third parties – I collect data about you via Google Analytics, who provide the cookies referred to above
How do I use your data?
I have set out below the purposes for which I use your data, and the legal basis (or bases, depending on the purposes for which I am using that data) that I rely upon in order to do so. If you need any more information about which legal basis applies to any particular use of data, then please contact me using the details above.
|Purpose/Activity||Data Used||Lawful Basis of Processing|
|To set you up as a client of Fairways Communications/to provide my services once you are set up||Name, address and contact details||Taking steps preparatory to entering into, or performance of, a contract with you to provide my services to you|
|To respond to enquiries about Fairways Communications and my services, quote requests or briefs including those submitted via any forms on my Website||Contact details as provided to me||Taking steps preparatory to entering into, or performance of, a contract with you to provide my services to you|
|To send newsletters and updates||Email address||You have given consent for me to do so|
|To manage my relationship with you, including: (a) notifying you of changes to my policies; and (b) to collect and recover any monies owed to me.||(a) Name and contact details(b) Name, address and contact details||(a) necessary to comply with legal obligations from time to time(b) performance of a contract with you – recovering monies owed under that contract|
|To process payment of my fees||Name, address, contact details, financial information||Performance of a contract between you and me|
|To administer and provide my Website including performance monitoring, troubleshooting and data analysis||IP addresses and other technical data/analytics data (anonymised)||The legitimate interests of my business in improving and delivering my service as best as possible|
|To provide my services||Contact details provided by you||Performance of a contract with you to provide my services to you|
|To comply with legal and accounting obligations||Name, address and financial information||Necessary to comply with legal and regulatory obligations from time to time|
I will only use your personal data for the purposes for which I collected it, unless I believe that I need to use it for another purpose and that purpose is compatible with the original purpose for which the data was provided to me. You can contact me at any time to obtain more information about this processing. If I need to use your personal data for any other purpose, I will notify you and will explain the legal basis that allows me to do so.
Please note that I may process your personal data without your knowledge or consent if the law requires or permits me to do so.
I only send out any marketing information and newsletters if you have opted in to receive that information. I do not share or pass on data to any third parties for marketing purposes.
You can ask me to stop sending you marketing/newsletters at any time by contacting me at firstname.lastname@example.org or by choosing ‘unsubscribe’ at the bottom of any such communication (but, if you do so I will retain personal data provided to me and which I need to process in order to continue providing my services to you).
Disclosure of your personal data and international transfers
I may share your personal data with third parties as set out below:
|Third Party||Location of recipient (if outside EEA)|
|Professional advisors such as lawyers, accountants and auditors, who provide professional services to me and are under a duty of confidentiality||N/A|
|HMRC and other authorities and regulators, whose laws and regulations require us to disclose data||N/A|
|Third-party service providers:|
I require all third parties to respect the security of your personal data, to treat it in accordance with the law and to process and use that data only for the purposes specified by me and in accordance with my instructions.
Some of my external service providers are based outside the European Economic Area (EEA), as set out above, so their processing of your data involves a transfer of data outside the EEA. Wherever I transfer your data outside the EEA in this way, I use my best efforts to ensure that at least one of the following safeguards is in place:
- I will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
- Where I use certain service providers, I may use specific contracts approved by the European Commission which give personal data the same protection as it has in Europe.
- Where I use providers based in the US, I may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.
Please contact me if you want further information on the specific mechanism used when transferring your personal data out of the EEA.
I may also share personal data in the event that I sell or buy any business or assets, in which case I may disclose your personal data to the prospective seller or buyer of that business or assets; or if any third party acquires Fairways Communications or any part of it, in which case personal data held about my clients will be one of the transferred assets.
I have put in place appropriate security measures for the nature and scale of my business, in order to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, I limit access to your personal data to contractors and other third parties who have a business need to know, and only on my instructions and subject to a duty of confidentiality.
I have procedures in place to deal with any suspected personal data breach and I will notify you and any applicable regulator of a breach where I am legally required to do so.
How long will I use your data for?
I will only retain your personal data for as long as is necessary to fulfil the purposes I collected it for, including for the purposes of satisfying legal, accounting and reporting requirements.
To determine how long I need to retain data, I consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure, the purposes for which I process that data and whether I can achieve those purposes without keeping the data.
If you are a client, by law I have to keep certain basic information about you for six years after ceasing to work with you, for tax purposes.
I aim to carry out data reviews on an annual basis and will endeavour at such time, where possible, to delete any data held and which I no longer require.
Your legal rights
You have the right to request the information I hold on you, to ask me to correct that data and, in certain circumstances, to erase that data. If you would like to do so, or to opt out of any marketing and newsletter communications, or you wish to update your details and preferences, please email email@example.com or call me on +44(0)1932 227457.
You also have certain rights to object to me processing your data, to restrict that processing or to transfer your personal data. If you would like any more information about, or would like to exercise, any of these rights please contact me. You will not be charged any fee to do so, unless your request is clearly unfounded, excessive or malicious, in which case I may either refuse to comply or I will charge a reasonable fee.
I will make every effort to respond to legitimate requests within one month. Occasionally it may take me longer to do so, if your request is complicated or you have made more than one request. In this case, I will notify you and keep you updated.
You are entitled to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection, if you feel that my processing of your personal data is not compliant with my legal and regulatory obligations. I would, however, appreciate the chance to address your concerns before you contact the ICO, so I would be grateful if you would contact me in the first instance.
This Privacy Notice was last updated in September 2019.