Privacy Policy

We are ICO registered and our ICO number can be found: here

1.WHAT INFORMATION DO WE COLLECT?

We collect information from you when you place an order or fill out a form. When ordering or registering on our site, as appropriate, you may be asked to enter your: name, e-mail address, mailing address, phone number or credit card information.

2.WHAT DO WE USE YOUR INFORMATION FOR?

Any of the information we collect from you may be used in one of the following ways:
• To improve our website (we continually strive to improve our website offerings based on the information and feedback we receive from you)
• To improve customer service (your information helps us to more effectively respond to your customer service requests and support needs)
• To process transactions, Your information, whether public or private, will not be sold, exchanged, transferred, or given to any other company for any reason whatsoever, without your consent, other than for the express purpose of delivering the purchased product or service requested.

3.HOW DO WE PROTECT YOUR INFORMATION?

We implement a variety of security measures to maintain the safety of your personal information when you place an order or enter, submit, or access your personal information. All supplied sensitive/credit information is transmitted via Secure Socket Layer (SSL) technology and then encrypted into our Payment gateway providers database only to be accessible by those authorized with special access rights to such systems, and are required to keep the information confidential. After a transaction, your private information (credit cards, social security numbers, financials, etc.) will not be stored on our servers.

4.DO WE USE COOKIES?

We use both session cookies and persistent cookies on this website. We will send to you the following cookies:

(1) Statistical Cookies – We track the websites visitors, anonymously in order to provide better services and an online experience to customers.

(2) Security – To improve security and allow us to protect your personal data as this privacy policy states

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 stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. Cookies can be used by web servers to identity and track users as they navigate different pages on a website, and to identify users returning to a website. Cookies may be either “persistent” cookies or “session” cookies. A persistent cookie consists of a text file sent by a web server to a web browser, which will be stored by the 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.

5.DO WE DISCLOSE ANY INFORMATION TO OUTSIDE PARTIES?

We do not sell, trade, or otherwise transfer to outside parties your personally identifiable information. We may also release your information when we believe release is appropriate to comply with the law, enforce our site policies, or protect ours or others rights, property, or safety. However, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.

6.ONLINE PRIVACY POLICY

This online privacy policy applies only to information collected through our website and not to information collected offline.

7.TERMS & CONDITIONS

Please also visit our Terms and Conditions section establishing the use, disclaimers, and limitations of liability governing the use of our website.

9.YOUR CONSENT

By using our site, you consent to our Privacy Policy.

10.CHANGES TO OUR PRIVACY POLICY

If we decide to change our privacy policy, we will post those changes on this page, and/or update the Privacy Policy modification date below. This policy was last modified on 06/12/10

11.CONTACTING US

If there are any questions regarding this privacy policy you may contact us using the information below.

12.OUR DETAILS

13.Our business name is: Webjects Limited

14.Our contact details are: info@webjects.co.uk

15.Our contact number is: 02920709174

GDPR Policy

Introduction

Webjects Limited
is committed to protecting the rights and freedoms of data subjects and safely and securely processing their data in accordance with all of our legal obligations.

We hold personal data about our clients, suppliers and other individuals for a variety of business purposes.

This policy sets out how we seek to protect personal data and ensure that our staff understand the rules governing their use of the personal data to which they have access in the course of their work. In particular, this policy requires staff to ensure that the Data Protection Officer (DPO) be consulted before any significant new data processing activity is initiated to ensure that relevant compliance steps are addressed.

Definitions

Scope

This policy applies to all staff, who must be familiar with this policy and
comply with its terms.

This policy supplements our other policies relating to internet and email
use. We may supplement or amend this policy by additional policies and
guidelines from time to time. Any new or modified policy will be circulated
to staff before being adopted.

Who is responsible for this policy?

As our data protection officer (DPO), Christopher Gardner has overall
responsibility for the day-to-day implementation of this policy. You should
contact the DPO for further information about this policy if necessary.

Christopher Gardner – admin@webjects.co.uk

The principles

Webjects Limited shall comply with the principles of data protection (the
Principles) enumerated in the EU General Data Protection Regulation. We
will make every effort possible in everything we do to comply with these
principles. The Principles are:

1. Lawful, fair and transparent

Data collection must be fair, for a legal purpose and we must be open and
transparent as to how the data will be used.

2. Limited for its purpose

Data can only be collected for a specific purpose.

3. Data minimisation

Any data collected must be necessary and not excessive for its purpose.

4. Accurate

The data we hold must be accurate and kept up to date.

5. Retention

We cannot store data longer than necessary.

6. Integrity and confidentiality

The data we hold must be kept safe and secure.

Accountability and transparency

We must ensure accountability and transparency in all our use of personal
data. We must show how we comply with each Principle. You are responsible
for keeping a written record of how all the data processing activities you
are responsible for comply with each of the Principles. This must be kept
up to date and must be approved by the DPO.

To comply with data protection laws and the accountability and transparency
Principle of GDPR, we must demonstrate compliance. You are responsible for
understanding your particular responsibilities to ensure we meet the
following data protection obligations:

• Fully implement all appropriate technical and organisational
  measures

• Maintain up to date and relevant documentation on all processing
  activities

• Conducting Data Protection Impact Assessments

• Implement measures to ensure privacy by design and default,
  including:

• Data minimisation

• Pseudonymisation

• Transparency

• Allowing individuals to monitor processing

• Creating and improving security and enhanced privacy procedures
  on an ongoing basis

Our procedures

Fair and lawful processing

We must process personal data fairly and lawfully in accordance with
individuals’ rights under the first Principle. This generally means that we
should not process personal data unless the individual whose details we are
processing has consented to this happening.

If we cannot apply a lawful basis (explained below), our processing does
not conform to the first principle and will be unlawful. Data subjects have
the right to have any data unlawfully processed erased

Controlling vs. processing data

Webjects Limited is classified as a [data controller (and/or) data
processor]. We must maintain our appropriate registration with the
Information Commissioners Office in order to continue lawfully [controlling
(and/or) processing] data.

[For data processors] As a data processor, we must comply with our
contractual obligations and act only on the documented instructions of the
data controller. If we at any point determine the purpose and means of
processing out with the instructions of the controller, we shall be
considered a data controller and therefore breach our contract with the
controller and have the same liability as the controller. As a data
processor, we must:

• Not use a sub-processor without written authorisation of the data
  controller

• Co-operate fully with the ICO or other supervisory authority

• Ensure the security of the processing

• Keep accurate records of processing activities

• Notify the controller of any personal data breaches

If you are in any doubt about how we handle data, contact the DPO for
clarification.

Lawful basis for processing data

We must establish a lawful basis for processing data. Ensure that any data
you are responsible for managing has a written lawful basis approved by the
DPO. It is your responsibility to check the lawful basis for any data you
are working with and ensure all of your actions comply the lawful basis. At
least one of the following conditions must apply whenever we process
personal data:

1. Consent

We hold recent, clear, explicit, and defined consent for the individual’s
data to be processed for a specific purpose.

2. Contract

The processing is necessary to fulfil or prepare a contract for the
individual.

3. Legal obligation

We have a legal obligation to process the data (excluding a contract).

4. Vital interests

Processing the data is necessary to protect a person’s life or in a medical
situation.

5. Public function

Processing necessary to carry out a public function, a task of public
interest or the function has a clear basis in law.

6. Legitimate interest

The processing is necessary for our legitimate interests. This condition
does not apply if there is a good reason to protect the individual’s
personal data which overrides the legitimate interest.

Deciding which condition to rely on

If you are making an assessment of the lawful basis, you must first
establish that the processing is necessary. This means the processing must
be a targeted, appropriate way of achieving the stated purpose. You cannot
rely on a lawful basis if you can reasonable achieve the same purpose by
some other means.

Remember that more than one basis may apply, and you should rely on what
will best fit the purpose, not what is easiest.

Consider the following factors and document your answers:

• What is the purpose for processing the data?

• Can it reasonably be done in a different way?

• Is there a choice as to whether or not to process the data?

• Who does the processing benefit?

• After selecting the lawful basis, is this the same as the lawful
  basis the data subject would expect?

• What is the impact of the processing on the individual?

• Are you in a position of power over them?

• Are they a vulnerable person?

• Would they be likely to object to the processing?

• Are you able to stop the processing at any time on request, and
  have you factored in how to do this?

Our commitment to the first Principle requires us to document this process
and show that we have considered which lawful basis best applies to each
processing purpose, and fully justify these decisions.

We must also ensure that individuals whose data is being processed by us
are informed of the lawful basis for processing their data, as well as the
intended purpose. This should occur via a privacy notice. This applies
whether we have collected the data directly from the individual, or from
another source.

If you are responsible for making an assessment of the lawful basis and
implementing the privacy notice for the processing activity, you must have
this approved by the DPO.

Special categories of personal data

What are special categories of personal data?

Previously known as sensitive personal data, this means data about an
individual which is more sensitive, so requires more protection. This type
of data could create more significant risks to a person’s fundamental
rights and freedoms, for example by putting them at risk of unlawful
discrimination. The special categories include information about an
individual’s:

• race

• ethnic origin

• politics

• religion

• trade union membership

• genetics

• biometrics (where used for ID purposes)

• health

• sexual orientation

In most cases where we process special categories of personal data we will
require the data subject’s explicit consent to do this unless
exceptional circumstances apply or we are required to do this by law (e.g.
to comply with legal obligations to ensure health and safety at work). Any
such consent will need to clearly identify what the relevant data is, why
it is being processed and to whom it will be disclosed.

The condition for processing special categories of personal data must
comply with the law. If we do not have a lawful basis for processing
special categories of data that processing activity must cease.

Responsibilities

Our responsibilities

• Analysing and documenting the type of personal data we hold

• Checking procedures to ensure they cover all the rights of the
  individual

• Identify the lawful basis for processing data

• Ensuring consent procedures are lawful

• Implementing and reviewing procedures to detect, report and
  investigate personal data breaches

• Store data in safe and secure ways

• Assess the risk that could be posed to individual rights and
  freedoms should data be compromised

Your responsibilities

• Fully understand your data protection obligations

• Check that any data processing activities you are dealing with
  comply with our policy and are justified

• Do not use data in any unlawful way

• Do not store data incorrectly, be careless with it or otherwise
  cause us to breach data protection laws and our policies through
  your actions

• Comply with this policy at all times

• Raise any concerns, notify any breaches or errors, and report
  anything suspicious or contradictory to this policy or our legal
  obligations without delay

Responsibilities of the Data Protection Officer

• Keeping the board updated about data protection responsibilities,
  risks and issues

• Reviewing all data protection procedures and policies on a regular
  basis

• Arranging data protection training and advice for all staff members
  and those included in this policy

• Answering questions on data protection from staff, board members
  and other stakeholders

• Responding to individuals such as clients and employees who wish to
  know which data is being held on them by us

• Checking and approving with third parties that handle the company’s
  data any contracts or agreement regarding data processing

Responsibilities of the IT Manager

• Ensure all systems, services, software and equipment meet
  acceptable security standards

• Checking and scanning security hardware and software regularly to
  ensure it is functioning properly

• Researching third-party services, such as cloud services the
  company is considering using to store or process data

Responsibilities of the Marketing Manager

• Approving data protection statements attached to emails and other
  marketing copy

• Addressing data protection queries from clients, target audiences
  or media outlets

• Coordinating with the DPO to ensure all marketing initiatives
  adhere to data protection laws and the company’s Data Protection
  Policy

Accuracy and relevance

We will ensure that any personal data we process is accurate, adequate,
relevant and not excessive, given the purpose for which it was obtained. We
will not process personal data obtained for one purpose for any unconnected
purpose unless the individual concerned has agreed to this or would
otherwise reasonably expect this.

Individuals may ask that we correct inaccurate personal data relating to
them. If you believe that information is inaccurate you should record the
fact that the accuracy of the information is disputed and inform the DPO.

Data security

You must keep personal data secure against loss or misuse. Where other
organisations process personal data as a service on our behalf, the DPO
will establish what, if any, additional specific data security arrangements
need to be implemented in contracts with those third party organisations.

Storing data securely

• In cases when data is stored on printed paper, it should be kept in
  a secure place where unauthorised personnel cannot access it

• Printed data should be shredded when it is no longer needed

• Data stored on a computer should be protected by strong passwords
  that are changed regularly.

• Data stored on CDs or memory sticks must be encrypted or password
  protected and locked away securely when they are not being used

• The DPO must approve any cloud used to store data

• Servers containing personal data must be kept in a secure location,
  away from general office space

• Data should be regularly backed up in line with the company’s
  backup procedures

• Data should never be saved directly to mobile devices such as
  laptops, tablets or smartphones

• All servers containing sensitive data must be approved and
  protected by security software

• All possible technical measures must be put in place to keep data
  secure

Data retention

We must retain personal data for no longer than is necessary. What is
necessary will depend on the circumstances of each case, taking into
account the reasons that the personal data was obtained, but should be
determined in a manner consistent with our data retention guidelines.

Transferring data internationally

There are restrictions on international transfers of personal data. You
must not transfer personal data abroad, or anywhere else outside of normal
rules and procedures without express permission from the DPO.

Rights of individuals

Individuals have rights to their data which we must respect and comply with
to the best of our ability. We must ensure individuals can exercise their
rights in the following ways:

1. Right to be informed

• Providing privacy notices which are concise, transparent,
  intelligible and easily accessible, free of charge, that are
  written in clear and plain language, particularly if aimed at
  children.

• Keeping a record of how we use personal data to demonstrate
  compliance with the need for accountability and transparency.

2. Right of access

• Enabling individuals to access their personal data and
  supplementary information

• Allowing individuals to be aware of and verify the lawfulness of
  the processing activities

3. Right to rectification

• We must rectify or amend the personal data of the individual if
  requested because it is inaccurate or incomplete.

• This must be done without delay, and no later than one month. This
  can be extended to two months with permission from the DPO.

4. Right to erasure

• We must delete or remove an individual’s data if requested and
  there is no compelling reason for its continued processing.

5. Right to restrict processing

• We must comply with any request to restrict, block, or otherwise
  suppress the processing of personal data.

• We are permitted to store personal data if it has been restricted,
  but not process it further. We must retain enough data to ensure
  the right to restriction is respected in the future.

6. Right to data portability

• We must provide individuals with their data so that they can reuse
  it for their own purposes or across different services.

• We must provide it in a commonly used, machine-readable format, and
  send it directly to another controller if requested.

7. Right to object

• We must respect the right of an individual to object to data
  processing based on legitimate interest or the performance of a
  public interest task.

• We must respect the right of an individual to object to direct
  marketing, including profiling.

• We must respect the right of an individual to object to processing
  their data for scientific and historical research and statistics.

8. Rights in relation to automated decision making and profiling

• We must respect the rights of individuals in relation to automated
  decision making and profiling.

• Individuals retain their right to object to such automated
  processing, have the rationale explained to them, and request human
  intervention.

Privacy notices

When to supply a privacy notice

A privacy notice must be supplied at the time the data is obtained if
obtained directly from the data subject. If the data is not obtained
directly from the data subject, the privacy notice must be provided within
a reasonable period of having obtained the data, which mean within one
month.

If the data is being used to communicate with the individual, then the
privacy notice must be supplied at the latest when the first communication
takes place.

If disclosure to another recipient is envisaged, then the privacy notice
must be supplied prior to the data being disclosed.

What to include in a privacy notice

Privacy notices must be concise, transparent, intelligible and easily
accessible. They are provided free of charge and must be written in clear
and plain language, particularly if aimed at children

The following information must be included in a privacy notice to all data
subjects:

• Identification and contact information of the data controller and
  the data protection officer

• The purpose of processing the data and the lawful basis for doing
  so

• The legitimate interests of the controller or third party, if
  applicable

• The right to withdraw consent at any time, if applicable

• The category of the personal data (only for data not obtained
  directly from the data subject)

• Any recipient or categories of recipients of the personal data

• Detailed information of any transfers to third countries and
  safeguards in place

• The retention period of the data or the criteria used to determine
  the retention period, including details for the data disposal after
  the retention period

• The right to lodge a complaint with the ICO, and internal complaint
  procedures

• The source of the personal data, and whether it came from publicly
  available sources (only for data not obtained directly from the
  data subject)

• Any existence of automated decision making, including profiling and
  information about how those decisions are made, their significances
  and consequences to the data subject

• Whether the provision of personal data is part of a statutory of
  contractual requirement or obligation and possible consequences for
  any failure to provide the data (only for data obtained directly
  from the data subject)

Subject Access Requests

What is a subject access request?

An individual has the right to receive confirmation that their data is
being processed, access to their personal data and supplementary
information which means the information which should be provided in a
privacy notice.

How we deal with subject access requests

We must provide an individual with a copy of the information the request,
free of charge. This must occur without delay, and within one month of
receipt. We endeavour to provide data subjects access to their information
in commonly used electronic formats, and where possible, provide direct
access to the information through a remote accessed secure system.

If complying with the request is complex or numerous, the deadline can be
extended by two months, but the individual must be informed within one
month. You must obtain approval from the DPO before extending the deadline.

We can refuse to respond to certain requests, and can, in circumstances of
the request being manifestly unfounded or excessive, charge a fee. If the
request is for a large quantity of data, we can request the individual
specify the information they are requesting. This can only be done with
express permission from the DPO.

Once a subject access request has been made, you must not change or amend
any of the data that has been requested. Doing so is a criminal offence.

Data portability requests

We must provide the data requested in a structured, commonly used and
machine-readable format. This would normally be a CSV file, although other
formats are acceptable. We must provide this data either to the individual
who has requested it, or to the data controller they have requested it be
sent to. This must be done free of charge and without delay, and no later
than one month. This can be extended to two months for complex or numerous
requests, but the individual must be informed of the extension within one
month and you must receive express permission from the DPO first.

Right to erasure

What is the right to erasure?

Individuals have a right to have their data erased and for processing to
cease in the following circumstances:

• Where the personal data is no longer necessary in relation to the
  purpose for which it was originally collected and / or processed

• Where consent is withdrawn

• Where the individual objects to processing and there is no
  overriding legitimate interest for continuing the processing

• The personal data was unlawfully processed or otherwise breached
  data protection laws

• To comply with a legal obligation

• The processing relates to a child

How we deal with the right to erasure

We can only refuse to comply with a right to erasure in the following
circumstances:

• To exercise the right of freedom of expression and information

• To comply with a legal obligation for the performance of a public
  interest task or exercise of official authority

• For public health purposes in the public interest

• For archiving purposes in the public interest, scientific research,
  historical research or statistical purposes

• The exercise or defence of legal claims

If personal data that needs to be erased has been passed onto other parties
or recipients, they must be contacted and informed of their obligation to
erase the data. If the individual asks, we must inform them of those
recipients.

The right to object

Individuals have the right to object to their data being used on grounds
relating to their particular situation. We must cease processing unless:

• We have legitimate grounds for processing which override the
  interests, rights and freedoms of the individual.

• The processing relates to the establishment, exercise or defence of
  legal claims.

We must always inform the individual of their right to object at the first
point of communication, i.e. in the privacy notice. We must offer a way for
individuals to object online.

The right to restrict automated profiling or decision making

We may only carry out automated profiling or decision making that has a
legal or similarly significant effect on an individual in the following
circumstances:

• It is necessary for the entry into or performance of a contract.

• Based on the individual’s explicit consent.

• Otherwise authorised by law.

In these circumstances, we must:

• Give individuals detailed information about the automated
  processing.

• Offer simple ways for them to request human intervention or
  challenge any decision about them.

• Carry out regular checks and user testing to ensure our systems are
  working as intended.

Third parties

Using third party controllers and processors

As a [data controller (and/or) data processor], we must have written
contracts in place with any third party [data controllers (and/or) data
processors] that we use. The contract must contain specific clauses which
set out our and their liabilities, obligations and responsibilities.

[For controllers] As a data controller, we must only appoint processors who
can provide sufficient guarantees under GDPR and that the rights of data
subjects will be respected and protected.

[For processors] As a data processor, we must only act on the documented
instructions of a controller. We acknowledge our responsibilities as a data
processor under GDPR and we will protect and respect the rights of data
subjects.

Contracts

Our contracts must comply with the standards set out by the ICO and, where
possible, follow the standard contractual clauses which are available. Our
contracts with [data controllers (and/or) data processors] must set out the
subject matter and duration of the processing, the nature and stated
purpose of the processing activities, the types of personal data and
categories of data subject, and the obligations and rights of the
controller.

At a minimum, our contracts must include terms that specify:

• Acting only on written instructions

• Those involved in processing the data are subject to a duty of
  confidence

• Appropriate measures will be taken to ensure the security of the
  processing

• Sub-processors will only be engaged with the prior consent of the
  controller and under a written contract

• The controller will assist the processor in dealing with subject
  access requests and allowing data subjects to exercise their rights
  under GDPR

• The processor will assist the controller in meeting its GDPR
  obligations in relation to the security of processing, notification
  of data breaches and implementation of Data Protection Impact
  Assessments

• Delete or return all personal data at the end of the contract

• Submit to regular audits and inspections, and provide whatever
  information necessary for the controller and processor to meet
  their legal obligations.

• Nothing will be done by either the controller or processor to
  infringe on GDPR.

Criminal offence data

Criminal record checks

Any criminal record checks are justified by law. Criminal record checks
cannot be undertaken based solely on the consent of the subject. We cannot
keep a comprehensive register of criminal offence data. All data relating
to criminal offences is considered to be a special category of personal
data and must be treated as such. You must have approval from the DPO prior
to carrying out a criminal record check.

Audits, monitoring and training

Data audits

Regular data audits to manage and mitigate risks will inform the data
register. This contains information on what data is held, where it is
stored, how it is used, who is responsible and any further regulations or
retention timescales that may be relevant. You must conduct a regular data
audit as defined by the DPO and normal procedures.

Monitoring

Everyone must observe this policy. The DPO has overall responsibility for
this policy. Webjects Limited will keep this policy under review and amend
or change it as required. You must notify the DPO of any breaches of this
policy. You must comply with this policy fully and at all times.

Training

You will receive adequate training on provisions of data protection law
specific for your role. You must complete all training as requested. If you
move role or responsibilities, you are responsible for requesting new data
protection training relevant to your new role or responsibilities.

If you require additional training on data protection matters, contact the
DPO.

Reporting breaches

Any breach of this policy or of data protection laws must be reported as
soon as practically possible. This means as soon as you have become aware
of a breach. Webjects Limited has a legal obligation to report any data
breaches to Christopher Gardner within [72 hours].

All members of staff have an obligation to report actual or potential data
protection compliance failures. This allows us to:

• Investigate the failure and take remedial steps if necessary
  Maintain a register of compliance failures

• Notify the Christopher Gardner of any compliance failures that are
  material either in their own right or as part of a pattern of
  failures

Any member of staff who fails to notify of a breach, or is found to have
known or suspected a breach has occurred but has not followed the correct
reporting procedures will be liable to disciplinary action.

Please refer to our controller for our reporting procedure.

Failure to comply

We take compliance with this policy very seriously. Failure to comply
puts both you and the organisation at risk.

The importance of this policy means that failure to comply with any
requirement may lead to disciplinary action under our procedures which may
result in dismissal.

If you have any questions or concerns about anything in this policy, do not
hesitate to contact the DPO.