This privacy policy ("Privacy Policy") applies to personal data that we collect from you as a customer ("you" or "your"). It provides information on what data we collect, why we collect the data, how it is used and the lawful basis on which your personal data is processed, and what your rights are under the applicable data protection and privacy laws, including the UK General Data Protection Regulation ("UK GDPR").
We are Fletcher Digital Limited, a company registered in Scotland. We are the data controller responsible for your personal data.
We collect the following information from you:
Personal information: This includes your name, business name, address, e-mail address, phone number, job title, and other information that you elect to provide to us when enquiring about or using our services.
Payment Information: Information about your debit/credit card and bank account information provided by you to our payment service providers, that we require for the purpose of processing payment for our goods and services.
Technical and Account Information: Where we provide hosting, software, or platform services, we may collect login credentials, usage data, IP addresses, browser information, and other technical data necessary to deliver and secure our services.
Other Information: Personal details you choose to give when corresponding with us by phone or e-mail or through our websites and applications.
We use your personal information in the following ways:
To provide you with our services and to create and deliver the products you have requested and contact you regarding your use of the services. Such use is necessary to respond to or implement your request and for the performance of the contract between you and us.
As necessary for certain legitimate business interests, which include the following:
We may provide you with information about goods or services, events and other promotions we feel may interest you. We will contact you by email only with your consent, if this was given at the time you provided us with the personal data.
We may use your personal data for other purposes which you have consented to at the time of providing your data.
As used in this Privacy Policy, "legitimate interests" means our interests in conducting and managing our business. When we process your personal data for our legitimate interests, we make sure to consider and balance any potential impact on you, and your rights under data protection laws. Our legitimate interests do not automatically override your interests. We will not use your personal data for activities where our interests are overridden by the impact on you, unless we have your consent or those activities are otherwise required or permitted to by law. You have the right to object at any time to processing of your personal data that is based on our legitimate interests, on grounds relating to your particular situation (for more information on your rights, please see "Your Data Protection Rights" section below).
We share your personal data with third parties in the following situations:
Service Providers: we sometimes engage selected third parties who act on our behalf to support our operations, such as (i) card processing or payment services (see the section below headed "Payment Information"), (ii) IT suppliers and contractors (e.g. data hosting providers, cloud infrastructure providers, email service providers) as necessary to provide IT support and enable us to provide our goods and services, and (iii) providers of specialist services including marketing, analytics, and professional advisors. Pursuant to our instructions, these parties may access, process or store your personal data in the course of performing their duties to us and solely in order to perform the services we have hired them to provide.
Business Transfers: if we sell our business or our company assets are acquired by a third party, personal data held by us about our customers may be one of the transferred assets.
Administrative and Legal Reasons: if we need to disclose your personal data (i) to comply with a legal obligation and/or judicial or regulatory proceedings, a court order or other legal process, (ii) to enforce our Terms & Conditions or other applicable contract terms that you are subject to, (iii) to protect us, our members or contractors against loss or damage. This may include (without limit) exchanging information with the police, courts or law enforcement organisations.
Any credit/debit card payments and other payments you make will be processed by our third party payment providers and the payment data you submit will be securely stored and encrypted by our payment service providers using up to date industry standards. Please note that we do not ourselves directly process or store the debit/credit card data that you submit.
We store and use this card or payment information for the purpose of processing any future payments that you make for additional goods and services. We will store this data in accordance with our legal obligations under applicable law and only for so long as legally permitted.
You may choose to opt out of us holding your card or payment data although this means that you will need to re-supply us with card/payment details for the purpose of making any future purchases.
Your personal data may be transferred to and stored in countries other than the country in which the information was originally collected, including the United States and other destinations outside the United Kingdom and European Economic Area ("EEA") to our service providers for the purposes described above.
Please note that the countries concerned may not provide the same legal standards for protection of your personal data that you have in the United Kingdom or EEA. Where we transfer your personal data to countries outside of the UK or EEA we will take all steps to ensure that your personal data continues to be protected. We will implement appropriate safeguards for the transfer of personal data to our service providers in accordance with the applicable law, such as relying on adequacy decisions or implementing standard contractual clauses for data transfers. If you would like to receive more information on the safeguards that we implement, including copies of relevant data transfer contracts, please contact us as indicated below.
We will keep your personal data only for as long as is reasonably necessary for the purposes outlined in this Privacy Policy, or for the duration required by any legal, regulatory, accounting or reporting requirements, whichever is the longer. In particular, we retain client and contact data for the duration of our business relationship and for a period of seven years thereafter to meet our legal and accounting obligations. When you consent to receive marketing communications, we will keep your data until you unsubscribe. Upon expiry of the applicable retention period we will securely destroy your personal data in accordance with applicable laws and regulations.
Certain applicable data protection laws give you specific rights in relation to your personal data. In particular, if the processing of your personal data is subject to the UK GDPR, you have the following rights in relation to your personal data:
Right of access: If you ask us, we will confirm whether we are processing your personal data and, if so, provide you with a copy of that personal data along with certain other details. If you require additional copies, we may need to charge a reasonable fee.
Right to rectification: If your personal data is inaccurate or incomplete, you are entitled to ask that we correct or complete it. If we shared your personal data with others, we will tell them about the correction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your personal data so you can contact them directly.
Right to erasure: You may ask us to delete or remove your personal data, such as where our legal basis for the processing is your consent and you withdraw consent. If we shared your data with others, we will tell them about the erasure where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your personal data so you can contact them directly. We may continue processing personal data where this is necessary for a legitimate interest in doing so, as described in this Privacy Policy.
Right to restrict processing: You may ask us to restrict or 'block' the processing of your personal data in certain circumstances, such as where you contest the accuracy of the data or object to us processing it. We will tell you before we lift any restriction on processing. If we shared your personal data with others, we will tell them about the restriction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your personal data so you can contact them directly.
Right to object: You may ask us at any time to stop processing your personal data, and we will do so:
Right to withdraw consent: If we rely on your consent to process your personal data, you have the right to withdraw that consent at any time. This will not affect the lawfulness of processing of your data before we received notice that you wished to withdraw your consent.
Right to lodge a complaint with the data protection authority: If you have a concern about our privacy practices, including the way we handled your personal data, you can report it to the UK data protection authority (the Information Commissioner's Office or ICO), or, as the case may be, any other competent data protection authority of an EU member state that is authorised to hear those concerns.
If you wish to exercise any of these rights please contact us as described in the "Contact" section below. We may also need to ask you for further information to verify your identity before we can respond to any request.
Questions, comments or requests regarding this Privacy Policy should be addressed to info@fletcherdigital.uk
