information security2018-10-11T14:07:06+00:00

As a provider of hosted unified communications services, we recognise and are committed to maintaining the highest standards of information security.

The scope of information security is broad and we believe we have taken a thorough approach with our commitment to ensuring the confidentiality, integrity and availability of customer, supplier and employee data.

We operate in a highly regulated industry and in addition to adherence to voluntary codes of conduct we are a member of ITSPA.

Gradwell are also an ISO/IEC 27001:2013 certified organisation, reflecting our commitment to information security and continual improvement.  We have a dedicated team in place to monitor current regulation, assess compliance and coordinate activities to ensure Gradwell continue to meet requirements.

As part of our ISMS framework, we have a robust disaster recovery and failover process that is periodically tested and invest in vulnerability scans and penetration tests to identify and respond effectively to potential risks.

Should you have any queries about our approach to information assurance and regulatory compliance please complete the form or contact our Information Security team.

GDPR

The EU General Data Protection Regulation (GDPR) comes into legally enforceable effect on 25th May 2018 replacing the Data Protection Directive (DPD). If you are making your own preparations, you will know that this is not a trivial exercise. The good news is that we are on track to be compliant by the deadline. Our ongoing commitment to ISO27001, an international data security standard and best practice approach, along with a team dedicated to compliance has given us a significant head start.

What is GDPR?

The European Union General Data Protection Regulation (GDPR) has been put into effect to ensure a consistent approach, where previously a Directive (Data Protection Directive) relied on interpretation and localised laws which conflicted across European countries.

The Regulation reflects a collaboration of the European Economic Area to provide a solution to application of data protection law and enhancing the rights of individuals in the first major overhaul for many years.

Each country will have a Supervisory Authority in place to regulate compliance and issue fines dependent on the impact to the rights and privacy of the individual/s affected. For the UK this is the Information Commissioners Office (ICO) and maximum penalties for breach of the GDPR can be very high.

What has changed?

Anybody responsible for controlling or processing an individual’s personal data will now be required to ensure there is a lawful reason for collection and processing, where relevant consent is secured and is made freely and easy to retract, only the necessary data required is retained and only for as long as it is required.

The sharing of individual’s data is also restricted with further explicit consent being required if using or wishing to share with other parties for any other purpose than it was originally collected for unless other lawful reasons for sharing the data apply, for example to investigate criminal activity or in the best interests of the data subject.

A person will now be able to easily access their personal data, make applications to correct, port, restrict or have it deleted under qualifying circumstances.

For full details on changes to data protection regulation please refer to the ICO website www.ico.org.uk

Your Legal Rights under GDPR

The right to be informed

Individuals have a right to understand when their personal data is being held and processed, even when this has been obtained indirectly.

The right of access

You can request access to your personal data at any time to be aware of and verify the lawfulness of the processing, this is via a Subject Access Request (see below).

The right to rectification

Personal data can be easily rectified if inaccurate, incomplete or out of date. This can be done by updating your control panel (insert link) or by written request (please see below for information)

The right to erasure

Under qualifying criteria, you can request your data to be deleted where there is no lawful reason for its continued processing. Please refer to the GDPR regulation or ico.org.uk for full details.

The right to restrict processing

Under qualifying criteria, you can request the processing of your data to be restricted. This means your data will still be held but not processed and may apply where information is inaccurate or if there is an objection over the lawfulness of the processing. Please refer to the GDPR regulation or ico.org.uk for full details. Please send your request in writing as per the below instructions.

Where data is restricted, Gradwell shall, where possible, also inform any involved 3rd parties of the restriction.

The right to data portability

Individuals can request personal data to be provided in order to reuse elsewhere and/or moved from one IT environment to another in a secure manner without hindrance. Please send your request in writing as per the below instructions.

The right to object

Where processing of your data is taking place under certain purposes and no legitimate reason exists for this, you have the right to object. Please send your request in writing as per the below instructions.

Rights in relation to automated decision making and profiling

Automated decision making, and profiling can only take place where consent or a lawful reason apply. Processors are also required to notify individuals when their data is processed by automated means and provide information about the processing and lawful reason for doing so. It should be straightforward for an individual to challenge or request intervention.

What are we doing about it?

 Here is a brief overview of our preparations over the last six months:

  • We have assigned a Data Protection Officer (DPO) who is part of a core team working on the project.  In addition, we have dedicated Information Asset Owners (IAOs) for each of our in-house departments to field queries and provide feedback.
  • We have a fully documented project plan and have conducted Data Protection Impact Assessments (DPIAs). These DPIAs help us to understand what personal data is collected, how it is used and stored and feed into data flow and risk assessments
  • Though there isn’t clear published guidance we are in regular contact with the Information Commissioner’s Office (ICO) where necessary.
  • We will provide updates as we implement new features. We are also planning a webinar to share our experiences with you as you make your own preparation.

Accessing my Data – Subject Access Request

If you wish to make a request to access the personal data we hold, you must provide the following:

Application in writing – You will need to make a request in writing, using either the form provided below or via email to governance@gradwell.com or post to Governance Team, Gradwell Communications Ltd, Westpoint, James Street West, Bath. BA1 2DA.

Proof of identity – You will need to provide proof of identity as part of your application. Please provide contact telephone numbers as identity is confirmed via a callback and DPA verification from a member of our team for data protection purposes

What to include in your application – please state the specific data you wish to access

If you wish to apply to restrict, rectify, port, object or request erasure of your data, please submit your request in writing as above also including the qualifying circumstances that apply.

Please note in order to validate your request our staff must verify your identity for data protection purposes and where relevant, confirm the qualifying criteria.

Following verification Gradwell will provide the information and lawful basis for processing your data within one month of receipt. This will be in a format that is concise and intelligible and at no cost to you*.

I agree to Gradwell Communication Ltd's Privacy Policy and our Terms and Conditions. Please tick

ISO

ISO 27001 is an internationally recognised information security management standard which ensures organisations can apply a framework to business processes to help identify, manage and reduce risks to information security, and considers not only IT but all business operations.

Whereas in the past, accreditation levels were required of suppliers to the enterprise market; the same assurances are increasingly sought by organisations of any size, in an effort to manage risk within the business and secure the information it relies on to perform.

Gradwell achieved ISO 27001 certification on 10th March 2016 and are audited regularly against the standard to maintain compliance and drive our continuous improvement programme.

COOKIE POLICY

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.

By continuing to browse the site, you are agreeing to our use of cookies.

A cookie is a small file of letters and numbers that is stored on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.

When a website is visited, devices such as cookies, tags or web beacons may be employed to enable the site owner to identify and monitor visitors. If the website is inappropriate, such a marker could be a source of embarrassment to the visitor and us, especially if inappropriate material has been accessed, downloaded, stored or forwarded from the website.

Such actions may also, in certain circumstances, amount to a criminal offence if, for example, the material is pornographic in nature.

Information about our use of Cookies

We use the following cookies:

Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.

Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.

Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

Disabling Cookies

You can usually disable cookies by adjusting your web browser settings to stop it from accepting cookies. However, this will likely limit the functionality of our Website (and most of the others you visit using that web browser).
The method for disabling cookies and adjusting the cookie settings will depend on which web browser you are using.

Instructions for doing this in the most common web browsers can be found below:

You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

Category: Necessary (5)

Necessary cookies help make our website usable by enabling basic functions like page navigation and access to secure areas of the website. Our website cannot function properly without these cookies.

COOKIE NAME PROVIDER TYPE EXPIRY
__cfduid zopim.com HTTP 1 year
PHPSESSID Gradwell.com HTTP session
wc_cart_hash_# Gradwell.com HTTP session
wc_fragments_# Gradwell.com HTTP session
wp_woocommerce_session_# Gradwell.com HTTP 24 hours

Category: Statistics (4)

Marketing cookies are used to track visitors across websites. The intention is to display ads that are relevant and engaging for the individual user and thereby more valuable for publishers and third party advertisers.

COOKIE NAME PROVIDER TYPE EXPIRY
_ga Gradwell.com HTTP 2 years
_gat Gradwell.com HTTP session
_gid Gradwell.com HTTP session
dtCookie pardot.com HTTP session

Category: Marketing (15)

Marketing cookies are used to track visitors across websites. The intention is to display ads that are relevant and engaging for the individual user and thereby more valuable for publishers and third party advertisers.

COOKIE NAME PROVIDER TYPE EXPIRY
__zlcmid gradwell.com HTTP 2 years
_hjIncludedInSample gradwell.com HTTP session
ads/ga-audiences google.com HTTP session
ads/user-lists/# google.com HTTP session
IDE doubleclick.net HTTP session
lpv17942 Pardot.com HTTP session
pardot Pardot.com HTTP session
PREF youtube HTTP session
test_cookie doubleclick.net HTTP session
visitor_id# gradwell.com HTTP session
visitor_id#-hash gradwell.com HTTP session
visitor_id#-hash Pardot.com HTTP session
VISITOR_INFO1_LIVE youtube.com HTTP session
YSC youtube.com HTTP session
zte# gradwell.com HTTP session

Category: Unclassified (6)

Unclassified cookies are cookies that we are in the process of classifying, together with the providers of individual cookies.

COOKIE NAME PROVIDER TYPE EXPIRY
__zlcid Gradwell.com HTTP 2 years
__zlcstore Gradwell.com HTTP session
AWSALB ie08.zopim.com HTTP session
gwcc Gradwell.com HTTP session
laravel_session app.leadformly.com HTTP session
who.ashx dashboard.whoisvisiting.com HTTP session

Privacy Policy

Welcome to the Gradwell Communications Limited privacy policy.

Gradwell Communications Limited respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

This privacy policy is provided in a layered format so you can click through to the specific areas set out below. Alternatively, you can download a pdf version of the policy here. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.

“Gradwell Communications Limited” is registered in the UK with the Data Protection Registrar for the purposes of storing personal data. Our registration number is Z7041930

Important information and who we are

Purpose of this privacy policy

This privacy policy aims to give you information on how Gradwell Communications Limited collects and processes your personal data through your use of this website and other interactions with us, including any data you may provide through this website when you make an enquiry or purchase a service.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Controller

Gradwell Communications Limited is the controller and responsible for your personal data (also referred to as “we”, “us” or “our” in this privacy policy).

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact our data privacy manager in the following ways:

Full name of legal entity: Gradwell Communications Limited

Email address: governance@gradwell.com

Postal address: Westpoint, James Street West, Bath, BA1 2DA

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated in June 2018.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes first name, last name, username or similar identifier and title.
  • Contact Data includes billing address, delivery address, email address and telephone numbers.
  • Financial Data includes bank account and payment card details.
  • Transaction Data includes details about payments to and from you and details of products and services you have purchased from us.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
  • Profile Data includes your username and password and purchases or orders made by you.
  • Usage Data includes information about how you use our website, products and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity, Contact and Financial Data by filling in online forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

• purchase our products or services;
• create an account on our website;
• use a chat room to speak with our team;
• subscribe to our service or publications;
• request marketing to be sent to you;
• enter a promotion or survey; or
• give us feedback or contact us.

Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy above for further details.

Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:

Technical Data from the following parties:

(a) analytics providers such as Google; and
(b) search information providers such as Google or Bing.
Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Paypal and Stripe.
Identity and Contact Data from data brokers or aggregators such as Marketing VF Limited and Intelligence Media Limited.
Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register.

How we use your personal data

How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you or create an online account as a new customer (a) Identity

(b) Contact

Performance of a contract with you
To process and deliver your order including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To enable you to partake in a competition or complete a survey (a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

To enable you to use our public forums. (a) Identity

(b) Profile

(c) Usage

(d) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services to grow our business)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity

(b) Contact

(c) Technical

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of our  advertising (a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences (a) Technical

(b) Usage

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you (a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

(f) Marketing and Communications

Necessary for our legitimate interests (to develop our products/services and grow our business)

 

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

If you receive marketing communications from us it may be because you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy found above.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table above.

  • External Third Parties as set out in the Glossary.
  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

International transfers

Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented, data will only be transferred:

  • to a country that the European Commission deems to provide an adequate level of protection for personal data;
  • where the European Commission has approved the specific contract or contract terms; or
  • where the provider is based in the US, where it is part of the Privacy Shield.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data Retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by emailing governance@gradwell.com

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

You have the right to:

1. Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

2. Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

3. Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

4. Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

5. Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

  • If you want us to establish the data’s accuracy.
  • Where our use of the data is unlawful but you do not want us to erase it.
  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

6. Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

7. Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us at seniortech@gradwell.com.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Lawful Basis

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

THIRD PARTIES

External Third Parties

  • Service providers acting as processors, such as:
    • Our marketing providers who collect and store personal data to enable us to send marketing communications to you and improve our marketing offering.
    • Our website hosting, development and maintenance service providers.
    • Our external IT system administration and support function.
    • Shipping providers who process delivery information on our behalf.
    • Third parties who provide processing services in respect of order processing, fulfilment and accounting as well as record keeping to facilitate and improve the customer experience.
  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
  • HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers who require reporting of processing activities in certain circumstances.