Data Protection Notice for Website Users, Customers and Potential Customers
1.1 Project11 Limited (“Project 11”, “we“, “our“, “us“) are committed to protecting personal data and respecting your privacy.
1.2 This notice (“Notice”) sets out how and why we collect, use and disclose personal data that we receive from you or otherwise obtain about you.
2 Data Controller
Project11 Limited is the data controller in respect of your personal data. We are registered in the United Kingdom with company number 9118089, and our registered office address is Solar House, Chase Road London, N14 6NZ.
2.1 Questions, comments and requests regarding this Notice may be emailed to email@example.com or sent by post to the above mentioned address.
3 SOURCES AND CATEGORIES OF PERSONAL DATA THAT WE COLLECT, PURPOSES FOR PROCESSING AND LAWFUL BASIS
3.1 We collect various types of personal data about our prospective customers and business contacts for marketing purposes.
3.2 We may obtain your personal data directly from you or from a company with which you are employed or associated as an officer or shareholder. You may also provide personal data to us by filling out any of our forms. We may also obtain your personal data from publically available sources or through your use of our website.
3.3 As our current or potential business contact it is in our legitimate business interest to process the following for the purposes of marketing our products or services to you:
a) your name;
b) contact details; and
c) information on your job role.
3.4 As a website user we may process your personal data for the following purposes on the basis of our legitimate interests:
a) responding to the contents of your email to us;
b) internal record keeping;
c) improvement of our products / services;
d) transmission by email of promotional materials that may be of interest to you, where you have consented for us to do so;
e) contact for market research purposes which may be done using email. Such information may be used to customise or update the Website.
4 SHARING OF YOUR PERSONAL DATA
4.1 We do not share your personal data with third parties or sell our marketing lists [without your permission].
4.2 We may disclose personal data to comply with any legal or regulatory obligation, or to enforce any contracts with us or to protect the rights, property, or safety of Project11, and this may include disclosing personal data required from us by governmental or law enforcement authorities or a trade association of which we are a member.
4.3 We may also use and disclose personal information when you provide that information to us and with your consent.
4.4 In the event that we sell or buy any business or assets, we may disclose your personal information to the prospective seller or buyer of such business or assets. If Project11, or substantially all of its assets, are acquired by a third party, personal data held by us will be one of the transferred assets.
5 HOW LONG DO WE KEEP YOUR PERSONAL DATA?
5.1 Project11 will keep the personal data relating to you for marketing purposes for the period that you remain on our marketing lists. We will check with you every [2 years] to make sure that you remain on our marketing lists and you can ask to be removed at any time.
5.2 We only retain personal data for longer periods where you have given us your consent to do so or as necessary to meet our legal obligations or in order to establish, exercise or defend potential legal claims.
6 YOUR RIGHTS
6.1 You have the following rights:
a) To object to the processing of your personal data for the purposes of direct marketing.
b) to obtain access to your personal data – you may request information on how your personal data is handled by us and request a copy of such personal data;
c) to request us to correct or update your personal data if it is inaccurate or out of date;
d) to object to the processing of your personal data for the purposes of our legitimate interests, unless we:
i. demonstrate compelling legitimate grounds which override your right to object, or
ii. the processing is necessary for the establishment, exercise or defence of legal claims;
e) to erase your personal data held by us:
i. which are no longer necessary in relation to the purposes for which they were collected,
ii. to the processing of which you object, or
iii. which may have been unlawfully processed by us;
f) to restrict processing by us, i.e. the processing will be limited to storage only:
i. where you oppose to deletion of your personal data and prefer restriction of processing instead, or
ii. where you object to the processing by us on the basis of its legitimate interests (see para 7.1(c) above); and
g) to transmit personal data you submitted to us back to you or to another organisation in certain circumstances.
6.2 These rights are not absolute and may be subject to certain conditions under the GDPR. Should you wish to exercise any of these rights, please contact Company using the details in paragraph 2.1 and provides us with at least the following:
a) your name;
b) proof of identity;
c) the right you want to exercise;
d) the personal data to which it relates.
6.3 Where processing of your personal data is based on your consent you have the right to withdraw your consent at any time, this will not affect the lawfulness of processing based on your consent prior to withdrawal.
7.1 If you are unhappy with how we handle your personal data, please address your complaint(s) to the physical address specified in paragraph 2.1 above.
7.2 In addition, you have the right to file a complaint with the Information Commissioner’s Office, the UK data protection supervisory authority.