PRIVACY POLICY
This Privacy Policy describes how whitestep.co.uk (the “Site” or “we”) collects, uses, and discloses your Personal Data in accordance with the requirements of all applicable data protection legislation, including the EU GDPR, the UK GDPR and the Data Protection Act 2018.
We are committed to protecting and respecting your privacy. This policy sets out the legal basis on which any Personal Data we collect from you or that you provide will be processed by us. Please read the following carefully to understand our views and practices regarding your Personal Data and how we will treat it.
COLLECTING PERSONAL DATA
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).
When you visit the Site, we automatically collect certain information about your web browser, IP address, time zone and cookies installed on your device as well as the Information necessary to process your purchases. We may also collect additional Information if you contact us for customer support, comment on or review our products, or sign up for news, offers, events and new product launches. In this Privacy Policy, we refer to any information that can uniquely identify an individual (including the Information below) as “Personal Information”, and we refer to automatically collected information as “Device Information”. See the list below for more information about what Personal Information we collect.
Device information:
• examples of Personal Information collected: version of web browser, IP address, time zone, cookie information, what sites or products you view, search terms, and how you interact with the Site.
• Source of collection: Collected automatically when you access our Site using cookies, log files, web beacons, tags, or pixels.
• Disclosure for a business purpose: shared with our processor WordPress.
Identity and Contact Data: includes your personal or professional contact information and/or other personal identification information, such as your name, last name, title, gender, job role, employer name, email address, telephone number and address;
Financial and Transaction Data: includes, where appropriate, details about payments to and from you in the course of the operation or our business or engagement and also a record of your bank account and payment card details;
Communications Data: includes details of any communications with you, your communication preferences, any communications which relate to you, and any feedback, responses, comments, or opinions provided by you.
Marketing Data: includes your preferences in receiving marketing from us.
We may also collect, use and share Aggregated Data, such as statistical or demographic data, for any purpose. Aggregated Data could be derived from your 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 and Technical 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 notice.
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.
MINORS
The Site is not intended for individuals under the age of 18. We do not intentionally collect Personal Information from children. If you are the parent or guardian and believe your child has provided us with Personal Information, please contact us at the address below to request deletion.
COOKIES
A cookie is a small amount of information downloaded to your computer or device when you visit our site. We use a number of different cookies, including functional, performance, advertising, and social media or content cookies. Cookies improve your browsing experience by allowing the website to remember your actions and preferences (such as login and region selection). This means you don’t have to re-enter this information when you return to the site or browse from page to page. Cookies also provide information on how people use the website, for instance, whether it’s their first time visiting or if they are frequent visitors.
You can control and manage cookies in various ways. Please keep in mind that removing or blocking cookies can negatively impact your user experience, and parts of our website may no longer be fully accessible.
Most browsers automatically accept cookies, but you can choose whether or not to accept cookies through your browser controls, often found in your browser’s “Tools” or “Preferences” menu. For more information on how to modify your browser settings or block, manage or filter cookies can be found in your browser’s help file or through such sites as all about cookies
Additionally, please note that blocking cookies may only partially prevent how we share information with third parties, such as our advertising partners.
GOOGLE ANALYTICS
This Website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies (text files placed on your computer) to help the website operators analyse how users use the site. The information generated by the cookie about your use of the Website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the Website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. By using this Website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.
USING AND SHARING 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.
We share your Personal Information with service providers to help us provide our services and fulfil our contracts with you. For example:
• We may share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.
• Internal third parties, such as other companies within our corporate group.
• External third-party service providers, including providers of IT services, cloud / hosting services, system administration services, and payment processing services.
• External third-party professional advisers, including lawyers, surveyors, financial advisers, bankers, auditors and insurers.
• Local authorities / councils, HM Revenue & Customs, regulators, and other relevant public authorities.
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.
BEHAVIOURAL ADVERTISING
As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For example:
• We use Google Analytics to help us understand how our customers use the Site. You can read more about how Google uses your Personal Information here: https://policies.google.com/privacy?hl=en.You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.
For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.
You can opt out of targeted advertising by using the links below:
• Facebook: https://www.facebook.com/settings/?tab=ads
• Google: https://www.google.com/settings/ads/anonymous
• Bing: https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads
Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/.
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 are subject to a duty of confidentiality.
We have established 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
We will only retain your Personal Information for our records as long as reasonably necessary unless and until you ask us to erase this information. We may retain your personal data for a more extended period in case of a complaint or if we reasonably believe there is a prospect of litigation concerning 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.
We do not sell, trade, or otherwise transfer your Personally Identifiable Information to outside parties.
We do not alter our Site’s data collection and use practices when we see a Do Not Track signal from your browser.
YOUR LEGAL RIGHTS
You have the right to:
• Request access to your Personal Data we hold about you.
• To port it to a new service.
• To ask that your Personal Information be corrected, updated, or erased.
• Request restriction of processing your personal data
• Right to withdraw consent
If you would like to exercise these rights, please contact us through the contact information below.
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.
REGULATORS
Please note that under the UK GDPR you have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). To the extent that the EU GDPR applies to our processing of your personal data, you have the right to make a complaint at any time to a supervisory authority in the EEA. We would, however, appreciate the chance to deal with your concerns before you approach the ICO or any supervisory authority, so please contact us in the first instance.
CONTACT DETAILS
For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e-mail at enquiry@whitestep.co.uk or by post using the details set out below:
Whitestep Limited
Unit 1
45 Circus Road
London, NW8 9JH
CHANGES
We may update this Privacy Policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal, or regulatory reasons.