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--- privacy_policy [2019/04/14 15:21]
admin
+++ privacy_policy [2019/04/27 19:19] (current)
admin
@@ Line 113: / Line 113: @@
 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.
 ====6 International transfers====
-[We do not transfer your personal data outside the European Economic Area (EEA).]
-OR
+Some of our external third parties are based outside the EEA, so their processing of your personal data will involve a transfer of data outside the EEA.
-[Some of our external third parties are based outside the 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:
   * We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
   * Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
   * Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US 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.]
+Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
 ====7 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.
@@ Line 129: / Line 128: @@
 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.
 By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for seven years after they cease being customers for accounting and tax purposes.
-In some circumstances you can ask us to delete your data: see your legal rights [INSERT LINK] below for further information.
+In some circumstances you can ask us to delete your data: see your legal rights [[privacy_policy#your_legal_rights|9 Your legal rights]] below for further information.
 In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
 ====9 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:
+Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
-  * Request access to your personal data [INSERT LINK].
-  * Request correction of your personal data [INSERT LINK].
+  * **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
-  * Request erasure of your personal data [INSERT LINK].
-  * Object to processing of your personal data [INSERT LINK].
+  * **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
-  * Request restriction of processing your personal data [INSERT LINK].
-  * Request transfer of your personal data [INSERT LINK].
+  * **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
-  * Right to withdraw consent [INSERT LINK].
+  * **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
+  * **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
+  * **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
+  * **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.
 ===No fee usually required===
@@ Line 153: / Line 164: @@
 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===
-  * Service providers acting as processors, such as [INSERT NAME] based in [INSERT COUNTRY] who provide [INSERT SERVICES] if you register on our wiki.
+  * Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services
-  * Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.
+  * HM Revenue & Customs, the Information Commissioner’s Office, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances
-  * HM Revenue & Customs, the Information Commissioner’s Office, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
-  * [INSERT DETAILS OF ANY OTHER THIRD PARTIES, FOR EXAMPLE, MARKET RESEARCHERS ETC. IF RELEVANT.]
-===YOUR LEGAL RIGHTS===
-You have the right to:
-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.
-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.
-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.
-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.
-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.
-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.
-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.

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