Last update: 14th December 2018
By creating a business user account on petinsurancereview.co.uk (the "Website") owned and operated by Symphony Digital Ltd you accept these guidelines for processing personal data on the Website. (Date: 14th December 2018)
1. COLLECTING INFORMATION ON THE WEBSITE
We will always comply (and be able to demonstrate our compliance) with relevant data protection legislation, including the Data Protection Act 2018 (“DPA”) and General Data Protection Regulation (“GDPR”) as applicable, when processing personal data. Further details on the DPA and GDPR can be found at the Information Commissioner’s Office website (www.ico.gov.uk).
1.1. COMPANY DATA
When you create a business user profile on the Website, we collect the following master data: Your name, company name, password and your email address. The purpose of the collection of this information is to identify you as a customer when you log on to the Website and to facilitate your operation of your user profile. If you are a customer of petInsurancereviews.co.uk we also collect information relevant to the fulfilment of the agreement between you and us.
When you write a reply to a review made by a user about your company, we collect the information you state in the reply, including company details and your name.
1.4 IP ADDRESSES
When visiting the Website, the IP address of your computer is registered as set out below.
2. PROCESSING OF DATA
Whenever we process personal data, the relevant basis for processing (selected from the following list) will be identified and recorded alongside the data:
(a) the data subject has given consent
(b) processing is necessary for the performance of a contract made with the data subject
(c) processing is necessary for compliance with a legal obligation to which we are subject
(d) processing is necessary in order to protect the data subject’s vital interests (or those of another individual)
(e) processing is necessary in the public interest or under official authority
(f) processing is necessary in our legitimate interests (or those of a third party), subject to the data subject’s interests or fundamental rights and freedoms.
2.1. DISCLOSURE OF DATA ON THE WEBSITE
Your email address and password provided by you on the Website are not disclosed to others. Your user id and any replies to users' reviews are automatically made available for other users of the Website to view.
2.2. DISCLOSURE TO OTHER SERVICES
A main purpose of the Website is to increase the exposure and the availability of the reviews made on the Website. Hence, we permit you as a customer of petinsurancereview.co.uk to show the reviews created on the Website and your replies thus increasing other consumers' knowledge of petinsurancereview.co.uk and the reviews.
2.3. OTHER DISCLOSURE
Symphony Digital Ltd may be required to disclose information given to PetInsuranceReview.co.uk by a court order from a competent court of law or public authority in accordance with the existing legislation.
3. DATA CONTROLLER VS. DATA PROCESSOR
3.1. DATA CONTROLLER
Symphony Digital Ltd will act as controller of personal data processed by use or on our behalf in connection with the Website.
We will collect and process personal data only to the extent that it is required for the specific purpose notified to the data subject, unless we are authorised by law to use the data for limited other purposes. We will not keep more personal data than necessary or for longer than necessary to achieve the purpose or purposes for which it was obtained. We will take all reasonable steps to erase from our systems all data which is no longer required.
We will take all reasonable steps to ensure that personal data we hold is accurate and up to date and to amend inaccurate or out-of-date data.
All data passed to petinsurancereview.co.uk will be deleted after 60 days except for reviews which are retained.
4. SECURITY MEASURES
Symphony Digital Ltd will put in place appropriate procedures and technologies to maintain the security of all personal data from the point of collection to the point of destruction. Personal data will only be transferred to a data processor in accordance with equivalent procedures and policies. Symphony Digital Ltd regularly audits its system for possible vulnerabilities and attacks. However, since the internet is not a 100% secure environment, Symphony Digital Ltd cannot ensure or warrant the security of information you transmit to petinsurancereview.co.uk.
We may transfer personal data we hold to a country outside the UK or EEA (e.g. for storage in a secure cloud storage centre) where one of the following conditions applies:
(a) specific contractual clauses or binding rules are in place
(b) the data subject has given explicit consent
(c) the transfer is necessary for certain specified reasons such as: the performance of a contract, for reasons of public interest, for the purpose of a legal claim, to protect the data subject’s vital interests or for our legitimate interests.
Cookies are digital information which is stored on your computer. The cookie does not identify the individual user but the user's computer, and it is for example used for measuring Website traffic for the purpose of producing anonymous statistics in order to improve the functionality of the Website and to get the Website to work. You can read more about what cookies we use on the Website and for what purposes below.
6.1. THIRD PARTY COOKIES
We may provide cookie and anonymised data to trusted 3rd parties to improve the relevance of online advertising and personalisation.
Your email address is only shared with our 3rd party insurance partners if you request a quotation by completing our quotation request form. They will then email a quotation to you directly. Symphony Digital Ltd cannot be held responsible for how such third parties process your personal data – please refer to their own privacy policies for further details. Personal data is not otherwise shared with any other third parties at any time.
Third party Cookies are set by third party websites – not our Website.
When you visit our Website, the following third party Cookies may be set:
- Google Analytics Cookies set when you log in to our Website with Google
- Google AdSense cookies set when displaying relevant targeted advertisements on our Website. Some cookies may be set as DoubleClick, which is part of Google
6.2. DELETION OF COOKIES
You can delete the cookies already on your device. However, refusing to accept some or all of our cookies may affect your ability to access or use certain parts of the Website.
You can typically delete cookies from the Privacy or History area, available from the Settings or Options menu in most browsers.
To opt-out of third party cookies, please go to http://www.aboutads.info choices or Your Online Choices at http://www.youronlinechoices.com/uk/.
7. IP ADDRESSES AND BROWSER SETTINGS
When visiting the Website, the IP address of your computer or device is logged. The IP address is the numerical address of the computer or device used when visiting the Website and does not directly identify the user of that computer or device. The IP address is registered to analyse how visitors use the Website, to monitor users’ preferences whilst visiting the Website and to enable petinsurancereview.co.uk to trace the computer or device in case of misuse or unlawful actions in connection with the visit on or use of the Website. Further, the IP address is used to derive your approximate location (city level) and verify your review as genuine. IP data is removed after 30 days unless a review is written in which case the IP data is retained until the review is deleted or a removal request has been actioned.
If you have any questions or comments, or if you want to update, delete, or change any Personal Information you've submitted on the Website, please use our contact form to get in touch.
In addition, you are welcome to contact our Data Protection Administrator if you have any questions about the data processing activities performed by us: firstname.lastname@example.org
11. YOUR RIGHTS
We will process all personal data in line with data subjects’ rights, in particular their right to:
(a) access any personal data held about them
(b) be given certain information concerning how their personal data is obtained and processed (this information is as set out in this Policy)
(c) have their personal data rectified where necessary
(d) have their personal data erased in certain circumstances (the “right to be forgotten”)
(e) restrict processing of their personal data in certain circumstances
(f) have their personal data transferred to themselves or another data controller (“data portability”)
(g) object to automated processing
You may make formal requests for access to information we hold about you. All such requests will be forwarded to the Data Protection Administrator for a response within the applicable time period. We will only disclose personal data we hold once we have verified the enquirer’s identity to ensure personal data is only given to a person who is entitled to it.