ControlPlane Website Privacy Notice

1. Purpose Of This Privacy Notice

2. This privacy notice (“Privacy Notice”) outlines how your Personal Data is collected and Processed on and through the website https://control-plane.io/ (together with its subdomains, features, and services available thereon (the “Site”)), including, but not limited to, any data you may provide through this website in visiting our Site (regardless of where you visit it from), contacting us, signing up to any of our email lists, taking part in our free training services or downloading any materials. It will also tell you about your rights of privacy and how the law protects you.

3. The Site is owned and administered by ControlPlane Group Limited, a limited company registered in England and Wales under company number 14149926 with its registered office at 49 Queens Road, Cheltenham, England, GL50 2LX (“ControlPlane”, “we”, “us” and “our”).

4. ControlPlane is the ultimate parent company of a group of legal entities with a corporate presence in the United Kingdom, the United States (through ControlPlane North America, LLC) and in New Zealand (through ControlPlane APAC Limited). This Privacy Notice is therefore issued on behalf of ControlPlane and all entities within its group (the “Group”), and any reference to “ControlPlane” includes its Group companies.

5. You have the right to make a complaint at any time to the ICO at 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.

6. If you have any questions about this Privacy Notice, including any requests to exercise your legal rights, please email [EMAIL ADDRESS].

7. We may update this Privacy Notice from time to time in response to changing legal, technical or business developments. We reserve the right, at our discretion, to change, modify, add, or remove portions from this Privacy Notice at any time, provided that any such modifications will only be applied prospectively. We encourage you to periodically review the Site for the latest information on our privacy practices. Your continued use of the Site following the posting of any changes to this Privacy Notice means you accept such changes.

8. The paragraph headings contained in this Privacy Notice, and their capitalisation, are included solely for convenience of reference and shall not in any way affect the meaning or interpretation of any of the provisions of this Privacy Notice.

9. Unless the context otherwise requires, words in the singular shall include the plural and in the plural shall include the singular.

10. Unless the context otherwise requires, a reference to one gender shall include a reference to the other genders.

11. A person includes a natural person, corporate or unincorporated body (whether or not having a separate legal personality).

12. Definitions

    1. The following definitions apply in this Privacy Notice:

“Aggregated Data” has the meaning provided in section 3.2 of this Privacy Notice;

“California Consumer(s)” has the meaning provided in section 14.1 of this Privacy Notice;

“CCPA” means California Consumer Protection Act;

“Comply with a legal obligation” means Processing your Personal Data where it is necessary for compliance with a legal obligation to which we are subject;

“Consent” means any freely given, specific, informed and unambiguous indication of the Data Subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the Processing of Personal Data relating to him or her;

“Contact Data” has the meaning provided in section 3 of this Privacy Notice;

“Controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the Processing of Personal Data; where the purposes and means of such Processing are determined by European Union or Member State law, the controller or the specific criteria for its nomination may be provided for by European Union or Member State law;

“CPRA” has the meaning provided in section 14.3 of this Privacy Notice;

“Data Subject” means a person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. It does not include data where the identity has been removed (anonymous data);

“EEA” means the European Economic Area;

“EEA Residents” has the meaning set out in section 13.6.1 of this Privacy Notice;

“External Third Parties” means designated service providers which are working with us and acting as Processors. Examples of External Third Parties include Third Parties providing IT and system administration services. It also includes professional advisers acting as Processors or joint Controllers including lawyers, bankers, auditors and insurance providers based in in the UK, the European Union, Australia, New Zealand and/or the United States who provide consultancy, banking, legal, insurance and accounting services, as well as HM Revenue & Customs, or its foreign equivalent, regulators and other authorities acting as Processors or joint Controllers who require reporting of Processing activities in certain circumstances;

“Group” has the meaning provided in section 1.3 of this Privacy Notice;

“ICO” means the office of the UK Information Commissioner, being the regulator appointed in the UK as the data protection supervisory authority;

“Identity Data” has the meaning provided in section 3 of this Privacy Notice;

“Internal Third Parties” means designated other companies in the Group acting as joint Controllers or Processors and who are based in the UK, United States of America and/or New Zealand;

“GDPR” means the General Data Protection Regulation 2016/679 of the European Parliament;

“Legitimate Interests” means the interests of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience;

“Marketing and Communications Data” has the meaning provided in section 3 of this Privacy Notice;

“Member State” means a member country or state of the European Union;

“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;

“Personal Data” means any information relating to a Data Subject. Personal Data includes but is not limited to a Data Subject’s Identity Data, Contact Data, Technical Data, Usage Data, Profile Data and Marketing and Communications Data, as defined in section 3.1. of this Privacy Notice;

“Processing” or “Process” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction**;**

“Processor” means a natural or legal person, public authority, agency or other body which Processes Personal Data on behalf of the Controller;

“Privacy Notice” has the meaning provided in section 1.1;

“Profile Data” has the meaning provided in section 3 of this Privacy Notice;

“Restriction of Processing” means the marking of stored Personal Data with the aim of limiting their Processing in the future;

“Site” has the meaning provided in section 1.1 of this Privacy Notice;

“Special Categories of Personal Data” has the meaning provided in section 3 of this Privacy Notice;

“Technical Data” has the meaning provided in section 3 of this Privacy Notice;

“Third Party” means a natural or legal person, public authority, agency or body other than the Data Subject, Controller, or Processor, who, under the direct authority of the Controller or Processor, is authorised to Process Personal Data. Third Parties can be categorised as Internal Third Parties or External Third Parties;

“UK GDPR” means Data Protection Act 2018;

“UK” means the United Kingdom; and

“Usage Data” has the meaning provided in section 3 of this Privacy Notice.

1. Third Party Links

   1. The Site may include links to Third-Party websites. Clicking on those links 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 accuracy, contents, or their privacy statements. Should you click on a link to leave the Site we would encourage you to read the privacy notice of the website you visit.

2. The Data We Collect About You

3. We may collect, use, store, and transfer different kinds of Personal Data about you which we have grouped together as follows (and referred to collectively as “Special Categories of Personal Data”):

   1. data collected on identity (“Identity Data”) includes first name, maiden name, last name, title, date of birth and gender;
   2. data collected about contact details (“Contact Data”) includes postal address, email address, and telephone numbers;
   3. data collected on your device’s technology (“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 the Site;
   4. data collected about your usage (“Usage Data”) includes information about how you use the Site and services;
   5. when applicable, data collected about your profile information on our Site (“Profile Data”) includes username, Contact Data, password and any submissions, downloads or other actions made on our Site; and
   6. any data collected regarding your marketing and communication preferences on our Site or in connection with any Third Parties (“Marketing and Communications Data”). Marketing and Communications Data includes your preferences in receiving marketing from us and our Third Parties, and your communication preferences.

4. We also collect, use, and share aggregated data such as statistical or demographic data for any purpose (“Aggregated Data”). 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 Notice.

5. We may collect any Special Categories of Personal Data about you.

6. Information Collected for Recruitment Purposes. ControlPlane may collect Personal Data about a Data Subject in connection with the recruitment process. When you apply for a job posted by us, the Personal Data you provide is used to determine whether or not you’re a good fit for current and future roles at our company.

7. We collect Personal Data directly from you, as a job applicant, or we may receive Personal Data from Third Parties, for example, in connection with a background, employment, or reference check, subject to your Consent where required by law. Please note that we use Breezy HR, a web-based hiring platform, to assist in our recruiting process. As part of that process, Breezy HR will be Processing the personal information you’ve shared in accordance with ControlPlane’s instructions. If you are applying to any of our job openings through Breezy HR, we encourage you to read their privacy notice available on their website.

8. We may collect, store, and process the following categories of Personal Data, which we require in connection with our recruitment activities:

   1. personal contact details such as name, title, addresses, telephone numbers, and personal email addresses;
   2. work history and other relevant experience including information contained in a resume, CV, cover letter, or job application;
   3. education information including degrees awarded, transcripts, and other information provided in support of the job application;
   4. information collected during phone screenings and interviews;
   5. details regarding the type of employment sought, desired salary, willingness to relocate, job preferences, and other information related to compensation and benefits; and/or
   6. reference information and information received from background checks, where applicable, including information provided by Third Parties.

9. If at any point you’d like us to remove the information we’ve collected or share it with you, contact us at: [INSERT EMAIL].

10. If You Fail To Provide Personal Data

    1. 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 services). In this case, we may have to cancel a service you have with us, but we will notify you if this is the case at the time.

11. How Is Your Personal Data Collected?

    1. We use different methods to collect data from and about you including through:
       1. Direct Interactions. You may give us your Identity Data and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes, but is not limited to, Personal Data you provide when you:
          • apply for our services;
          • subscribe to our service or publications;
          • request marketing to be sent to you;
          • request a free download of any books or materials, participate in any promotion or survey; and/or
          • give us feedback or contact us.
       2. Automated Technologies or Interactions. As you interact with our Site, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this 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 Cookies and Tracking Technologies Notice for further details.
       3. 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:
            • analytics providers such as Google based outside the UK;
            • advertising networks; and/or
            • search information providers.

12. How We Use Your Personal Data

    1. 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:
       1. where we need to perform the contract we are about to enter into or have entered into with you;
       2. 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; and/or
       3. where we need to comply with a legal obligation.
    2. Please refer to the Lawful Basis section of the Glossary to find out more about the types of Lawful Basis that we will rely on to Process your Personal Data.
    3. Generally, we do not rely on Consent as a Lawful 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 adjusting your marketing preferences or by unsubscribing from our mailing list.
    4. 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.

13. Purposes for Which We Will Use Your Personal Data

    1. 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.
    2. Please 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 Lawful Basis we are relying on to Process your Personal Data where more than one ground has been set out in the table below.

1. Marketing

   1. We strive to provide you with choices regarding certain Personal Data uses, particularly around marketing and advertising. For more information about our marketing practices or to learn more on how to unsubscribe from any ControlPlane communication, please contact us.
   2. Promotional Offers From Us. We may use your Identity Data, Contact Data, Technical Data, Usage Data, and Marketing and Communications 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).
   3. Marketing Communications. You will receive marketing communications from us if you have requested information or purchased services from us and you have not opted out of receiving that marketing.
   4. Third Party Marketing. We will get your express opt-in Consent before we share your Personal Data with any Third Party for marketing purposes.
   5. Opting Out. You can ask us or Third Parties to stop sending you marketing messages at any time by [SPECIFY OPTION], 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 service purchase, service experience or other transactions.

2. Cookies

   1. 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 our Site may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookies and Tracking Technologies Notice.

3. Change Of Purpose

   1. 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.
   2. 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.
   3. 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.

4. Disclosures Of Your Personal Data

   1. We may share your Personal Data with the parties set out below for the purposes set out in the table Purposes for Which We Will Use Your Personal Data above:
      1. Internal Third Parties as set out in section 2. Definitions;
      2. External Third Parties as set out in section 2. Definitions;
      3. Third Parties also include any entity or person 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 Notice.
   2. 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.

5. International Transfers

   1. ControlPlane will store all your Personal Data on servers within the United Kingdom. However, we may share your Personal Data within the Group, which will involve transferring your data outside the UK. Internal and External Third Parties, and their employees, board directors, agents and consultants based in the United States, the European Union, Australia or in New Zealand will have access to your information but when accessing your data they will do so in accordance with our policies and procedures. We ensure your Personal Data is protected by requiring all our Group companies to follow the same rules when Processing your Personal Data.
   2. Under the GDPR and the UK GDPR, we are considered a Controller or joint Controller of the information of EEA and UK residents and provide Processing of data at the request of our clients, who may be Controllers or Processors of such data. By providing information to us for the purpose of obtaining information about us and our services, clients, job applicants and other visitors Consent to the Processing of such Personal Data in the United Kingdom, New Zealand, Australia, the European Union and the United States.
   3. The transfer of information and of Personal Data to and from New Zealand is necessary for the performance of our services and obligations and will be Processed in accordance with applicable data privacy laws and regulation. Please note that, in a 2012 ruling, the European Commission has established that New Zealand’s privacy laws provided an “adequate level” of privacy protection to meet European standards.
   4. We may also transfer Personal Data to and from Australia for the performance of our services and obligations and it will be Processed subject to applicable data privacy laws and regulation, including the Australia Privacy Act. Please note that the European Commission has not yet established that Australia’s privacy laws provided an “adequate level” of privacy protection to meet European standards.
   5. We may also transfer Personal Data to and from the United States for the performance of our services and obligations and will be Processed with applicable data privacy laws and regulation. Please note that the United States does not have federal data protection laws equivalent to those in the EEA, United Kingdom, and other jurisdictions.
   6. Please contact us if you want further information on the specific mechanism used by us when transferring your Personal Data out of the UK.
   7. Rights of EEA and United Kingdom Residents.
      1. This section of the Privacy Notice is applicable to residents of the EEA and the UK. The EEA consists of the Member States of the European Union, i.e., Austria, Belgium, Bulgaria, Croatia, Republic of Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden, and Iceland, Liechtenstein, and Norway. Residents of the EEA, including Switzerland, are referred to within this Privacy Notice as “EEA Residents”.
      2. Since 25th May 2018, all Processing of information of EEA Residents is performed in accordance with the GDPR. Since 1st January 2021, all Processing of information of UK residents is performed in accordance with the UK GDPR.
      3. Although we are based in the UK and operate also in the United States, Australia and New Zealand, we may obtain the information of EEA Residents.
      4. Under the GDPR and UK GDPR, EEA Residents and UK residents may have the right to:
         • obtain confirmation that we hold information about them;
         • receive details and/or copies of the information we maintain about them;
         • request access to the information we maintain about them;
         • update and correct inaccuracies in the information we hold about them;
         • object to the continued Processing of information about them; and
         • have the information we hold about them blocked, anonymised, or deleted, as appropriate.
      5. You have the right to obtain confirmation from us as to whether we are Processing your Personal Data and, if we are, to request a copy of the Personal Data we hold about you. This is known as a ‘data subject request’, which can be made by contacting us at [INSERT EMAIL]. You also have the right to ask that we update any information we hold about you that may be incorrect. It is important that the information we hold about you is accurate and up to date. If any of your information changes, please let us know.
      6. In certain circumstances you have the right to request that we restrict the way in which we Process your data, or that we erase all information that we hold about you.
      7. You have the right to object to certain types of Processing.
      8. The right to access information may be limited in some circumstances by local law and by our ethical and legal obligations. We are also limited by the terms of our agreements with our clients in responding to such requests and may refer any requests received from EEA Residents and/or UK residents to our clients.
      9. We will try our best to comply with any request to restrict, object, or erase your Personal Data, however the Processing of some data may still be required for legitimate business purposes or to comply with legal obligations. Please also note that if you want us to restrict or stop Processing your data this may prevent us from ever delivering services to you.
      10. You have the right to request that we send a copy of your Personal Data, that you have provided to us, to another organisation for your own purposes (e.g., if you wish to change service provider). This data must be provided in a structured and usable format. This right only applies to Personal Data Processed by way of Consent or in pursuit of a contract we have with you. If you wish us to transfer your Personal Data, please let us know.
      11. You will not have to pay a fee to access your Personal Data or to exercise any of your other rights. However, we may charge a reasonable fee should your request be clearly unfounded, repetitive, or excessive. To prevent unauthorised access to information we may ask for proof of identity.
      12. When we receive such a request, we will aim to provide a response to your request within one (1) 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 keep you updated.
      13. If you wish to contact us in relation to any of your rights stated within this Privacy Notice, please contact us at: [INSERT EMAIL ADDRESS].
      14. We may ask individuals making any request under this section, or under the California Privacy Rights section below, to provide additional information for identity verification purposes.

6. California Privacy Rights

   1. The following section pertains to the rights of individuals or households in California (“California Consumer(s)”) as defined by California Civil Code, Section 1798.83.
   2. Under certain circumstances, California Civil Code, Section 1798.83 states that, upon receipt of a request by a California Consumer, a business may be required to provide detailed information regarding how that business has shared the California Consumer’s information with Third Parties for direct marking purposes. However, we reserve the right to state that this section does not apply to businesses like ours that do not disclose information to Third Parties for direct marketing purposes without prior approval and/or give clients a free mechanism to opt-out of having their information disclosed to Third Parties for their direct marketing purposes. Moreover, we reserve our right to put forward other reasons why this section does not apply to ControlPlane.
   3. Rights Under the CCPA.
      1. As of January 1, 2020, the CCPA, as amended by the California Privacy Rights Act (“CPRA”) on January 1, 2023, provides California Consumers with additional rights regarding information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly with a particular consumer or household. The categories of information are generally described above but differ for individual consumers depending on the services used by such consumers. Under the CCPA and CPRA, qualifying California Consumers may have the following rights:
      2. Right to Know and Right to Delete.
         • A California Consumer has the right to request that we disclose what information we collect, use, disclose and sell. A California Consumer also has the right to submit requests to delete information.
         • When we receive a request to know or delete information from a California Consumer, we will aim to provide a response to your request within one (1) 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 keep you updated.
         • Our obligation to delete Personal Information is not required when the information is necessary, among other things:
           • to provide services to our clients;
           • to detect and resolve issues related to security or functionality;
           • to comply with legal obligations;
           • to exercise free speech or to ensure another’s exercise of free speech; and/or
           • for internal purposes that a consumer may expect.
      3. Right for Disclosure of Information.
         • A California Consumer may also submit requests that we disclose specific types or categories of information that we collect.
         • Under certain circumstances, we will not provide such information, including where the disclosure creates a substantial, articulable, and unreasonable risk to the security of that information, or the security of our systems or networks. We will not disclose California Consumers’ social security numbers, driver’s license numbers, or other government issued identification numbers, financial account numbers, any health insurance or medical identification numbers, or account passwords and security questions and answers. Our obligations to disclose information are subject to legal and ethical restrictions placed on us, including our duty to protect client information from disclosure or restrictions placed by legal or court authority.
         • In the event we receive requests from a California Consumer who has a relationship with a client (for example, from an employee or customer of a client), we will inform that client.
      4. Submitting Requests. If you are a California Consumer and would like to make any requests under the CCPA and CPRA, please contact us at: [INSERT EMAIL ADDRESS].
      5. Verifying Requests.
         • If we receive any request, we will use a two-step process for requests where the California Consumer must first, clearly submit the request and then second, separately confirm the request.
         • In submitting a request, a California Consumer must provide sufficient information to identify the consumer, such as name, email address, home or work address, or other such information that is on record with us so that we can match such information to the information that we maintain. Do not provide social security numbers, driver’s license numbers, account numbers, credit or debit card numbers, medical information, or health information with requests. If requests are unclear, we will provide the California Consumer with specific directions on how to submit the request and/or remedy any deficiencies. If we cannot verify the identity of the requestor, we may deny the request.
      6. California Do Not Track Disclosures. Although some browsers currently offer a “do not track (“DNT”) option”, no common industry standard for DNT exists. We therefore do not currently commit to responding to browsers’ DNT signals.
      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, board directors and 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.
      8. Data Retention.
         • 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.
         • In some circumstances you can ask us to delete your data: see 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. 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. This is 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; or
           • where 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; and
         • 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 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.
      10. 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.
      11. 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.