Privacy policy
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Introduction
- We are committed to safeguarding the privacy of our customers.
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This policy applies where we are acting as a data controller with
respect to the personal data of our customers; in other words, where we determine the purposes
and means of the processing of that personal data.
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In this policy, "we", "us" and "our" refer to Tellma, Ltd. For more information about us, see Section 11.
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Credit
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This document was created using a template from Docular (https://docular.net).
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How we use your personal data
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In this Section 3 we have set out:
- the general categories of personal data that we may process;
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in the case of personal data that we did not obtain directly from you, the source and
specific categories of that data;
- the purposes for which we may process personal data; and
- the legal bases of the processing.
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We may process data about your use of our website and services
("usage data"). The usage data may include your IP address, geographical location,
browser type and version, operating system, referral source, length of visit, page views and
website navigation paths, as well as information about the timing, frequency and pattern of your
service use. The source of the usage data is our analytics tracking system. This usage data may
be processed for the purposes of analysing the use of the website and services. The legal basis
for this processing is our legitimate interests, namely monitoring and improving our website and
services.
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We may process your account data ("account data"). The
account data may include your name and email address. The source of the account data is you or
your employer. The account data may be processed for the purposes of operating our website,
providing our services, ensuring the security of our website and services, maintaining back-ups
of our databases and communicating with you. The legal basis for this processing is the
performance of a contract between you and us and/or taking steps, at your request, to enter into
such a contract.
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We may process your information included in your personal profile on
our website ("profile data"). The profile data may include your name, address,
telephone number, email address. The profile data may be processed for the purposes of enabling
and monitoring your use of our website and services. The legal basis for this processing is the
performance of a contract between you and us and/or taking steps, at you request, to enter into
such a contract.
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We may process your personal data that are provided in the course of
the use of our services ("service data"). The source of the service data is you or
your employer, supplier, or customer. The service data may be processed for the purposes of
operating our website, providing our services, ensuring the security of our website and
services, maintaining back-ups of our databases and communicating with you. The legal basis for
this processing is our legitimate interests, namely the proper administration of our website and
business.
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We may process information contained in any enquiry you submit to us
regarding goods and/or services ("enquiry data"). The enquiry data may be processed
for the purposes of offering, marketing and selling relevant goods and/or services to you. The
legal basis for this processing is consent.
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We may process information relating to our customer relationships,
including customer contact information ("customer relationship data"). The customer
relationship data may include your name, your employer, your job title or role, your contact
details, and information contained in communications between us and you or your employer. The
source of the customer relationship data is you or your employer. The customer relationship data
may be processed for the purposes of managing our relationships with customers, communicating
with customers, keeping records of those communications and promoting our products and services
to customers. The legal basis for this processing is consent.
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We may process information relating to transactions, including
purchases of goods and services, that you enter into with us and/or through our website
("transaction data"). The transaction data may include your contact details, your
card details and the transaction details. The transaction data may be processed for the purpose
of supplying the purchased goods and services and keeping proper records of those transactions.
The legal basis for this processing is the performance of a contract between you and us and/or
taking steps, at your request, to enter into such a contract and our legitimate interests,
namely the proper administration of our website and business.
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We may process information that you provide to us for the purpose of
subscribing to our email notifications and/or newsletters ("notification data"). The
notification data may be processed for the purposes of sending you the relevant notifications
and/or newsletters. The legal basis for this processing is consent.
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We may process information contained in or relating to any
communication that you send to us ("correspondence data"). The correspondence data
may include the communication content and metadata associated with the communication. The
correspondence data may be processed for the purposes of communicating with you and
record-keeping. The legal basis for this processing is our legitimate interests, namely the
proper administration of our website and business and communications with users.
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We may process any of your personal data identified in this policy
where necessary for the establishment, exercise or defence of legal claims, whether in court
proceedings or in an administrative or out-of-court procedure. The legal basis for this
processing is our legitimate interests, namely the protection and assertion of our legal rights,
your legal rights and the legal rights of others.
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We may process any of your personal data identified in this policy
where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks,
or obtaining professional advice. The legal basis for this processing is our legitimate
interests, namely the proper protection of our business against risks.
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In addition to the specific purposes for which we may process your
personal data set out in this Section 3, we may also process any of your personal data where
such processing is necessary for compliance with a legal obligation to which we are subject, or
in order to protect your vital interests or the vital interests of another natural person.
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Providing your personal data to others
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We may disclose your personal data to any member of our group of
companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries)
insofar as reasonably necessary for the purposes, and on the legal bases, set out in this
policy.
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We may disclose your personal data to our insurers and/or professional
advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance
coverage, managing risks, obtaining professional advice, or the establishment, exercise or
defence of legal claims, whether in court proceedings or in an administrative or out-of-court
procedure.
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We may disclose your enquiry data to one or more of those selected
third party suppliers of goods and services identified on our website for the purpose of
enabling them to contact you so that they can offer, market and sell to you relevant goods
and/or services. Each such third party will act as a data controller in relation to the enquiry
data that we supply to it; and upon contacting you, each such third party will supply to you a
copy of its own privacy policy, which will govern that third party's use of your personal data.
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In addition to the specific disclosures of personal data set out in
this Section 4, we may disclose your personal data where such disclosure is necessary for
compliance with a legal obligation to which we are subject, or in order to protect your vital
interests or the vital interests of another natural person. We may also disclose your personal
data where such disclosure is necessary for the establishment, exercise or defence of legal
claims, whether in court proceedings or in an administrative or out-of-court procedure.
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Retaining and deleting personal data
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This Section 5 sets out our data retention policies and procedure,
which are designed to help ensure that we comply with our legal obligations in relation to the
retention and deletion of personal data.
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Personal data that we process for any purpose or purposes shall not be
kept for longer than is necessary for that purpose or those purposes.
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We will retain your personal data as follows:
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profile data will be retained for a minimum period of 1 month following registration,
and for a maximum period of 1 week following deleting your account; and
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business data will be retained for a minimum period of 3 months following entry, and for
a maximum period of 1 week following deleting your company.
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In some cases it is not possible for us to specify in advance the
periods for which your personal data will be retained. In such cases, we will determine the
period of retention based on the following criteria:
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the period of retention of personal data will be determined based on technical, legal
and scheduling considerations.
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Notwithstanding the other provisions of this Section 5, we may retain
your personal data where such retention is necessary for compliance with a legal obligation to
which we are subject, or in order to protect your vital interests or the vital interests of
another natural person.
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Amendments
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We may update this policy from time to time by publishing a new
version on our website.
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You should check this page occasionally to ensure you are happy with
any changes to this policy.
- We may notify you of significant changes to this policy by email.
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Your rights
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In this Section 7, we have summarised the rights that you have under
data protection law. Some of the rights are complex, and not all of the details have been
included in our summaries. Accordingly, you should read the relevant laws and guidance from the
regulatory authorities for a full explanation of these rights.
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Your principal rights under data protection law are:
- the right to access;
- the right to rectification;
- the right to erasure;
- the right to restrict processing;
- the right to object to processing;
- the right to data portability;
- the right to complain to a supervisory authority; and
- the right to withdraw consent.
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You have the right to confirmation as to whether or not we process
your personal data and, where we do, access to the personal data, together with certain
additional information. That additional information includes details of the purposes of the
processing, the categories of personal data concerned and the recipients of the personal data.
Providing the rights and freedoms of others are not affected, we will supply to you a copy of
your personal data. The first copy will be provided free of charge, but additional copies may be
subject to a reasonable fee.
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You have the right to have any inaccurate personal data about you
rectified and, taking into account the purposes of the processing, to have any incomplete
personal data about you completed.
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In some circumstances you have the right to the erasure of your
personal data without undue delay. Those circumstances include: the personal data are no longer
necessary in relation to the purposes for which they were collected or otherwise processed; you
withdraw consent to consent-based processing; you object to the processing under certain rules
of applicable data protection law; the processing is for direct marketing purposes; and the
personal data have been unlawfully processed. However, there are exclusions of the right to
erasure. The general exclusions include where processing is necessary: for exercising the right
of freedom of expression and information; for compliance with a legal obligation; or for the
establishment, exercise or defence of legal claims.
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In some circumstances you have the right to restrict the processing of
your personal data. Those circumstances are: you contest the accuracy of the personal data;
processing is unlawful but you oppose erasure; we no longer need the personal data for the
purposes of our processing, but you require personal data for the establishment, exercise or
defence of legal claims; and you have objected to processing, pending the verification of that
objection. Where processing has been restricted on this basis, we may continue to store your
personal data. However, we will only otherwise process it: with your consent; for the
establishment, exercise or defence of legal claims; for the protection of the rights of another
natural or legal person; or for reasons of important public interest.
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You have the right to object to our processing of your personal data
on grounds relating to your particular situation, but only to the extent that the legal basis
for the processing is that the processing is necessary for: the performance of a task carried
out in the public interest or in the exercise of any official authority vested in us; or the
purposes of the legitimate interests pursued by us or by a third party. If you make such an
objection, we will cease to process the personal information unless we can demonstrate
compelling legitimate grounds for the processing which override your interests, rights and
freedoms, or the processing is for the establishment, exercise or defence of legal claims.
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You have the right to object to our processing of your personal data
for direct marketing purposes (including profiling for direct marketing purposes). If you make
such an objection, we will cease to process your personal data for this purpose.
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You have the right to object to our processing of your personal data
for scientific or historical research purposes or statistical purposes on grounds relating to
your particular situation, unless the processing is necessary for the performance of a task
carried out for reasons of public interest.
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To the extent that the legal basis for our processing of your personal
data is:
- consent; or
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that the processing is necessary for the performance of a contract to which you are
party or in order to take steps at your request prior to entering into a contract,
and such processing is carried out by automated means, you have the right to receive your
personal data from us in a structured, commonly used and machine-readable format. However, this
right does not apply where it would adversely affect the rights and freedoms of others.
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If you consider that our processing of your personal information
infringes data protection laws, you have a legal right to lodge a complaint with a supervisory
authority responsible for data protection. You may do so in the EU member state of your habitual
residence, your place of work or the place of the alleged infringement.
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To the extent that the legal basis for our processing of your personal
information is consent, you have the right to withdraw that consent at any time. Withdrawal will
not affect the lawfulness of processing before the withdrawal.
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You may exercise any of your rights in relation to your personal data
by written notice to us, in addition to the other methods specified in this Section 7.
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About cookies
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A cookie is a file containing an identifier (a string of letters and
numbers) that is sent by a web server to a web browser and is stored by the browser. The
identifier is then sent back to the server each time the browser requests a page from the
server.
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Cookies may be either "persistent" cookies or "session" cookies: a
persistent cookie will be stored by a web browser and will remain valid until its set expiry
date, unless deleted by the user before the expiry date; a session cookie, on the other hand,
will expire at the end of the user session, when the web browser is closed.
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Cookies do not typically contain any information that personally
identifies a user, but personal information that we store about you may be linked to the
information stored in and obtained from cookies.
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Cookies that we use
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We use cookies for the following purposes:
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authentication - we use cookies to identify you when you visit our website and as you
navigate our website;
- status - we use cookies to help us to determine if you are logged into our website;
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personalisation - we use cookies to store information about your preferences and to
personalise the website for you;
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security - we use cookies as an element of the security measures used to protect user
accounts, including preventing fraudulent use of login credentials, and to protect our
website and services generally; and
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cookie consent - we use cookies to store your preferences in relation to the use of
cookies more generally.
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Managing cookies
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Most browsers allow you to refuse to accept cookies and to delete
cookies. The methods for doing so vary from browser to browser, and from version to version. You
can however obtain up-to-date information about blocking and deleting cookies via these links:
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https://support.google.com/chrome/answer/95647?hl=en
(Chrome);
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https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
(Firefox);
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http://www.opera.com/help/tutorials/security/cookies/
(Opera);
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https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies
(Internet Explorer);
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https://support.apple.com/kb/PH21411
(Safari); and
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https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy
(Edge).
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Blocking all cookies will have a negative impact upon the usability of
many websites.
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If you block cookies, you will not be able to use all the features on
our website.
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Our details
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This website is owned and operated by Tellma, Ltd.,
Ltd.
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We are registered in England and Wales under registration number
11552287, and our registered office is at 71-75 Shelton Street, London, Greater London, WC2H
9JQ, UNITED KINGDOM
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You can contact us:
- by post, to the postal address given above;
- using our website contact form;
- by telephone, on the contact number published on our website from time to time; or
- by email, using the email address published on our website from time to time.