1.1 We are committed to safeguarding the privacy of our website visitors, and service users. This document was created using a template from SEQ Legal (http://www.seqlegal.com).
1.2 This policy applies where we are acting as a data controller with respect to the personal data of such persons; in other words, where we determine the purposes and means of the processing of that personal data.
1.5 In this policy, “we”, “us” and “our” refers to ACM Consultancy Services Ltd.
2. The personal data that we collect
2.1 In this Section 2 we have set out the general categories of personal data that we process.
2.2 We may process data enabling us to get in touch with you (“contact data”). The contact data may include your name, email address, telephone number, postal address and social media account identifiers. The source of the contact data is you and your employer.
2.3 We may process your website user account data (“account data”). The account data may include your account identifier, name, email address, business name, account creation and modification dates, website settings and marketing preferences. The primary source of the account data is you and your employer, although some elements of the account data may be generated by our website.
2.4 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, profile pictures, gender, date of birth, relationship status, interests and hobbies, educational details and employment details. The source of the profile data is you.
2.5 We may process information relating to our customer relationships (“customer relationship data”). The customer relationship data may include your name, the name of your business or employer, your job title or role, your services, your contact details and information contained in or relating to communications between us and you, or between us and your employer. The source of the customer relationship data is you and your employer.
2.6 We may process your personal data that are provided in the course of the use of our services and generated by our services in the course of such use (“service data”). The service data may include client contact details, client case studies and an account of our services performed (I.e., what, when and where), relevant points of contact, any recommendations you have provided as to the outcomes of that service, any non-classified activities that were undertaken on your behalf, such as to show case our services. We will of course also store the standard, relevant accounting, contracts, invoices, tax information, insurance and commercial information pertaining to the necessity of providing services. The source of the service data is you and your employer and any business information related to the services performed in the course of those services that we may store that allow us to operate.
2.7 We may process information relating to transactions, including purchases of goods and services, that you enter into with us through our website (“transaction data”). The transaction data may include your name, your contact details, your payment card details (or other payment details) and the transaction details. The source of the transaction data is you and our payment services provider.
2.8 We may process information contained in or relating to any communication that you send to us or that we send to you (“communication data”). The communication data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms.
2.9 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 Google Analytics tracking system, which is available from Google here: http://www.google.com/policies/privacy/. Our analytics service provider generates statistical and other information about website use by means of cookies. The information generated relating to our website is used to create reports about the use of our website.
2.10 Please do not supply any other person’s personal data to us, unless we prompt you to do so or you have that person’s consent to both the disclosure and the processing of that personal information.
3. Purposes of processing and legal bases
3.1 In this Section 3, we have set out the purposes for which we may process personal data and the legal bases of the processing.
3.2 Operations – We may process your personal data for the purposes of operating our website, the processing and fulfilment of orders, providing our services, supplying our goods, generating invoices, bills and other payment-related documentation, and credit control. The legal basis for this processing is our legitimate interests in running our company.
3.3 Publications – We may process account data, profile data and service data for the purposes of publishing such data on our website and elsewhere through our services in accordance with your express instructions. The legal basis for this processing is our legitimate interests, namely the publication of content in the ordinary course of our operations.
3.4 Relationships and communications – We may process contact data, account data, customer relationship data, transaction data and communication data for the purposes of managing our relationships, communicating with you (excluding communicating for the purposes of direct marketing) by email, SMS, post, fax and/or telephone, providing support services and complaint handling. The legal basis for this processing is our legitimate interests, namely communications with our website visitors, service users, individual customers and customer personnel, the maintenance of our relationships, enabling the use of our services, and the proper administration of our website, services and business.
3.5 Personalisation – We may process account data, service data and usage data for the purposes of personalising the content and advertisements that you see on our website and through our services to ensure that you only see material that is relevant to you. The legal basis for this processing is our legitimate interests, namely offering the best possible experience for our website visitors and service users.
3.6 Direct marketing – We may process contact data, account data, profile data, customer relationship data and transaction data for the purposes of creating, targeting and sending direct marketing communications by email (such as newsletters etc.), SMS, post and making contact by telephone for marketing-related purposes. The legal basis for this processing is our legitimate interests, namely promoting our business and communicating marketing messages and offers to our website visitors and service users. However, we will only undertake these services at our discretion on whether we think you will want to receive such communications.
3.7 Research and analysis – We may process usage data, service data and transaction data for the purposes of researching and analysing the use of our website and services, as well as researching and analysing other interactions with our business. The legal basis for this processing is our legitimate interests, namely monitoring, supporting, improving and securing our website, services and business generally.
3.8 Record keeping – We may process your personal data for the purposes of creating and maintaining our databases, back-up copies of our databases and our business records generally. The legal basis for this processing is our legitimate interests, namely ensuring that we have access to all the information we need to properly and efficiently run our business in accordance with this policy.
3.9 Security – We may process your personal data for the purposes of security and the prevention of fraud and other criminal activity. The legal basis of this processing is our legitimate interests, namely the protection of our website, services and business, and the protection of others.
3.10 Insurance and risk management – We may process your personal data where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks and obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
3.11 Legal claims – We may process your personal data 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.
3.12 Legal compliance and vital interests – We may also process 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.
3.13 Any exception to the purposes of processing for the purposes of the legitimate interests pursued by us, as the controller or by a third party, will be where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.
4. Automated decision-making
4.1 We will use your personal data for the purposes of automated decision-making in relation to our website.
4.3 The significance and possible consequences of this automated decision-making are simply to enable data analytics like Google and those of our Wix website host to carry out analysis and research on demographics, interests and behaviour of our users and supporters to help us gain a better understanding of them to enable us to improve our services. This may include connecting data we receive from you on the website to data available from other sources. Your personally identifiable data will only be used where it is necessary for the analysis required, and where your interests for privacy are not deemed to outweigh Google Analytic’s or Wix’s legitimate interests in developing new services for us.
5. Providing your personal data to others
5.1 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 and any sub-contractors, suppliers, accountants, agents, professional advisors, clients, the provider and host of our website) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.
5.2 We may disclose your personal data to our insurers and professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice.
5.3 Your personal data held in our website database will be stored on the servers of our hosting services providers.
5.6 In addition to the specific disclosures of personal data set out in this Section 5, 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.
5.7 We may disclose your data to the purchaser (or prospective purchaser) of any business or asset that we are (or are contemplating) selling.
6. International transfers of your personal data
6.1 In this Section 6, we provide information about the circumstances in which your personal data may be transferred to a third country under UK and/or EU data protection law. You expressly agree to the transfers of personal information described in this Section 6.
6.2 Information that we collect may be stored and processed in and transferred between any of the countries in which we operate in order to enable us to use the information in accordance with this policy.
6.3 We may transfer your personal data from the European Economic Area (EEA) to the UK and process that personal data in the UK for the purposes set out in this policy, and may permit our suppliers and subcontractors to do so, during any period with respect to which the UK is not treated as a third country under EU data protection law or benefits from an adequacy decision under EU data protection law; and we may transfer your personal data from the UK to the EEA and process that personal data in the EEA for the purposes set out in this policy, and may permit our suppliers and subcontractors to do so, during any period with respect to which EEA states are not treated as third countries under UK data protection law or benefit from adequacy regulations under UK data protection law.
6.4 We have offices or facilities in the UK, but our sub-contractor platform of resource that either already do, or will, undertake remote work with us, may live in other countries, such as those currently working with us in Canada and Norway. Our clients can also be nationally or internationally based, so some exchange of personal information may be required internationally. The competent data protection authorities have made an adequacy determination with respect to the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the competent data protection authorities, which would include, in Canada for example, the Canadian Federal Law Personal Information Protection and Electronic Documents Act (S.C. 2000, c. 5) (the “PIPEDA”) which contains similar provisions to those in the GDPR and the Data Protection Directive, from which a copy could be obtained.
6.5 In addition, several Canadian provinces (British Columbia, Alberta and Quebec) have adopted substantially similar data protection laws applicable in the private sector which partly displace PIPEDA in relation to personal information collected within each of these provinces, from which a copy could be obtained from contacting these provinces: https://www.priv.gc.ca/en/privacy-topics/privacy-laws-in-canada/the-personal-information-protection-and-electronic-documents-act-pipeda/r_o_p/prov-pipeda/ for these provinces (or equivalent sites).
6.6 The hosting facilities for our website are international as the host is Wix, which was founded in Israel, with offices in London and around the globe. The local branch is based in London.
6.7 The competent data protection authorities have made an adequacy determination with respect to the data protection laws of each of these countries. Transfers to each of these countries, and any others, will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the competent data protection authorities for each of those countries. The data protection laws for Wix can be found on their website with means to request these: https://www.wix.com/about/privacy
6.8 You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
7. Retaining and deleting personal data
7.1 This Section 7 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
7.2 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.
7.3 We will retain your personal data as follows:
(a) contact data, account data, profile data, customer relationship data, service data, transaction data, usage data, communication and all other personal data will be deleted after 10 years following the data of collection by us. Wix, Google, sub-contractors and clients will have their own timeframes identified for deleting personal data.
7.4 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 (including of electronic documents containing personal data) based on the following criteria:
(a) as long as required to the extent that we are required to do so by law;
(b) as long as we believe that the documents may be relevant to any ongoing or prospective legal proceedings; and
(c) as long as needed in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).
7.5 Notwithstanding the other provisions of this Section 7, 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.
7.6 If you grant to us a licence to publish any of your personal data, we may continue to retain and publish that personal data after the end of the relevant retention period specified in this Section 7 in accordance with the applicable licence terms, subject to your personal data rights. If we cease to publish such personal data after the end of the relevant retention period specified in this Section 7, that personal data will be retained for a maximum period of 10 Years following the date that publication ceases.
8. Security of personal data
8.1 We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.
8.2 We will store your personal data on secure servers (I.e., firewall and password protected) such as on personal computers or through the Cloud (icloud, Google Drive, OneDrive etc.).
8.3 The following personal data will be stored by us in encrypted form: any transactional data that would pass through our website. This is currently not applicable to our website however, because we do not process financial transaction data through our website. Any links to third party websites from our websites for the purchase of products or services, are not our responsibility and would be fairly covered by the encryption policy on that sales website for one of our services or products. Service agreements and contracts are managed through our google email provider in line with their privacy policies.
8.4 You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
8.5 You should ensure that your password is not susceptible to being guessed, whether by a person or a computer program. You are responsible for keeping the password you use for accessing our website confidential and we will not ask you for your password (except when you log in to our website).
9. Your rights
9.1 In this Section 9, we have listed 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.
9.2 Your principal rights under data protection law, once your identify has been verified by all means considered reasonable and appropriate by us (and the law) are:
(a) the right to access – you can ask for copies of your personal data;
(b) the right to rectification – you can ask us to rectify inaccurate personal data and to complete incomplete personal data;
(c) the right to erasure – you can ask us to erase your personal data;
(d) the right to restrict processing – you can ask us to restrict the processing of your personal data;
(e) the right to object to processing – you can object to the processing of your personal data;
(f) the right to data portability – you can ask that we transfer your personal data to another organisation or to you;
(g) the right to complain to a supervisory authority – you can complain about our processing of your personal data; and
(h) the right to withdraw consent – to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.
9.3 These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by visiting [https://edpb.europa.eu/our-work-tools/general-guidance/gdpr-guidelines-recommendations-best-practices_en and https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/].
10. Third party websites
10.1 Our website includes hyperlinks to, and details of, third party websites.
10.2 In general we have no control over, and are not responsible for, the privacy policies and practices of third parties. We recommend you read the privacy policies on those websites before submitting personal data to them.
11. Personal data of children
11.1 Our website and services are targeted at persons over the age of 18 Years.
11.2 If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.
12. Updating information
12.1 Please let us know if the personal information that we hold about you needs to be corrected or updated.
13. About cookies
13.1 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.
13.2 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.
13.3 Cookies may not contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.
14. Cookies that we use
14.1 We use persistent and session cookies for the following purposes (though you can select essential cookies only in our banner when selecting cookies from our settings option and then ‘advanced settings menu’, if preferred):
15. Cookies used by our service providers
16. Managing cookies
16.1 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:
(a) https://support.google.com/chrome/answer/95647 (Chrome);
(b) https://support.mozilla.org/en-US/kb/enhanced-tracking-protection-firefox-desktop (Firefox);
(c) https://help.opera.com/en/latest/security-and-privacy/ (Opera);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies(Internet Explorer);
(e) https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac (Safari); and
(f) https://support.microsoft.com/en-gb/help/4468242/microsoft-edge-browsing-data-and-privacy (Edge).
16.2 Blocking all cookies will have a negative impact upon the usability of many websites.
16.3 If you block cookies, you will not be able to use all the features on our website.
17. Cookie preferences
18.1 We may update this policy from time to time by publishing a new version on our website.
18.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
18.3 We may notify you of changes to this policy via email.
19. Our details
19.1 This website is owned and operated by ACM Consultancy Services Ltd.
19.2 We are registered in England and Wales under registration number: 10993022 and our registered office is at: Windsor House Troon Way Business Centre, Humberstone Lane, Thurmaston, Leicestershire, England, LE4 9HA.
19.3 You can contact us:
(a) using our website contact form;
(b) by telephone, on the contact number published on our website;
(c) by email, using the email address published on our website; or
(d) in writing at our registered office address, but the other routes will be quicker and more efficient.
END OF POLICY.