PRIVACY POLICY
BACKGROUND:
Pisces Accounts understands that your privacy is important to you and that you care about how your personal data is used. [We] OR [I] respect and value the privacy of everyone who visits this website, <<insert website address>> (“[Our] OR [My] Site”) and only collect and use your personal data as described in this Privacy Policy. Any personal data [we] OR [I] collect will only be used as permitted by law.
Please read this Privacy Policy carefully and ensure that you understand it. [Your acceptance of this Privacy Policy is requested <<insert point(s) at which acceptance is requested>>.]
1. Information About [Us] OR [Me]
[Our] OR [My] Site is [owned and] operated by <<insert business name>>, a <<insert business type, e.g. limited company, partnership, sole trader etc.>> [registered in England under company number <<insert company number>>].
[Registered address: <<insert address>>.]
[Main trading address:] OR [Address:] <<insert address>>.
[VAT number: <<insert VAT number>>.]
[Data Protection Officer: <<insert name>>.
Email address: <<insert email address>>.
Telephone number: <<insert telephone number>>.
Postal address: <<insert address>>.]
[Representative: <<insert name>>.
Email address: <<insert email address>>.
Telephone number: <<insert telephone number>>.
Postal address: <<insert address>>.]
[[We are] OR [I am] regulated by <<insert name(s) of regulator(s)>>.]
[[We are] OR [I am] a member of <<insert name(s) of association(s) etc.>>]
[<<insert further information as required>>.]
2. What Does This Policy Cover?
This Privacy Policy applies only to your use of [Our] OR [My] Site. [Our] OR [My] Site may contain links to other websites. Please note that [we] OR [I] have no control over how your data is collected, stored, or used by other websites and [we] OR [I] advise you to check the privacy policies of any such websites before providing any data to them.
3. What Is Personal Data?
Personal data is defined by the UK GDPR and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
4. What Are My Rights?
Under the Data Protection Legislation, you have the following rights, which [we] OR [I] will always work to uphold:
a) The right to be informed about [our] or [my] collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact [us] OR [me] to find out more or to ask any questions using the details in Part 10.
b) The right to access the personal data [we] OR [I] hold about you. Part 9 will tell you how to do this.
c) The right to have your personal data rectified if any of your personal data held by [us] OR [me] is inaccurate or incomplete. Please contact [us] OR [me] using the details in Part 10 to find out more.
d) The right to be forgotten, i.e. the right to ask [us] OR [me] to delete or otherwise dispose of any of your personal data that [we] OR [I] hold. Please contact [us] OR [me] using the details in Part 10 to find out more.
e) The right to restrict (i.e. prevent) the processing of your personal data.
f) The right to object to [us] OR [me] using your personal data for a particular purpose or purposes.
g) The right to withdraw consent. This means that, if [we are] OR [I am] relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
h) The right to data portability. This means that, if you have provided personal data to [us] OR [me] directly, [we are] OR [I am] using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask [us] OR [me] for a copy of that personal data to re-use with another service or business in many cases.
i) Rights relating to automated decision-making and profiling. [We] OR [I] do not use your personal data in this way.
For more information about [our] OR [my] use of your personal data or exercising your rights as outlined above, please contact [us] OR [me] using the details provided in Part 10.
It is important that your personal data is kept accurate and up-to-date. If any of the personal data [we] OR [I]hold about you changes, please keep [us] OR [me] informed as long as [we] OR [I] have that data.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about [our] OR [my] use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. [We] OR [I] would welcome the opportunity to resolve your concerns [ourselves] OR [myself], however, so please contact [us] OR [me] first, using the details in Part 10.
5. What Personal Data Do You Collect and How?
Subject to the following, [we] OR [I] do not collect any personal data from you. [We] OR [I] do not place cookies on your computer or device, nor do [we] OR [I] use any other means of data collection.
[Our] OR [My] Site collects certain information automatically, including your IP address, the type of browser you are using, [<<insert additional data as applicable>>] and certain other non-personal data about your computer or device such as your operating system type or version, and display resolution.
If you send [us] OR [me] an email, [we] OR [I] may collect your name, your email address, and any other information which you choose to give [us] OR [me]. For the purposes of the Data Protection Legislation, [We are] OR [I am] the data controller responsible for such personal data.
The lawful basis under the Data Protection Legislation that allows [us] OR [me] to use such information is article 6(1)(f) of the UK GDPR which allows [us] OR [me] to process personal data when it is necessary for the purposes of [our] OR [my] legitimate interests, in this case, the proper operation and functionality of [Our] OR [My] Site. [If you contact [us] OR [me] as described above, you will be required to consent to [our] OR [my]use of your personal data to contact you. In this case, [our] OR [my] lawful basis for using your personal data will be article 6(1)(a) of the UK GDPR, which allows [us] OR [me] to use your personal data with your consent for a particular purpose or purposes.]
6. How Do You Use My Personal Data?
Where [we] OR [I] collect any personal data, it will be processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. [We] OR [I] will comply with [our] OR [my]obligations and safeguard your rights under the Data Protection Legislation at all times. For more details on security see Part 7, below.
As stated above, [we] OR [I] do not generally collect any personal data directly from you, but if you contact [us] OR [me] and [we] OR [I] obtain your personal details from your email, [we] OR [I] may use them to respond to your email. The other technical data referred to above is necessary for the technical operation of [Our] OR [My] Site [and will not normally be used in any way to personally identify you].
Any and all emails containing your personal data will be deleted no later than <<insert period>> after <<insert event, e.g. "the subject matter of your email has been resolved.">> and no other personal data will be retained for any longer than is necessary.
[We] OR [I] will not share any of your personal data with any third parties for any purposes [other than storage on an email and/or web hosting server].
7. How and Where Do You Store My Data?
[[We] OR [I] will [only store your personal data] OR [store some of your personal data] in the UK. This means that it will be fully protected under the Data Protection Legislation.]
AND/OR
[[We] OR [I] will [only store your personal data] OR [store some of your personal data] within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the EU GDPR and/or to equivalent standards by law. Transfers of personal data to the EEA from the UK are permitted without additional safeguards.]
AND/OR
[[We] OR [I] [may] store some or all of your personal data in countries outside of the UK. These are known as “third countries”. We will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation as follows:
[We ensure that your personal data is protected under binding corporate rules. Binding corporate rules are a set of common rules which all our group companies are required to follow when processing personal data. For further information, please refer to the Information Commissioner’s Office.]
OR
[[We] OR [I] will only store or transfer personal data in or to countries that are deemed to provide an adequate level of protection for personal data. For further information about adequacy decisions and adequacy regulations, please refer to the Information Commissioner’s Office.]
OR
[[We] OR [I] will use specific approved contracts which ensure the same levels of personal data protection that apply under the Data Protection Legislation. For further information, please refer to the Information Commissioner’s Office.]
Please contact [us] OR [me] using the details below in Part 10 for further information about the particular data protection safeguard[s] used by [us] OR [me] when transferring your personal data to a third country.]
Personal data security is essential to [us] OR [me], and to protect personal data, [we] OR [I] take the following measures:
· limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;
· procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where [we are] OR [I am] legally required to do so;
· <<describe specific measures in place>>.
8. Do You Share My Personal Data?
[[We] OR [I] will not share any of your personal data with any third parties for any purposes, subject to the following exception[s].
[If [we] OR [I] sell, transfer, or merge parts of [our] OR [my] business or assets, your personal data may be transferred to a third party. Any new owner of [our] OR [my] business may continue to use your personal data in the same way that [we] OR [I] have used it, as specified in this Privacy Policy (i.e. to communicate with you).]
In some limited circumstances, [we] OR [I] may be legally required to share certain personal data, which might include yours, if [we are] OR [I am] involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.]
OR
[[[We] OR [I] may contract with the following third [parties] OR [party] for hosting and data storage purposes:
· <<insert name and details of third party, including where the third party is located>>.
· <<add more third parties as appropriate>>.
If any of your personal data is transferred to a third party, as described above, [we] OR [I] will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, [our] OR [my]obligations, and the third party’s obligations under the law, as described above in Part 7.]
[If any personal data is transferred outside of the UK, [we] OR [I] will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation, as explained above in Part 7.]
[If [we] OR [I] sell, transfer, or merge parts of [our] OR [my] business or assets, your personal data may be transferred to a third party. Any new owner of [our] OR [my] business may continue to use your personal data in the same way(s) that [we] OR [I] have used it, as specified in this Privacy Policy (i.e. to communicate with you).]
In some limited circumstances, [we] OR [I] may be legally required to share certain personal data, which might include yours, if [we are] OR [I am] involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.]
9. How Can I Access My Personal Data?
If you want to know what personal data [we] OR [I] have about you, you can ask [us] OR [me] for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 10. [To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell [us] OR [me] everything [we] OR [I] need to know to respond to your request as quickly as possible.]
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover [our] OR [my]administrative costs in responding.
[We] OR [I] will respond to your subject access request within [<<insert period (less than one month)>> and, in any case, not more than] one month of receiving it. Normally, [we] OR [I] aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date [we] OR [I] receive your request. You will be kept fully informed of [our] OR [my] progress.
10. How Do I Contact You?
To contact [us] OR [me] about anything to do with your personal data and data protection, including to make a subject access request, please use the following details [(for the attention of <<insert name>>)]:
Email address: <<insert email address>>.
Telephone number: <<insert telephone number>>.
Postal Address: <<insert address>>
11. Changes to this Privacy Policy
[We] OR [I] may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if [we] OR [I] change [our] OR [my] business in a way that affects personal data protection.
Any changes will be immediately posted on [Our] OR [My] Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of [Our] OR [My] Site following the alterations. [We] OR [I]recommend that you check this page regularly to keep up-to-date. This Privacy Policy was last updated on <<insert date>>.