INTRODUCTION
Welcome to Topher Ltd service users and website visitors privacy policy.
Topher Ltd respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website or use the services of Topher Ltd (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
This privacy notice deals with the specific areas set out below. Please use the glossary below to understand the meaning of some of the terms used in this privacy notice:
IMPORTANT INFORMATION AND WHO WE ARE
THE DATA WE COLLECT ABOUT YOU
HOW IS YOUR PERSONAL DATA COLLECTED
HOW WE USE YOUR PERSONAL DATA
DISCLOSURES OF YOUR PERSONAL DATA
DATA SECURITY
DATA RETENTION
YOUR LEGAL RIGHTS
GLOSSARY
IMPORTANT INFORMATION AND WHO WE ARE PURPOSE OF THIS PRIVACY NOTICE
This privacy notice aims to give you information on how Topher Ltd collects and processes your personal data through your use of this website. This website is not intended for children and we do not knowingly collect data relating to children. It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific areas of our business when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
Controller
Topher Ltd is the controller and responsible for your personal data. In this policy “we”, “us” and “our” refer to Topher Ltd. We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.
CONTACT DETAILS
Full name of legal entity: Topher Ltd, 121, Centura House, Ancells Business Park, Ancells Road, Fleet, Hampshire, GU512UJ
Name and title of DPO: Christopher Haywood, Managing Director
Email address: Chris@topherlimited.co.uk
Telephone number: 01252 400230
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (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.
CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
This version was last updated on 22 May 2018 to reflect the General Data Protection Regulations (“GDPR”) which will come into effect in the UK on 25th May 2018.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
THIRD-PARTY LINKS
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections 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 privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed. Through your use of this website, we may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
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 this website.
Data
We may process usage data (data you provide including 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).
Profile data
We may process your information included in your personal profile on our website, the profile data may include,
Your name, address, telephone number, email address, gender, date of birth, relationship status, interests and hobbies, educational details and work history, nationality. The legal basis of this processing is consent or our legitimate interest, namely the proper administration of our web site and business, or the performance of a contract between you and us/taking steps, at your request, to enter such a contract.
Service Data
We May process your personal service data that are provided in the course of the use of our service, the service data may include the source of the service data is “you” or “your employer “the service data may be processed for the purpose of providing our services, ensuring the security of our website and services, maintaining backups of our database and communicating with you. The legal basis for this processing is consent or legitimate interest, namely the proper administration of our website and business, or the performance contract between you and us and/or taking steps, at your request, to enter into such a contract.
Publication data
We May process information that you post for publication on our website or through our service, the publication data may be processed for the purpose of enabling such publication and administering our website and services. The legal basis for this processing is consent or our legitimate interest, namely the proper administration of our website and business, or the performance of a contract between you and us and/or taking steps, at your request, to enter into such of a contract.
Enquiry data
We may process information contained in any enquiry you submit to us regarding services/requests. The enquiry data may be processed for the purpose of offering services and replying to requests to you. The legal basis for this processing is consent or our legitimate interest for the proper management of our business and the management of our customer relationship.
Customer Relationship data
We may process information relating to our customer relationships, including customer contact information, the customer relationship data may include, your name, employer, your job, title, role, contact details, and information contained in communications between us and you or your employer. The course of the relationship data is, you or your employer, the customer, for the purpose of managing our relationship with customers, communicating with customers, keeping records, of those communications and promoting our services to customers. The legal basis for this processing is consent/or our legitimate interests, namely the proper management of our customer relationships.
Transaction Data
We may process information relating to transactions. Including purchases of good and service that you enter into with us and/or through our website, the Transaction data may include your contact details, your bank details. The transaction data may be processed for the purpose of supplying/purchasing goods or 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 interest, namely the proper administration of our website and business.
Notification data
We may process information that you provide to us for the purpose of subscribing to our email notification and or newsletter, for the purpose of sending relevant notifications and/or newsletters. The legal basis for this processing is consent/or the performance of a contract between you and us/or taking steps, at your request, to enter into such a contract.
Correspondence data
We may process information contained in or relating to any communication that you send us, the correspondence data may include the communication data associated with the communication. The correspondence data may be processed for the process of communicating with you and record keeping. The legal basis for this processing is our legitimate interest, namely the proper administration of our website and business and communications with users.
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 administrative or out of court procedure. The legal basis is our legitimate interest, namely protection and assertion of our legal rights, your legal rights, and the legal rights of others.
We may process any of your personal data identified in this policy where necessary for the purpose of obtaining or maintaining insurance coverage. Managing risks, or obtaining professional advice. The legal basis of this processing is our legitimate interest, namely the proper protection of our business against risk.
In addition to the specific purpose for which we may process your personal data set out in this section, we may also process any of your personal data where such processing is necessary, for the compliance with legal obligations of which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
Please do not supply any other person’s personal data to us, unless we prompt you to do so.
Providing your personal data to others
We may disclose your personal data to our insures/ Professional advisors/ suppliers/sub-contractors, insofar as reasonably necessary for the purpose 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 or out of court procedure.
Financial transactions relating to our business/ services are/or may be handled by our payment service providers. We will share transaction data with our payment service providers only to the extent necessary for the purpose of proceeding with payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds.
Retaining and deleting personal data
Personal data that we process for any purpose shall not be kept for longer than is necessary for that purpose or purposes.
We may retain your personal data where such retention is necessary for compliance with legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person
Amendments
We May update this policy from time to time by publishing a new version on our website.
We may or may not notify you of changes to this policy, by email or private messenger, you should check this page occasionally to ensure you are happy with any changes to this policy.
IF YOU FAIL TO PROVIDE PERSONAL DATA
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 goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
CHANGE OF PURPOSE
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.
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.
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.
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, contractors and other third parties who have a business and 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.
YOUR LEGAL RIGHTS
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
Request access to your personal data.
Request correction of your personal data.
Request erasure of your personal data.
Object to processing of your personal data.
Request restriction of processing your personal data.
Request transfer of your personal data.
Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us.
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.
TIME LIMIT TO RESPOND
You will not usually 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 may refuse to comply with your request in these circumstances.
GLOSSARY
LAWFUL BASIS
Legitimate Interest means the interest 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. 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 by law). You can obtain further information about how we assess our legitimate interests against any particular impact on you in respect of specific activities by contacting us.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
EXTERNAL THIRD PARTIES
Service providers acting as processors who provide IT and system administration services.
Service providers acting as processors based in the UK who provide lettering services.
Professional advisers acting as processors including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue and Customs, regulators and other authorities acting as processors based in the UK who require reporting of processing activities in certain circumstances.
YOUR LEGAL RIGHTS
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 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 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: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need to establish, exercise or defend legal claims; or (d) 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 information to perform a contract with you.
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.
Further information
Topher Ltd web site is managed by CIM web design
Topher Ltd is registered in England and Wales under registration number 6126075
Business address:- 121 Centura House, Ancells Business Park, Ancells Road, Fleet, Hampshire, GU512UJ
You can contact us by:-
At our business address:
121, Centaur House
Ancells Business Park
Ancells Road
Fleet
GU51 2UJ
Website: www.topherlimited.co.uk
Telephone: 01252 400230
Email: manager@topherlimited.co.uk