Privacy Policy

Freshwave Group Ltd ("We") are committed to protecting and respecting your privacy.

This policy (together with our terms of use and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. We keep certain basic information when you visit our Site and recognise the importance of keeping that information secure and letting you know what we will do with it.

For the purpose of the Data Protection Act 1998 (the Act), the data controller is Freshwave Group Ltd of 12 New Fetter Lane, London EC4A 1JP (registration number ZA034639).

This policy only applies to our Site. If you leave our Site via a link or otherwise, you will be subject to the policy of that website provider. We have no control over that policy or the terms of the website and you should check their policy before continuing to access the website.

Information we may collect from you

We may collect and process the following data about you:

  • Information that you provide by filling in forms on our Site. This includes information provided at the time of registering to use our Site, subscribing to our application or requesting further applications. We may also ask you for information when you report a problem with our Site.
  • If you contact us, we may keep a record of that correspondence.
  • We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
  • Details of your visits to our Site including, but not limited to, traffic data, location data, weblogs, operating system, browser usage and other communication data, whether this is required for our own purposes or otherwise and the resources that you access.

Categories of personal data you give to us

The personal data you give us includes:

  • Name
  • Employer
  • Employer Address
  • Employer Telephone number
  • Employer Email address
  • User name and passwords to access our applications
  • Photograph
  • Location information

Your location information

We may use GPS technology or other technology to determine your current location to provide certain functionality to you as part of our Site and applications. Some of our location-enabled applications require your location data for the feature to work. You can withdraw your consent to determine your current location at any time through your device settings.

Your device information

Each time you visit or use our Site or use our applications, we may automatically collect technical information, including the type of mobile device you use, a unique device identifier (for example, your device's IMEI number, the MAC address of the device's wireless network interface, or the mobile phone number used by the device), mobile network information, your mobile operating system, the type of mobile browser you use, and/or time zone setting;

We may automatically collect but not limited to, Internet protocol (IP) address used by your device, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes and the application that you access, URL click stream information showing how users have reached our Site and applications and whether they access other third-party sites via any external links.

Cookies

We may obtain information about your general internet usage by using a cookie file which is stored on the hard drive of your computer. Cookies contain information that is transferred to your computer's hard drive. They help us to improve our Site and to deliver a better and more personalised application. They enable us:

  • To estimate our audience size and usage pattern.
  • To store information about your preferences, and so allow us to customise our Site according to your individual interests.
  • To speed up your searches.
  • To recognise you when you return to our Site.

You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. However, if you select this setting you may be unable to access certain parts of our Site. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you log on to our Site.

View the Cookie Policy page.

Where we store your personal data

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Site, you are responsible for keeping this password confidential. We ask you not to share your user name or a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Uses made of the information

We use information held about you in the following ways:

  • To ensure that content from our Site is presented in the most effective manner for you and for your computer.
  • To provide you with information, products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes.
  • To carry out our obligations arising from any contracts entered into between you and us.
  • To allow you to participate in interactive features of our service, when you choose to do so.
  • To notify you about changes to our application.

Disclosure of your information

We may disclose your personal information to third parties:

  • In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
  • If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, our customers, or others. Your rights

Links to and from other websites

Our Site may, from time to time, contain links to and from other websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

Data security

Once it is within our control, we will do our utmost to ensure your personal data is processed in a way that ensures appropriate security from unauthorised or unlawful processing, accidental loss, destruction or damage.

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.

Retaining your personal information

We will 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. We may also retain your personal data for a reasonable period afterwards to allow us to respond to any follow up enquiries or complaints.

To determine appropriate retention periods 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 requirements.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, we may use or store this information indefinitely without further notice to you.

In some circumstances you can ask us to delete your data, see below Right of Erasure.

Access to information

Withdraw consent

Where we are using your personal information based on your consent, you have the right to withdraw that consent at any time. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at masts@freshwavegroup.com.

Right to be informed

You have the right to be told how your personal information will be used. This policy document is intended to be a clear and transparent description of how your data may be used.

Right of access

You can write to us asking what information we hold on you and to request a copy of that information. This is called a Subject Access Request. From 25 May 2018 we will have 30 days to respond to you once we are satisfied you have rights to see the requested records and we have successfully confirmed your identity. See below for details on how to submit a Subject Access Request.

Right of erasure

From 25 May 2018, you have the right to be forgotten (i.e. to have your personally identifiable data deleted). However, we may not always be able to comply with your request of erasure for specific legal reasons, which will be notified to you. In some cases, we may recommend that we supress you from future communications, rather than data deletion.

Right of rectification

If you believe our records are inaccurate you have the right to ask for those records concerning you to be updated. This enables you to have any incomplete or inaccurate data we hold about you corrected. We may need to verify the accuracy of the new data provided to us.

Right to restrict processing

In certain situations, you have the right to ask for processing of your personal data to be restricted because there is some disagreement about its accuracy or legitimate usage.

Right to data portability

Where we are processing your personal data under your consent, the law allows you to request data portability from us to another service provider. This right is largely seen as a way for people to transfer their personal data from one service provider to another. We are not a personal service provider.

Right to object

You have an absolute right to stop the processing of your personal data for direct marketing purposes. Simply contact our us to amend your contact preferences.

Right to object to automated decisions

In a situation where a data controller is using your personal data in a computerised model or algorithm to make decisions "that have a legal effect on you", you have the right to object. This right is more applicable to mortgage or finance situations. We do not undertake complex computerised decision making, that produce legal effects.

Changes to our privacy policy

Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. However, we advise that you check this page regularly to keep up to date with any necessary changes.

How to make a Subject Access Request

A Subject Access Request should be in writing and can be submitted by letter or email. So that we can respond fully, your request must include your name and correspondence address (email address where applicable). Please provide us with as much detail as possible on the information you require. This will enable us to identify the information requested.

Before responding to your Subject Access Request, we will require proof of identity to ensure that we do not release the information to anybody else other than you. If information is required in a format, for example, a photocopy or electronic copy, please state this in your request.

If we need more information from you to help us find your information or identify you, we will ask you for further information. The 30-day timescales will commence once we are satisfied we have all the necessary identification and information to respond to your request.

Contact

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to masts@freshwavegroup.com.

Complaints

If, for any reason, you have a complaint, please contact the Data Protection Officer to discuss your concerns.

Data Protection Officer: Andrew Saunders
Email: asaunders@spydersites.com
Call: 01279 215555
Post: Freshwave Group Ltd of 12 New Fetter Lane, London EC4A 1JP

Following this, if you are still dissatisfied, you can contact the Information Commissioner's Office directly at the contact details below.

Information Commissioner: Contact telephone number: 0303 123 1113 www.ico.org.uk

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