1. INTRODUCTION
1.1 We are committed to safeguarding the privacy of our website visitors and service users.
1.2 This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.
1.3 By using our website (www.albertpenn.com) and agreeing to this policy, you consent to our use of cookies in accordance with the terms outlined in this policy.
1.4 Our website allows you to amend your communication preferences and/or opt-out from specific communications at any time. When you share data with us, you will receive a prompt asking whether you would like to opt in and receive marketing communications from us. If you opt in to our marketing communications, you will be able to opt out of communications at a later point by clicking ‘unsubscribe’ at the footer of the relevant email. If you want to edit your details at any point you can email us at info@albertpenn.com to update your preferences.
1.5 We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website and services, we will ask you to consent to our use of cookies when you first visit our website.
1.6 In this policy, "we", "us" and "our" refer to Albert Penn Ltd.
2. CREDIT
2.1 This document was created using a template from SEQ Legal https://seqlegal.com/free-legal-documents/privacy-policy.
3. HOW WE USE PERSONAL DATA
3.1 In this Section 3 we have set out:
(a) the general categories of personal data that we may process;
(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
(c) the purposes for which we may process personal data; and
(d) the legal bases of the processing.
3.2 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. This usage data may be processed for the purposes of analysing the use of the website. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and optimizing our services.
3.3 We may process information contained in any enquiry you submit to us regarding our services ("enquiry data"). The enquiry data may be processed for the purposes of offering, marketing and selling relevant services to you. The legal basis for this processing is consent or legitimate interest, namely the proper administration of our website and business.
3.4 We may process information relating to transactions, namely purchases of services, that you enter into with us ("transaction data"). The transaction data may include your contact details and the transaction details. The source of the transaction data is you and or our payment services provider. The transaction data may be processed for the purpose of supplying the purchased 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 taking steps, at your request, to enter into such a contract.
3.5 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.
3.6 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.
3.7 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.
3.8 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.
4. PROVIDING YOUR PERSONAL DATA TO OTHERS
4.1 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.
4.2 Your personal data held in our website database will be stored on the servers of our hosting services providers at www.squarespace.com
4.3 We may disclose enquiry and transaction data to our suppliers or subcontractors insofar as reasonably necessary for delivering our services and marketing solutions.
4.4 Financial transactions relating to our website and services may be handled by our payment services providers. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds.
4.5 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. INTERNATIONAL TRANSFERS OF YOUR PERSONAL DATA
5.1 In this Section 6, we provide information about the circumstances in which your personal data may be transferred to outside the European Economic Area (EEA).
5.2 The hosting facilities for our website are situated in the United States.
5.3 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 take all appropriate measures to keep your data secure, however we cannot prevent the use (or misuse) of such personal data by others.
6. RETAINING AND DELETING PERSONAL DATA
6.1 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.
6.2 We will only retain your personal information for the time that is necessary to achieve the purpose for which it was processed. For some purposes such as our business accounting obligations, this length of time will be determined by legislation.
6.3 We will hold your personal information on our email circulation list until you unsubscribe from the circulation or email us requesting removal of your details.
6.4 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. YOUR RIGHTS
7.1 You may ask us to provide you with any personal information we hold about you. Provision will be subject to the supply of appropriate evidence of your identity
7.2 We may withhold personal information if required to by legal obligation
7.3 You may instruct us at any time not to process your personal information for marketing purposes either through opting out or by email notice to info@albertpenn.com
8. ABOUT COOKIES
8.1 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.
8.2 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.
8.3 Cookies do not typically 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.
9. COOKIES THAT WE USE
We use cookies for the following purposes:
(a) authentication and status - we use cookies to identify you when you visit our website and as you navigate our website, and to help us determine if you are logged into our website (cookies used for this purpose are: ss_cid,ss_cpvisit, ss_cvisit, ss_cvr, ss_cvt );
(b) personalisation - we use cookies to store information about your preferences and to personalise our website for you (cookies used for this purpose are: remember_client, SiteUserInfo, SiteUserSecureAuthToken, squarespace-announcement-bar, squarespace-likes, squarespace-popup-overlay, Test, TZ);
(c) 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 (cookies used for this purpose are: Crumb, siteUserCrumb, PHPSESSID);
(d) analysis - we use cookies to help us to analyse the use and performance of our website and services (cookies used for this purpose are: AWSALB, AWSALBCORS, algoliasearch-client-js); and
(e) cookie consent - we use cookies to store your preferences in relation to the use of cookies more generally (cookies used for this purpose are: ss_cookieAllowed).
10. COOKIES USED BY OUR SERVICE PROVIDERS
10.1 Our service providers use cookies and those cookies may be stored on your computer when you visit our website.
10.2 We use Google Analytics. Google Analytics gathers information about the use of our website by means of cookies. The information gathered is used to create reports about the use of our website. You can find out more about Google's use of information by visiting https://www.google.com/policies/privacy/partners/ and you can review Google's privacy policy at https://policies.google.com/privacy.
10.3 We use Facebook Ads Manager to deliver relevant adverts to our visitors. This service uses cookies to help us display Facebook advertisements that will be relevant to you, and to track the performance of these advertisements .
10.4 We use LinkedIn Ads Manager to deliver relevant adverts to our visitors. This service uses cookies to help us display LinkedIn advertisements that will be relevant to you, and to track the performance of these advertisements .
10.5 We use Google Ad Words to deliver relevant adverts to our visitors. This service uses cookies to help us display advertisements on your Google Search page that will be relevant to you, and to track the performance of these advertisements .
11. MANAGING COOKIES
11.1 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/enable-and-disable-cookies-website-preferences (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://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
11.2 Blocking all cookies will have a negative impact upon the usability of many websites.
11.3 If you block cookies, you will not be able to use all the features on our website.
12. AMENDMENTS
12.1 We may update this policy from time to time by publishing a new version on our website.
12.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
12.3 We will notify you of significant changes to this policy by email.
13. OUR DETAILS
13.1 This website is owned and operated by Albert Penn Ltd.
13.2 We are registered in England and Wales under registration number 11842332.
13.3 You can contact us:
(a) using our website contact form;
(c) by telephone, on the contact number published on our website; or
(d) by email, using the email address published on our website.