(We, Us, Our) are committed to protecting and respecting your privacy.

This Privacy & Cookies Policy (Policy), together with any other documents referred to on (Our Site) set out the basis on which any personal data We collect from you, or that you provide to Us, will be processed by Us for the purpose of any and all applicable data protection legislation in force from time to time including but not limited to the Data Protection Act 1998 and any replacement legislation, the General Data Protection Regulation (Regulation (EU) 2016/679), the Regulation of Investigatory Powers Act 2000, the Telecommunications (Lawful Business Practice) (Interception of Communications) Regulations 2000 (SI 2000/2699), the Electronic Communications Data Protection Directive (2002/58/EC), the Privacy and Electronic Communications (EC Directive) Regulations 2003 (SI 2426/2003) and any replacement legislation and all applicable laws and regulations relating to the processing of personal data and privacy, including where applicable the guidance and codes of practice issued by the Information Commissioner or any other supervisory authority, and the equivalent of any of the foregoing in any relevant jurisdiction (DP Legislation).

Please read the following carefully to understand Our views and practices regarding your personal data and how We will treat it. By continuing to use Our Site or any of the functionalities displayed on it you are accepting and consenting to the practices described in this Policy.

Controller

We are the controller and are responsible for your personal data. Where any processing is carried out by OneTwo Agency Ltd. (OneTwo), a company registered in England and Wales with company number 02257022 and whose registered office is at Unit 5 Centurion Court, Farington, Leyland, Lancashire, PR25 3UQ, they do so purely as data processors for the purposes of the Act.

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this Policy. If you have questions about this Policy, including any requests to exercise your legal rights (including those detailed below), please contact the DPO using the details set out below.

Changes to this Policy and your duty to inform Us of Changes

This version was last updated on 17/05/2018 and historic versions can be accessed by contacting Us. Any changes We may make to this Policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to this Policy.

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.

Information We may collect from you

We may collect and process the following data about you:

• Information you give Us. You may give Us information about you by filling in forms on Our Site or by corresponding with Us by phone, e-mail or otherwise. This includes information you provide when you use the contact functionalities via Our Site, participate in any interactive services which We operate via Our Site or social media platforms, enter a competition, receive the event booking services and our newsletter, promotion or survey, and when you report a problem with Our Site. The information you give Us may include without limitation your name, address, e-mail address and phone number, membership details, lifestyle and social circumstances, education and employment details, racial or ethnic origin, religious or other beliefs of a similar nature, personal description and photograph.
• Information We collect about you. With regard to each of your visits to Our Site We may automatically collect the following information:
  • technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
  • information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from Our Site (including date and time); products and/or services you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call Our customer service number.

Our Site uses cookies to distinguish you from other users of Our Site. This helps Us to provide you with a good experience when you browse Our Site and also allows Us to improve Our Site.

A cookie is a small file of letters and numbers that We store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.

We use the following cookies:

• Strictly necessary cookies. These are cookies that are required for the operation of Our Site. They include, for example, cookies that enable you to log into secure areas of Our website, use a shopping cart or make use of e-billing services.
• Analytical/performance cookies. They allow Us to recognise and count the number of visitors and to see how visitors move around Our Site when they are using it. This helps Us to improve the way Our Site works, for example, by ensuring that users are finding what they are looking for easily.
• Functionality cookies These are used to recognise you when you return to Our Site. This enables Us to personalise Our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Session cookies. These cookies store your browsing information and will be active until you leave Our Site and close your browser at which point they are erased.
• Persistent cookies. These cookies stay in one of a browser’s subfolders until they are deleted manually or your browser deletes them based on the duration period contained within the persistent cookie’s file. You can set your browser to automatically remove these cookies.
• Social sharing. These cookies enable you to share any of Our content that you may find interesting with friends via email and social media platforms.

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which We have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of Our Site.

For more information about cookies, please visit: https://www.allaboutcookies.org.

Uses made of the information

We use information held about you in the following ways:

• Information you give to Us. We will use this information:
  • to carry out Our obligations arising from any contracts entered into between you and Us and to provide you with the information, products and/or services that you request from Us;
  • to maintain Our accounts and records, undertake research and to support and manage Our employees;
  • to provide you with information about other products and/or services We offer that are similar to those that you have already purchased or enquired about (where and to the extent that you have positively opted-in to receive the same);
  • (where and to the extent that you have positively opted-in to receive the same) to provide you, or permit selected third parties to provide you, with information about products and/or services We feel may interest you. If you are an existing customer, We will only contact you by electronic means (e-mail or SMS) with information about products and/or services similar to those which were the subject of a previous sale or negotiations of a sale to you. If you are a new customer, and where We permit selected third parties to use your data, We (or they) will contact you by electronic means only if you have consented to this. If you do not want Us to use your data in this way, or to pass your details on to third parties for marketing purposes, please tick the relevant box situated on the form on which We collect your data or otherwise notify Us in writing;
  • to notify you about changes to Our service;
  • to ensure that content from Our Site is presented in the most effective manner for you and for your computer.
• Information We collect about you. We will use this information:
  • to administer Our Site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
  • to improve Our Site to ensure that content is presented in the most effective manner for you and for your computer;
  • to allow you to participate in interactive features of Our service, when you choose to do so;
  • as part of Our efforts to keep Our Site safe and secure;
  • to measure or understand the effectiveness of advertising We serve to you and others, and to deliver relevant advertising to you;
  • to make suggestions and recommendations to you and other users of Our Site about products and/or services that may interest you or them.
• Information We receive from other sources. We may combine this information with information you give to Us and information We collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information We receive and where applicable, where and to the extent that you have positively opted-in to receive the same).

Disclosure of your information

Where and to the extent that you have positively opted-in to permit Us to do so, We may share your personal information with any member of Our group from time to time, which means Our subsidiaries, Our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.

Where and to the extent that you have positively opted-in to permit Us to do so, We may share your information with selected third parties including:

• Business partners, suppliers and sub-contractors for the performance of any contract We enter into with them or you.
• Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. Analytics and search engine providers that assist Us in the improvement and optimisation of Our Site.
• Survey and research organisations.
• Credit reference agencies for the purpose of assessing your credit score where this is a condition of Us entering into a contract with you.

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, where and to the extent that you have positively opted-in to permit Us to do so.
• If We are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply contractual agreements; or to protect Our rights, property, or safety and those of Our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

Where We store your personal data

Whilst not presently the case, 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. Such staff maybe engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy and in the event that this ever becomes necessary shall ensure that this is carried out subject to a Data Transfer Agreement for compliance with the DP Legislation.

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 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.

How Long We Keep Your Personal Data

We do not hold any personal data longer than necessary, having considered the purposes for processing.

Your rights

If you believe that any of the personal information We hold about you is incorrect, you have the right to ask Us to rectify that information at any time.

You may also have the right, in certain circumstances, to request that We delete your personal information, to block any further processing of your personal information or to object to the processing of your personal information. There are some specific circumstances where these rights do not apply and We can refuse to deal with your request.

Where You have opted in You have the right to ask Us not to continue to process your personal data for marketing purposes. You can exercise your right to prevent such continued processing by contacting Us at gdpr@onetwo.agency.

If We are processing your personal information based upon your consent (e.g. as part of our marketing or promotional activities), you have the right to withdraw your consent at any time.

If you require any further information about your right to rectification, erasure, restriction of or object to processing or you wish to withdraw your consent please contact Us at gdpr@onetwo.agency.

Our Site may, from time to time, contain links to and from the websites of Our partner networks, advertisers and affiliates. 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.

If you think Our collection or use of personal information is unfair, misleading or inappropriate or if you have concerns about the security of your personal information, you also have the right to make a complaint to the Information Commissioner’s Office. You can contact the Information Commissioner’s Office at the following address:

Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.

Access to information

You can find out if We hold any personal information about you by making a ‘subject access request’ under the DP Legislation. If We do hold information about you, We will:

• Give you a description of it;
• Tell you why We are holding;
• Tell you who it has been disclosed to; and
• Let you have a copy of the information in an intelligible form.

You may also have the right for your personal information to be transmitted electronically to another organisation in certain circumstances.

You can request access to the information we hold about you at any time by contacting us at gdpr@onetwo.agency.

Contact

Questions, comments and requests regarding this Policy are welcomed and should be addressed to the DPO at gdpr@onetwo.agency.