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Linkcare Privacy
and cookies policy
1. Introduction
1.1 We
are committed to safeguarding the privacy of our website visitors and service
users in compliance with EU-General Data Protection Regulation (GDPR) 2016/679,
dated April 27th, 2016. This privacy statement explains when and why
we collect personal information, how we use it, the conditions under which we
may disclose it to others and how we keep it secure. This Privacy Statement
applies to the use of our products and to our sales, marketing and customer contract
fulfilment activities. It also applies to individuals seeking employment with
us.
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 We
will ask you to consent to our use of cookies in accordance with the terms of
this policy when you first visit our website
1.4 In
this policy, "we", "us" and "our" refer to Linkcare
Ltd. For more information about us, see Section 19.
2. How we use your personal data
2.1 In
this Section 2 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.
2.2 We
may process data about your use of our website ("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 Google
analytics. 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 monitoring and improving our website and services.
2.3 We
may process your account data ("account data"). The account
data may include your name and email address. The source of the account data is
you. The account data may be processed for the purposes of operating our
website, ensuring the security of our website and services, maintaining
back-ups of our databases and communicating with you. The legal basis for this
processing is our legitimate interests, namely the proper administration of our
website and business.
2.4 We
may process your information included in your personal profile on our website
("profile data"). The profile data may include your name,
address, telephone number, email address. The profile data may be processed for
the purposes of enabling your use of our website. The legal basis for this processing
is our legitimate interests, namely the proper administration of our website
and business.
2.5 We
may process information contained in any enquiry you submit to us regarding
goods and/or services ("enquiry data"). The enquiry data may
be processed for the purposes of offering, marketing and selling relevant goods
and/or services to you. The legal basis for this processing is consent.
2.6 We
may process information relating to transactions, including purchases of goods
and services, that you enter into with us and/or through our website ("transaction
data"). The transaction data may include your contact details, your
card details and the transaction details. The transaction data may be processed
for the purpose of supplying the purchased goods and 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 interests, namely our
interest in the proper administration of our website and business.
2.7 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.
2.8 We
may process information contained in or relating to any communication that you
send to us ("correspondence data"). The correspondence data
may include the communication content and metadata associated with the
communication. Our website will generate the metadata associated with
communications made using the website contact forms. The correspondence data
may be processed for the purposes of communicating with you and record-keeping.
The legal basis for this processing is our legitimate interests, namely the
proper administration of our website and business and communications with
users.
2.9 We
may process information contained
in or relating to any on-line review that
you provide us ("review data"). The source of
this data is Ekomi and Collect Reviews. This data
may be processed for promotional
purposes. The legal
basis for this processing is consent.
2.10 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.
2.11 In
addition to the specific purposes for which we may process your personal data
set out in this Section 2, 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.
2.12 Please
do not supply any other person's personal data to us, unless we prompt you to
do so.
3. Providing your personal data to others
3.1 We
may disclose personal data to
our supplier identified at https://mailchimp.com/ insofar as
reasonably necessary for emailing our
regular newsletter.
3.2 We
may disclose personal data to
our supplier identified at https://www.zoho.eu/ insofar as
reasonably necessary for managing contact and information requests from existing
and prospective customers and suppliers.
3.2 Financial
transactions relating to our website are handled by our payment services
providers, PayPal and WorldPay. 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. You can find information about the
payment services providers' privacy policies and practices at https://www.paypal.com/uk/webapps/mpp/ua/privacy-full
and https://www.worldpay.com/uk/privacy-policy.
3.3 In
addition to the specific disclosures of personal data set out in this Section 3,
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.
4. International transfers of your personal
data
4.1 In
this Section 4, we provide information about the circumstances in which your
personal data may be transferred to countries outside the European Economic
Area (EEA).
4.2 The hosting facilities for our websites are
situated in the United Kingdom. The European Commission has made an
"adequacy decision" with respect to the data protection laws of each
of the United Kingdom.
4.3 Our Email marketing supplier, Mailchimp
is situated in the USA. The European Commission has made an "adequacy
decision" with respect to the data protection laws of the USA. Transfers
to the USA will be protected by appropriate safeguards. See https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en
4.4 Our
CRM supplier, Zoho.com is
situated in the USA. The European Commission has made an "adequacy
decision" with respect to the data protection laws of the USA. Transfers
to the USA will be protected by appropriate safeguards. See https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en
5. Retaining and deleting personal data
5.1 This
Section 5 sets out our data retention policies and procedure, which are
designed to help ensure that we comply with our legal obligations in relation
to the retention and deletion of personal data.
5.2 Personal
data that we process for any purpose or purposes shall not be kept for longer
than is necessary for that purpose or those purposes.
5.3 We
will retain your personal data as follows:
(a) Your
personal data in our newsletter email
list will be retained for a minimum period of 1 month following your
instruction to be removed from this list, and for a maximum period of 3 months.
(b) Your
personal data in our CRM will
be retained for a minimum period of 1
month following your
instruction to be removed from this list, and for a maximum period of 3 months.
5.4 Notwithstanding
the other provisions of this Section 5, 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.
6. Security of personal data
6.1 We
will take appropriate technical and organisational precautions to secure your
personal data and to prevent the loss, misuse or alteration of your personal
data.
6.2 We
will store all your personal data on secure servers, personal computers and
mobile devices, and in secure manual record-keeping systems.
6.3 Data
relating to your enquiries and financial transactions that is sent from your
web browser to our web server, or from our web server to your web browser, will
be protected using encryption technology.
6.4 You
acknowledge that the transmission of unencrypted (or inadequately encrypted)
data over the internet is inherently insecure, and we cannot guarantee the
security of data sent over the internet.
6.5 You
should ensure that your password is not susceptible to being guessed, whether
by a person or a computer program. You are responsible for keeping the password
you use for accessing our website confidential and we will not ask you for your
password (except when you log in to our website).
7. Amendments
7.1 We
may update this policy from time to time by publishing a new version on our
website.
7.2 You
should check this page occasionally to ensure you are happy with any changes to
this policy.
8. Your rights
8.1 In
this Section 8, we have summarised the rights that you have under data
protection law. Some of the rights are complex, and not all of the details have
been included in our summaries. Accordingly, you should read the relevant laws
and guidance from the regulatory authorities for a full explanation of these
rights.
8.2 Your
principal rights under data protection law are:
(a) the
right to access;
(b) the
right to rectification;
(c) the
right to erasure;
(d) the
right to restrict processing;
(e) the
right to object to processing;
(f) the
right to data portability;
(g) the
right to complain to a supervisory authority; and
(h) the
right to withdraw consent.
8.3 You
have the right to confirmation as to whether or not we process your personal
data and, where we do, access to the personal data, together with certain
additional information. That additional information includes details of the
purposes of the processing, the categories of personal data concerned and the
recipients of the personal data. Providing the rights and freedoms of others
are not affected, we will supply to you a copy of your personal data. The first
copy will be provided free of charge, but additional copies may be subject to a
reasonable fee. You can access your personal data by visiting https://www.linkcare.net/index.php?route=account/account
when logged into our website.
8.4 You
have the right to have any inaccurate personal data about you rectified and,
taking into account the purposes of the processing, to have any incomplete
personal data about you completed.
8.5 In
some circumstances you have the right to the erasure of your personal data
without undue delay. Those circumstances include: the personal data are no
longer necessary in relation to the purposes for which they were collected or
otherwise processed; you withdraw consent to consent-based processing; you
object to the processing under certain rules of applicable data protection law;
the processing is for direct marketing purposes; and the personal data have
been unlawfully processed. However, there are exclusions of the right to
erasure. The general exclusions include where processing is necessary: for
exercising the right of freedom of expression and information; for compliance
with a legal obligation; or for the establishment, exercise or defence of legal
claims.
8.6 In
some circumstances you have the right to restrict the processing of your
personal data. Those circumstances are: you contest the accuracy of the
personal data; processing is unlawful but you oppose erasure; we no longer need
the personal data for the purposes of our processing, but you require personal
data for the establishment, exercise or defence of legal claims; and you have
objected to processing, pending the verification of that objection. Where
processing has been restricted on this basis, we may continue to store your
personal data. However, we will only otherwise process it: with your consent;
for the establishment, exercise or defence of legal claims; for the protection
of the rights of another natural or legal person; or for reasons of important
public interest.
8.7 You
have the right to object to our processing of your personal data on grounds
relating to your particular situation, but only to the extent that the legal
basis for the processing is that the processing is necessary for: the
performance of a task carried out in the public interest or in the exercise of
any official authority vested in us; or the purposes of the legitimate
interests pursued by us or by a third party. If you make such an objection, we
will cease to process the personal information unless we can demonstrate
compelling legitimate grounds for the processing which override your interests,
rights and freedoms, or the processing is for the establishment, exercise or
defence of legal claims.
8.8 You
have the right to object to our processing of your personal data for direct
marketing purposes (including profiling for direct marketing purposes). If you
make such an objection, we will cease to process your personal data for this
purpose.
8.9 You
have the right to object to our processing of your personal data for scientific
or historical research purposes or statistical purposes on grounds relating to
your particular situation, unless the processing is necessary for the
performance of a task carried out for reasons of public interest.
8.10 To
the extent that the legal basis for our processing of your personal data is:
(a) consent;
or
(b) that
the processing is necessary for the performance of a contract to which you are
party or in order to take steps at your request prior to entering into a
contract,
and
such processing is carried out by automated means, you have the right to
receive your personal data from us in a structured, commonly used and
machine-readable format. However, this right does not apply where it would
adversely affect the rights and freedoms of others.
8.11 If
you consider that our processing of your personal information infringes data
protection laws, you have a legal right to lodge a complaint with a supervisory
authority responsible for data protection. You may do so in the EU member state
of your habitual residence, your place of work or the place of the alleged
infringement.
8.12 To
the extent that the legal basis for our processing of your personal information
is consent, you have the right to withdraw that consent at any time. Withdrawal
will not affect the lawfulness of processing before the withdrawal.
8.13 You
may exercise any of your rights in relation to your personal data by written
notice to us in addition to the other methods specified in this Section 8.
10. Third party websites
10.1 Our
website includes hyperlinks to, and details of, third party websites.
10.2 We
have no control over, and are not responsible for, the privacy policies and
practices of third parties.
11. Updating information
11.1 Please
let us know if the personal information that we hold about you needs to be
corrected or updated.
12. About cookies
12.1 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.
12.2 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.
12.3 Cookies
do not typically contain any information that personally identifies a user, but
personal information that we store about you may be linked to the information
stored in and obtained from cookies.
13. Cookies that we use
13.1 We
use cookies for the following purposes:
(a) Status
- we use cookies to determine user session states across page requests (cookies
used for this purpose are PHPSESSID);
(b) Shopping cart - we use cookies to maintain
the state of your shopping cart as you navigate our website.
(c) Personalisation
- we use cookies to store information about your preferences and to personalise
our website for you.
(d) 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.
(e) Advertising
- we use cookies to help us to display advertisements that will be relevant to
you.
(f) Analysis
- we use cookies to help us to analyse the use and performance of our website
and services (cookies used for this purpose are Google analytics cookies _ga,
_gat and _gid); and
16. Cookies used by our service providers
16.1 Our
service providers use cookies and those cookies may be stored on your computer
when you visit our website.
16.2 We
use Google Analytics to analyse the use of our website. Google Analytics
gathers information about website use by means of cookies. The information
gathered relating to our website is used to create reports about the use of our
website. Google's privacy policy is available at: https://www.google.com/policies/privacy
16.3 We
use HotJar to provide analysis of visitor experience on our
website. You can view the privacy policy of this service provider at https://help.hotjar.com/hc/en-us/sections/115003180467-Privacy-Security-and-Operations.
17. Managing cookies
17.1 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?hl=en
(Chrome);
(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
(Firefox);
(c) http://www.opera.com/help/tutorials/security/cookies/
(Opera);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies
(Internet Explorer);
(e) https://support.apple.com/kb/PH21411
(Safari); and
(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy
(Edge).
17.2 Blocking
all cookies will have a negative impact upon the usability of many websites.
17.3 If
you block cookies, you will not be able to use all the features on our website.
18. Cookie preferences
18.1 You can manage your preferences relating to the use of cookies on our website by visiting: https://www.linkcare.net/index.php?route=account/gdpr
19. Our details
19.1 This
website is owned and operated by Linkcare
Ltd
19.2 We
are registered in England and Wales under registration number 2771600, and our VAT number is 714 3996 17. Our registered office is
at 15 Chiltern Business Village, Arundell Road, Uxbridge, Middlesex, UB8 2SN
19.3 Our
principal place of business is at 2 Chiltern Business Village, Arundell Road,
Uxbridge, Middlesex, UB8 2SN
19.4 You
can contact us:
(a) By
post, to the postal address given above;
(b) Using
our website contact form;
(c) By
telephone, on the contact number published on our website;
(d) By
email, using the email address published on our website.
22. Data protection officer
22.1 Our
data protection officer's contact details are: Simon Van Lessen – info@linkcare.net,
tel: - 01895 232626
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