We will comply with data protection law. This says that the personal information we hold about you must be:
Personal data means any information relating to an identified or identifiable individual. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
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 services). In this case, we may have to cancel a service you have with us, but we will notify you if this is the case at the time.
We use different methods to collect data from and about you, including through:
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Generally, we do not rely on consent as a legal basis for processing your personal data.
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as a new customer||(a) Identity(b) Contact||Performance of a contract with you|
|To process and deliver your order||(a) Identity(b) Contact(c) Marketing and Communications||Performance of a contract with you|
|To process and deliver a service on behalf of a third party (e.g. public body or regulatory body):||(a) Identity(b) Contact(c) Profile||(a) Necessary for the performance of a task carried out carried out in the public interest or in the exercise of official authority(b) Necessary for our legitimate interests (providing our business services)|
|To enable you to partake in a prize draw, competition or complete a survey||(a) Identity(b) Contact(c) Profile(d) Usage(e) Marketing and Communication||(a) Performance of a contract with you(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)|
|To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity(b) Contact(c) Technical||(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)(b) Necessary to comply with a legal obligation|
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||(a) Identity(b) Contact(c) Profile(d) Usage(e) Marketing and Communications(f) Technical||Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences||(a) Technical(b) Usage||Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
|To make suggestions and recommendations to you about goods or services that may be of interest to you (marketing)||(a) Identity(b) Contact(c) Technical(d) Usage(e) Profile||Necessary for our legitimate interests (to develop our products/services and grow our business)|
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.
We may share your personal data with the parties set out below for the purposes set out in the table above.
If you are based in the EEA, we may transfer your personal data to the UK if we share it with other Amtivo companies.
We may also use service providers and organisations based outside the UK or EEA for the purpose of processing your personal data; where this is the case we will ensure that the transfer of your personal data is compliant with data protection law. You can obtain more details about the protection given to your personal data when it is transferred outside the UK or EEA by contacting us at email@example.com.
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, agents, contractors and other third parties who have a business 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.
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, regulatory, or reporting requirements. To determine the appropriate retention period 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.
Under certain circumstances, by law you have rights under data protection laws in relation to your personal data, as follows:
If you want to review, verify, correct or request erasure of your personal data, object to the processing of your personal data, or request that we transfer a copy of your personal data to another party, please contact firstname.lastname@example.org. You have the right to make a complaint at any time to your local data protection authority as set out below. We would, however, appreciate the chance to deal with your concerns before you approach your data protection authority so please contact us in the first instance.
|Region||Data Protection Authority|
|UK||Information Commissioner’s Office (ico.org.uk).|
|Republic of Ireland||Data Protection Commission (dataprotection.ie)|
|Italy||Garante per la Protezione dei Dati Personali (garanteprivacy.it)|
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.
If you have any questions or comments regarding how we handle your personal data, please contact us at:
Post: Data Protection, Amtivo, 30 Tower View, Kings Hill, West Malling, Kent ME19 4UY
If you are a user of the Activ software system, you can also contact the data protection officer for MyActiv Limited at email@example.com