1. Definitions and Interpretation
In this Policy, the following terms shall have the following meanings: “personal data” means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site. This definition shall, where applicable, incorporate the definitions provided in the [Data Protection Act 1998] OR [EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”)].
2. Information About Us
2.1 Our Site is [owned and] operated by CookieSale. 2.2 Our Data Protection Officer can be contacted by email at [email protected]
3. What Does This Policy Cover?
4. Your Rights
4.1 As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:
4.1.1 The right to be informed about Our collection and use of personal data;
4.1.2 The right of access to the personal data We hold about you;
4.1.3 The right to rectification if any personal data We hold about you is inaccurate or incomplete;
4.1.4 The right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you (We only hold your personal data for a limited time, as explained in section 5 but if you would like Us to delete it sooner, please contact Us using the details in section 13);
4.1.5 The right to restrict (i.e. prevent) the processing of your personal data;
4.1.6 The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);
4.1.7 The right to object to Us using your personal data for particular purposes; and
4.1.8 Rights with respect to automated decision making and profiling.
4.2 If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided in section 13 and We will do Our best to solve the problem for you.
5. What Data Do We Collect?
Depending upon your use of Our Site, we may collect some or all of the following personal [and non-personal] data:
5.1 [Your Name;]
5.2 [Contact information such as email addresses;]
5.3 [geographic information such as business address]
5.4 [Government issued ID and photograph in the event of a KYC, and can only be made upon request]
6. How Do We Use Your Data?
6.1 All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the [Data Protection Act 1998] OR [GDPR] at all times. For more details on security see section 7, below.
6.2 Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of your personal data (e.g. by subscribing to emails), or because it is in Our legitimate interests. Specifically, We may use your data for the following purposes:
6.2.1 [Supplying Our [products] AND/OR [services] to you (please note that We require your personal data in order to enter into a contract with you);]
6.2.2 [Personalising and tailoring Our [products] AND/OR [services] for you;]
6.2.3 [Replying to emails from you;]
6.2.4 [Supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time by clicking ‘Unsubscribe’ at the bottom of our email.;]
6.3 [With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by [email] AND/OR [telephone] AND/OR [text message] AND/OR [post] with information, news, and offers on Our [products] AND/OR [services]. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the [Data Protection Act 1998] OR [GDPR] and the Privacy and Electronic Communications (EC Directive) Regulations 2003.]
6.4 You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it.
7. How and Where Do We Store Your Data?
7.1 We only keep your personal data for as long as We need to in order to use it as described above in section 6, and/or for as long as We have your permission to keep it.
7.2 [Your data will only be stored in the United States.]
7.2 [Your data will only be stored within the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein).]
7.2 [Some or all of your data may be stored outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). You are deemed to accept and agree to this by using Our Site and submitting information to Us. If We do store data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the [Data Protection Act 1998] OR [GDPR].
7.3 Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure data collected through Our Site.
7.4 Steps We take to secure and protect your data include:
7.4.1 All communications containing personal data must be encrypted [using Secure Sockets Layer (SSL)/Transport Layer Security (TLS) for data transfer, creating a secure tunnel protected by 128-bit or higher Advanced Encryption Standard (AES) encryption].
7.4.2 All electronic copies of personal data should be stored securely using passwords and [256-bit Advanced Encryption Standard – AES] data encryption.
7.4.3 All personal data stored electronically should be backed up every hour with backups stored [onsite] AND/OR [offsite]. All backups should be encrypted [using 256-bit AES].
8. Do We Share Your Data?
8.1 [Subject to section 8.2, We will not share any of your data with any third parties for any purposes.
8.2 In certain circumstances, we may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal obligations, a court order, or a governmental authority.
8.3 In certain circumstances, we may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal requirements, a court order, or a governmental authority.]
9. What Happens If Our Business Changes Hands?
9.2 In the event that any of your data is to be transferred in such a manner, you will [not] be contacted in advance and informed of the changes. [When contacted you will [not, however,] be given the choice to have your data deleted or withheld from the new owner or controller.]
10. How Can You Control Your Data?
10.1 [In addition to your rights under the GDPR, set out in section 4, when] OR [When] you submit personal data via Our Site, you may be given options to restrict Our use of your data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details).
10.2 You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
11. Your Right to Withhold Information.
You may access [certain areas of] Our Site without providing any data at all. [However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.]
12. How Can You Access Your Data?
You have the right to ask for a copy of any of your personal data held by Us (where such data is held). Under the GDPR, no fee is payable and We will provide any and all information in response to your request free of charge.] Please contact Us for more details at [email protected], or using the contact details below in section 13. For repeated or complex requests, a small administration may be payable upon request.
13. Contacting Us