1.1 We are committed to safeguarding the privacy of our website visitors, service users, individual customers and customer personnel.
1.2 This policy applies where we are acting as a data controller with respect to the personal data of such persons; in other words, where we determine the purposes and means of the processing of that personal data.
1.3 When using our website, if you submit a contact form we will hold you data inline with our data management policy, see 3. The personal data that we collect.
1.4 In this policy, "we", "us" and "our" refer to Cloakbury Limited t/a Curve Serviced Offices.
2.1 This document was created using a template from Docular (https://seqlegal.com/free-legal-documents/privacy-policy).
3. The personal data that we collect
3.1 In this Section 3 we have set out the general categories of personal data that we process[ and, in the case of personal data that we did not obtain directly from you, information about the source and specific categories of that data].
3.2 We may process data enabling us to get in touch with you ("contact data"). The contact data may include your name, email address and telephone number. The source of the contact data is you and/or your employer.
3.3 We may process your website user account data ("account data"). The account data may include your account identifier, name, email address, business name, account creation and modification dates, website settings and marketing preferences. The primary source of the account data is you and or your employer, although some elements of the account data may be generated by our website.
3.4 We may process information contained in or relating to any communication that you send to us or that we send to you ("communication data"). The communication 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.
3.5 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 from our analytics tracking system, Google Analytics.
4. Purposes of processing and legal bases
4.1 In this Section 4, we have set out the purposes for which we may process personal data and the legal bases of the processing.
4.2 Direct marketing - We may process contact data and account for the purposes of creating, targeting and sending direct marketing communications by email and making contact by telephone for marketing-related purposes. The legal basis for this processing is our legitimate interests, namely promoting our business and communicating marketing messages and offers to our website visitors and service users.
4.3 Research and analysis - We may process usage data for the purposes of researching and analysing the use of our website and services, as well as researching and analysing other interactions with our business. The legal basis for this processing is our legitimate interests, namely monitoring, supporting, improving and securing our website, services and business generally.
4.4 Legal compliance and vital interests - We may also process 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.
5. Providing your personal data to others
5.1 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.
5.2 Your personal data held in our website database will be stored on the servers of our hosting services providers identified at Wix.com.
5.5 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.
6. International transfers of your personal data
6.1 In this Section 6, we provide information about the circumstances in which your personal data may be transferred to a third country under UK data protection law.
6.2 We may transfer your personal data from the European Economic Area (EEA) to the UK and USA and process that personal data in the UK for the purposes set out in this policy, and may permit our suppliers and subcontractors to do so, during any period with respect to which the UK is not treated as a third country under EU data protection law or benefits from an adequacy decision under EU data protection law;
6.3 The hosting facilities for our website are situated in USA. The competent data protection authorities have made an adequacy determination with respect to the data protection laws of each of these countries.
6.4 Transfers to each of these countries will be protected by appropriate safeguards.
7. Retaining and deleting personal data
7.1 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.
7.2 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.
7.3 We will retain your personal data as follows:
(a) contact data will be retained for a minimum period of 6 months following the date of the most recent contact between you and us, and for a maximum period of 12 months following that date; reviewed annually on the 5th January. If not live for 12 months it is automatically omitted
(b) account data will be retained for a minimum period of 6 years following the date of termination of the relevant license agreement, and for a maximum period of 7 years following that date;
(c) communication data will be retained for a minimum period of 6 months following the date of the communication in question, and for a maximum period of 12 months following that date; reviewed annually in January. If not live for 12 months it is automatically omitted; and
(e) usage data will be retained for 12 months following the date of collection. Reviewed annually in January. If not live for 12 months it is automatically omitted;
7.4 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.
8. Your rights
8.1 In this Section 8, we have listed the rights that you have under data protection law.
8.2 Your principal rights under data protection law are:
(a) the right to access - you can ask for copies of your personal data;
(b) the right to rectification - you can ask us to rectify inaccurate personal data and to complete incomplete personal data;
(c) the right to erasure - you can ask us to erase your personal data;
(d) the right to restrict processing - you can ask us to restrict the processing of your personal data;
(e) the right to object to processing - you can object to the processing of your personal data;
(f) the right to data portability - you can ask that we transfer your personal data to another organisation or to you;
(g) the right to complain to a supervisory authority - you can complain about our processing of your personal data; and
(h) the right to withdraw consent - to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.
8.3 These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by visiting https://edpb.europa.eu/our-work-tools/general-guidance/gdpr-guidelines-recommendations-best-practices_en and https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.
8.4 You may exercise any of your rights in relation to your personal data by written notice to us, using the contact details set out below.
9. Links to other sites
10.1 We may update this policy from time to time by publishing a new version on our website.
10.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
10.3 We may notify you of significant changes to this policy by email.
11. Our details
11.1 This website is owned and operated by Cloakbury Ltd t/a Curve Serviced Offices.
11.2 We are registered in England and Wales under registration number 01998578, and our registered office is at The Thames Suite, 133 Creek Road, Greenwich, London, SE8 3BU.
11.3 You can contact us:
(a) using our website contact form;
(b) by telephone, on the contact number published on our website; or
(c) by email, using the email address published on our website.
12. Data protection officer
12.1 Our data protection officer's contact details are: Data Compliance Officer; email address: email@example.com