What law applies?
Our use of your Personal Data is subject to both the UK`s Data Protection Act (“DPA”) and the EU’s General Data Protection Regulation (“GDPR”), and of course we process your Personal Data accordingly.
What is Personal Data?
Personal Data is any information relating to personal or material circumstances that relates to an individual. This may include, a name, date of birth, e-mail address, postal address, or telephone number but also online identifiers such as IP addresses or device ID`s.
What is processing?
“Processing” means any operation or set of operations which is performed upon Personal Data, whether or not by automatic means. The term is broad and covers virtually any handling of data.
Who is responsible for data processing?
The responsible party within the meaning of the DPA and the GDPR is Click Success LTD, Clyde Offices, 2nd floor – West George Street, Glasgow, G2 1BP (“Click Success”, “we”, “us”, or “our”).
If you have any questions or if you wish to exercise your rights, please email firstname.lastname@example.org, use our Contact Form or write to us at the above address.
What are the legal bases of processing?
In accordance with the DPA and the GDPR, we have to have at least one of the following legal bases to process your Personal Data:
Where necessary, we process your data beyond the actual performance of the contract in order to safeguard legitimate interests of us or third parties. Examples are:
Is there an obligation for me to provide data?
Within the scope of our business relationship, you are only required to provide personal data that is necessary for the establishment, implementation, and termination of a business relationship or that we are legally obliged to collect. Without this data, we will usually have to refuse to conclude the contract or will no longer be able to perform an existing contract and may have to terminate it.
Data we collect automatically
Each time you visit our website, our system automatically records data from the visiting device and stores it in a so-called log file. Among other purely technical information, this includes both device information and the IP address (identification of the user’s device). The legal basis for processing is our legitimate interest.
Content Delivery Network
We use the Content Delivery Network (CDN) of WordPress by Automattic Inc to distribute our online content. A CDN is a network of regionally distributed servers of our technical service providers connected via the Internet. When our website is visited, your device`s browser transmits information to these service providers, which is collected in corresponding server log files. Server log files are generally anonymised and then transmitted without any personal reference. Server log files however include, besides technical information, device information and the IP address of the visiting device. The legal basis for processing is our legitimate interest.
Content Management System (CMS)
We also use the Content Management System (CMS) of WordPress to publish and maintain the created and edited content and texts on our website. This means that all content and texts submitted to us is transferred to WordPress. This represents a legitimate interest.
To provide our website, we use the services of Siteground Ltd who processes all data to be processed in connection with the operation of this website, including log files on our behalf. The legal basis is our legitimate interest.
Third-party services and content
We use services of third-party providers to integrate certain content and functions in our website. This usually requires that these third-party providers are aware of the IP address of the visiting device, as without the IP address they would not be able to send the content to your browser. The IP address is therefore necessary for the display of the content and as such the legal basis is our legitimate interest.
The following provides an overview of third-party providers and their content, together with links to their privacy policies, which contain further information on the processing of data and so-called opt-out measures, if any,
Data we collect directly
In addition to your name, company name, and e-mail address, IP address or telephone number, if provided, we usually collect the context of your message which may also include certain Personal Data. The Personal Data collected when contacting us is to handle your request and the legal basis is both your consent and contract.
When using our services
We process the Personal Data involved in your use of our services in order to be able to provide our contractual services. However, we only want to process as much Personal Data (for example, your name, address, e-mail address or telephone number) as is absolutely necessary. Nevertheless, we rely on the processing of certain Personal Data, to do what we have to do including invoicing, fulfilment of our accounting and tax obligations. Accordingly, the data is processed on the basis of fulfilling our contractual obligations and our legal obligations.
Administration, financial accounting, office organisation, contact management
We process data in the context of administrative tasks as well as organisation of our business, and compliance with legal obligations, such as archiving. In this regard, we process the same data that we process in the course of providing our contractual services. The processing bases are our legal obligations and our legitimate interest.
Who receives my data?
Within Click Success, those that need your data to fulfil our contractual and legal obligations will receive access to it.
Processors used by us may also receive data for these purposes. These are companies in the categories of IT services, telecommunications, and sales and marketing. Where we use processors to provide our services, we take appropriate legal precautions and corresponding technical and organisational measures to ensure the protection of personal data in accordance with the relevant legal provisions.
Data is only passed on to third parties within the framework of legal requirements. We only pass on users’ data to third parties if this is necessary, for example, for contractual purposes or on the basis of legitimate interests in the economic and effective operation of our business or you have consented to the transfer of data.
How long will my data be stored?
As far as necessary, we process and store your personal data for the duration of our business relationship, which also includes, for example, the initiation and execution of a contract.
In addition, we are subject to various storage and documentation obligations, which result from the minimum statutory retention periods and HMRC, among others. The retention and documentation periods specified there are two to 6 years.
How do we secure your data?
Our website uses SSL or TLS encryption to ensure the security of data processing and to protect the transmission of content or contact requests that you send to us. We have also implemented numerous security measures (“technical and organisational measures”) for example encryption or need to know access, to ensure the most complete protection of Personal Data processed through this website.
Nevertheless, internet-based data transmissions can always have security gaps, so that absolute protection cannot be guaranteed. And databases or data sets that include Personal Data may be breached inadvertently or through wrongful intrusion. Upon becoming aware of a data breach, we will notify all affected individuals whose Personal Data may have been compromised as expeditiously as possible after which the breach was discovered.
Is data transferred internationally?
Special Category Data
Unless specifically required when using our services and explicit consent is obtained for that service, we do not process special category data.
We do not request Personal Data from minors and children and do not knowingly collect such data or pass it on to third parties.
Automated decision-making is the process of making a decision by automated means without any human involvement. Automated decision-making including profiling does not take place.
Do Not Sell
We do not sell your Personal Data.
Your Rights and Privileges
Under the DPA and GDPR, you can exercise the following rights:
If you have any questions about the nature of the Personal Data we hold about you, or if you wish to exercise any of your rights, please contact us.
Updating your information
If you believe that the information we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion, or object to its processing, please do so by contacting us.
Withdrawing your consent
You can revoke consents you have given at any time by contacting us. The legality of the data processing carried out until the revocation remains unaffected by the revocation.
In the event that you wish to make a Data Subject Access Request, you may inform us in writing of the same. We will respond to requests regarding access and correction as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days, we will tell you why and when we will be able to respond to your request. If we are unable to provide you with any Personal Data or to make a correction requested by you, we will tell you why.
Complaint to a supervisory authority
You have the right to complain about our processing of Personal Data to a supervisory authority responsible for data protection. The supervisory authority in Scotland is: The Information Commissioner’s Office – Scotland, Queen Elizabeth House, Sibbald Walk, Edinburgh, EH8 8FT, Telephone: 0303 123 1115 www.ico.org.uk
Changes and Questions
We may update this policy from time to time. If we make changes, we will revise this policy accordingly and also change the effective date at the end. We encourage you to periodically review this policy. If you would like to contact us regarding this policy, please email email@example.com, use our Contact Form or write to us at the above address.
Tuesday, 16 May, 2023