This privacy notice covers Delocate Ltd. Delocate Ltd is a subsidiary of Athyrium Group Limited, a holding company for a number of businesses (Delocate Ltd). These businesses will hereafter be collectively referred to as ‘The Athyrium Group’.
The Athyrium Group respects your privacy and is committed to protecting your personal data. We know that you care how information about you is used and shared and we appreciate your trust in us to do that carefully and sensibly. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.
2. IMPORTANT INFORMATION AND WHO WE ARE
Purpose of this privacy notice
This privacy notice aims to give you information on how The Athyrium Group collects and processes your personal data through your use of this website, including any data you may provide through this website when you purchase a product or service, visit our website, or sign up to receive updates from us.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
Delocate Ltd is the controller and responsible for your personal data (collectively referred to as “we”, “us” or “our” in this privacy notice).
Delocate Ltd is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us using the details set out below.
Full name of legal entity: Delocate Ltd
Company No. 1183-3172
VAT No. GB 322 7258 15
Data Privacy Manager: Tom Hayden
Registered Address: The Ferns, Yarmouth Road, Worstead, Norfolk, NR28 9LX
Email address: firstname.lastname@example.org
Telephone number: 01603-555-208
We are registered with the ICO under the Data Protection Register, our registration number is ZA524857.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
THIRD PARTY LINKS
Third Party Websites
It is possible that either clients or these third parties may grant permission to The Athyrium Group for us to place targeting pixels and cookies on their websites, possibly as a redirect from a social media post sent through our platform. This should be indicated in their policies; this will be used to investigate supporter journeys and possibly be used to create Custom Audiences for targeted advertising across digital media (including social media).
Social Media Platforms
This website uses social sharing buttons which help share web content directly from web pages to the social media platform in question. Users are advised before using such social sharing buttons that they do so at their own discretion and note that the social media platform may track and save your request to share a web page respectively through your social media platform account.
3. THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. 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:
- Identity data includes (first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender).
- Contact data includes (billing address, delivery address, email address and telephone numbers).
- Financial data includes (billing address, bank account and payment card details).
- Transaction data includes (details about payments to and from you and other details of products and services you have purchase from us).
- Technical data includes (internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website).
- Profile data includes (your username, purchases or orders made by you, your interests, preferences, feedback and survey responses).
- Usage data includes (information about you use our website, products and services).
- Marketing and Communications data includes (your preferences in receiving marketing from us and our third parties and your communication preferences).
We also collect, use and share Aggregated data such as statistical or demographical 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.
We do not collect any other categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
If you fail to provide personal data
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 goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this the case at the time.
4. HOW YOUR PERSONAL DATA IS COLLECTED
We use different methods to collect data from and about you, including through:
- Direct interactions. You may give us your (Identity, Contact and Financial Data) by filling in forms or corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- Apply for our products or services;
- Subscribe to our service or publications;
- Request marketing to be sent to you;
- Enter a competition, promotion or survey; or
- Give us feedback.
- Automated technologies or interactions. As you interact with our website, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies. We may also receive technical data about you if you visit other websites employing our cookies. Please see section 10 in this document for further information on cookies.
- Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
- Analytics providers (such as Google)
- Advertising networks;
- Identity and contact data from publicly available sources (such as Companies House and the Electoral Register based inside the EU)
5. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data where the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract, we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
Click here to find out more about the types of lawful basis that we will rely on to process your personal data.
Purposes for which we will use 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 are 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 bases we are relying on to process your personal data where more than one ground has been set out in the table.
|Purpose/Activity||Type of data||Lawful basis for processing (including basis of legitimate interest)|
|To register you as a new customer||a) Identity
|Performance of a contract with you|
|To process and deliver your order including:
a) Manage payments, fees and charges
b) Collect and recover money owed to us
e) Marketing and Communications
|a) Performance of a contract with you
b) Necessary for our legitimate interests (to recover debts due to us)
|To manage our relationship with you which will include:
b) Asking you to leave a review or take a survey
d) Marketing and Communications
|a) Performance of a contract with you
b) Necessary to comply with a legal obligation
c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services
|To enable you to partake in a prize draw, competition or complete a survey.||a) Identity
e) Marketing and Communications
|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 this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||a) Identity
|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
e) Marketing and Communications
|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
|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||a) Identity
|Necessary for our legitimate interests (to develop our products/services and grow our business)|
The Athyrium Group takes your privacy seriously. We keep your personal information private and secure and will not supply your details to any organisation for marketing purposes. When you opt in to receive marketing from us we ensure the content is relevant and interesting to you.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Promotional offers from us
If you are opted in to receive marketing content from us we may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.
You will receive marketing communications from us if you opted in following making a purchase from us or subscribing to our newsletter and updates.
If, after, opting in, you change your mind about receiving marketing emails from us you can ask us to stop at any time by contacting us.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. For more information about the cookies we use, please see section 11 of this document.
Change of purpose
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 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 notes 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.
6. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the purposes set out in the table in section 4 above.
- Internal Third Parties
- External Third Parties
- Specific third parties. We use third-party providers to help us to conduct our business. Third-party service providers will have access to personal information needed to perform their functions but may not use it for other purposes.
- Third parties to who we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same ways as set out in this privacy notice.
We may also share your personal data, in accordance with the law and for the purposes set out in the table in section 4 above, among the subsidiaries of Athyrium Group Limited; ‘The Athyrium Group’ as defined in sections 1 and 12.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
All services offered by third parties are strictly necessary to conduct our business. The following companies will have access to the personal data necessary to perform their functions but may not use it for other purposes. Please note this list may not include all third-party service providers used by The Athyrium Group.
7. INTERNATIONAL TRANSFERS
We share your personal data within The Athyrium Group. This may involve transferring your data outside the European Economic Area (EEA).
Many of our external third parties are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data outside of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data outside of the EEA.
8. DATA SECURITY
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 business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
Although we take precautions intended to help protect information we process, no system or electronic data transmission is completely secure. Any transmission of your personal data is at your own risk and we expect that you will use appropriate security measures to protect your personal information.
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.
9. DATA RETENTION
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, 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.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see Request erasure below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
10. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see the glossary below for further details.
If you wish to exercise any of the rights set out below, please contact us.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
a) Cookies Overview
If you run a website, you may already know what a cookie is and how it functions. Just in case you don’t know much about cookies, though, here is a brief overview:
A cookie (sometimes also referred to as a browser cookie, HTTP cookie, Internet cookie or Web cookie) is a small file sent from a Web server to your computer whenever you visit a website. If you return to the website later, your Web browser sends the small file to the server to notify the website of any previous activity you engaged in on the site. Once you return to a website, the server can retrieve the cookie file from the local computer to assist in expediting certain functions such as logging in and retrieving account or user data.
Cookies can serve many useful purposes, such as remembering items you had in a shopping cart, logging visited pages on the site and remembering login details, so you don’t have to enter them every time you visit the website. The most common types of cookies are authentication cookies, which servers use to determine whether a user is logged into a site or not.
b) Information Collected
- Log files – this would include things like IP addresses, browser type and version, time zone settings, browser plugins, operating systems and platform.
- Website usage, how long users spend on the sites and what they click on, how many times and with what they interact.
This information is used to help enhance features and services. It is worth noting that the IP address data collected cannot be used to identify you personally on its own, it would need to be combined with other information generated to construct a profile of you.
You can manage browser cookies through your browser settings. The ‘Help’ feature on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, how to disable cookies, and when cookies will expire. If you disable all cookies on your browser, neither we nor third parties will transfer cookies to your browser. If you do this, however, you may have to manually adjust some preferences every time you visit a site and some features and services may not work. To find out more about cookies, including how to see what cookies have been set, visit www.aboutcookies.org/ or www.allaboutcookies.org/.
Find out how to manage cookies on popular browsers:
To find out how to delete already stored cookies and for the browsers or operating systems that are not listed then please visit www.aboutcookies.org.
By using our sites, the cookies in place record your preferences, remembering information about how you use the site and allows us to compile statistical reports on our website activity. Through a visit any of The Athyrium Group domains the cookies are downloaded directly to the device that is accessing it.
Social Media Cookies
The Athyrium Group is active on a range of social media platforms and its services are tailored around the use of these social media sites. The Athyrium Group has no control over the use of the cookies on these third-party sites. Please see the policy links below for the social media site policies around privacy, cookies and data:
The Athyrium Group
‘The Athyrium Group’ encompasses Athyrium Group Ltd and all of its’ subsidiaries; namely Delocate Ltd
A small text file placed on your computer by this Website when you visit certain parts of the Website and or/when you use certain features of the Website.
Collectively all information that you submit to Delocate Ltd via the Website or other means. This definition incorporates, where applicable, the definitions provided in the Data Protection Laws
Data Protection Laws
Any applicable law relating to the processing of personal Data, including but not limited to the GDPR, and any national implementing laws, regulations and secondary legislation, for as long as the GDPR is effective in the UK.
The General Data Protection Regulation (EU) 2016/679
Legitimate interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Consent means that the data subject (you) has given consent to the processing of his or her personal data for one or more specific purposes.
External Third Parties
- Professional advisers [acting as processors or joint controllers] including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue and Customs, regulators and other authorities [acting as processors or joint controllers] based in the United Kingdom who require reporting of processing activities in certain circumstances.
YOUR LEGAL RIGHTS
You have the right to
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that are lawfully processing it. You should tell us how you would like to receive this information, via email, post etc.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- if you want us to establish the data’s accuracy;
- where our use of the data is unlawful but you do not want us to erase it;
- where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
- you have objected to our use if your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Effective Date: 09 September 2019
Last Reviewed: September 2019