PRIVACY POLICY

Table of Contents

I. Preamble
Approval Status
Version Control
Definitions

II. Context and Purpose
Policy Owner
Context
Relevant Regulatory framework
Purpose of Policy
Applicability of Policy
Contractual Status
Policy Review & Reissue

III. Policy: Privacy
Collection of personal information
Use of automated tools
Non-personal information
How we use your information
Opting in / out
Sale of personal information
Sharing of personal information
Young person’s privacy
Links to non-Company websites or social media
Your choices and selecting your privacy preferences
Accuracy of your information
Keeping your personal information secure
Contacting us

Preamble

Approval Status
This version is Approved for issue

Version Control
Date Version Author Changes / comments Issued
19/05/2014 Draft 1.0 Graham Smith First version, issued for comments TM & DM
21/05/2014 Issue 1.0 Graham Smith Approved for release All staff; public via website


Definitions
“Company”........................................ means channelcentral.net Limited and its successors and assigns.
“Confidential Information”......... means information that is marked or identified orally as confidential; or is reasonably known to be confidential; or contains customer lists, customer and account information, information regarding business planning and business operations, and/or administrative, financial, or marketing activities.
“Director”............................................ means a shareholding executive director of the Company, not being an Employee.
“Disclosure”....................................... means passing information gathered to others for action.
“Employee”........................................ means regardless of job title or role any person directly or indirectly employed by the Company including permanent full-time and part-time employees, contract workers, and temporary workers, but not a Director.
“Personal Information”................. means information about an individual that can be used to identify and individual.
“Policy”................................................ means a written document including this one which defines the Company’s position, policy and expectations on the subject matter.
“Supplier”........................................... means an organisation providing services of any nature to the Company.
“Third Party”..................................... means any non-Company entity or person.


Context and Purpose

Policy Owner
This policy is owned by the Company CIO, to whom any questions and suggestions should be directed.

Context
The Company respects your privacy. This Privacy Statement describes our privacy practices, choices about the way information is collected and how we use that information. If you have questions or complaints regarding our Privacy Policy, please get in touch using the contact information included at the end of this Policy.

Relevant Regulatory framework
In the development of the Company’s privacy policies and standards, we have taken into account some of the major principles and frameworks around the world, including the UK’s Data Protection Act, the OECD Guidelines on the Protection of Privacy and Transborder Flows, and the EU Directive 95/46/EC.

Purpose of Policy
This policy has been written to ensure that our policy is clear to all stakeholders. Adherence to this policy will ensure that the Company will:

  • Comply with the privacy expectations of our customers, staff and trading partners;
  • Comply with current and anticipated privacy legislation;
  • Minimise business risk to the company.

Applicability of Policy
channelcentral.net Limited is a UK organisation, albeit with business processes and customers that cross borders. The policy applies worldwide. This Privacy Policy applies to all Company-owned websites, domains, services, applications, and products, except that a privacy policy or statement that is specific to a particular Company programme, product, or service may supersede or supplement this Privacy Policy. It applies to our staff, suppliers and service providers, and to our customers and potential customers.

Contractual Status
For Suppliers operating under the terms of a contract to the Company, it is intended that the contractual terms obligate the Supplier to align with the provisions of this Policy.

Policy Review & Reissue
This policy shall be reviewed approximately annually. Any changes required to be made shall be approved by a Director before reissue.

Policy

Collection of Personal Information
The Company may collect, process, export, or use personal information to manage your relationship with us and to serve you better by personalising your experience and interaction with us. We may collect information from you in connection with any of the following although this is not an exhaustive list:

  • profile creation and user verification for online services
  • access to and use of websites or web-based applications
  • marketing, newsletter or support subscriptions
  • service orders, activations, and user registrations
  • information requests or complaints
  • job applications
  • event registration or attendance
The types of personal information we may collect from you include:
  • business contact information, such as name, address, telephone number, and email address
  • financial information, such as billing or payment information
  • unique information such as user IDs and passwords, contact preferences, educational and employment background
  • geo-location data such as your IP address or physical location when you request location based services
  • details of products and services you have purchased from us or which you have enquired about, together with any additional information necessary to deliver those products and services and to respond to your enquiries
  • any additional information relating to you that you provide to us directly through our websites or indirectly through use of our websites or social media
  • information you provide to us through our support services, customer surveys or visits by our representatives from time to time

Use of automated tools
In addition to the information you provide, we may also use automated data collection tools to collect information during a visit to a Company website or web-based application. This includes information that your browser sends to a website, such as your browser type, version and language; your access times; the address of the website from which you arrived; your IP address, unique device identifier; the pages you view, the links you click, and other actions you take in connection with Company websites. We may also use these tools in connection with certain emails and communications we send you, to collect information when you open the email or click on a link contained in the email.

Non-personal information
We may also collect some information that is not Personal Information because it does not identify you or anyone else. For example, we may collect anonymous answers to surveys or aggregated information about how people use our websites, products or services.

How we use your information
We may use your information to:
  • manage our relationship with you
  • keep your contact details up to date
  • allow our service providers and suppliers deliver their contracted services
  • provide information, support or advice about existing and new products or services
  • communicate with you about our products, services or support
  • send marketing communications about products, services and support to you, or to update you on new services and benefits
  • measure the performance of marketing initiatives
  • assist you in completing a transaction or order
  • prevent and detect security threats, fraud or other malicious activity
  • personalise some the Company websites or online services
  • provide you with access to protected areas of our website
  • assess and improve the products, services and support, performance and operation of our websites and online services
  • process and respond to any complaint made by you
  • conduct checks on business contacts as part of the Company’s sales due diligence, supplier due diligence, customer onboarding or staff recruitment processes
  • internal recruitment or payroll processing purposes
  • payment processing and fraud prevention.


Opting in / out
We will give you the opportunity to opt in/out of marketing communications we send.

Sale of personal information
We will not sell, rent or lease your personal information under any circumstances.

Sharing of personal information
Except as described in this Statement, we will not share your personal information with third parties without your permission, unless to: (i) respond to duly authorised information requests of the police or government authorities; (ii) comply with any law, regulation, subpoena, or court order; (iii) investigate and help prevent security threats, fraud or other malicious activity; (iv) enforce/protect our rights and properties; or (v) protect the rights or personal safety of the Company, our employees, and third parties.
The Company may share limited personal information with service providers. We retain service providers located in the UK, the US, or overseas locations to augment, manage or support its business operations. These providers include providers of credit card services, customer support services, marketing and communications, hosting and IT services. Our providers are contractually obliged to keep confidential and secure the information they receive on behalf of the Company, and may not use it for any purpose other than to carry out the services they are performing for us.

Young person’s privacy
We do not knowingly collect information from people under the age of 18, and do not target our services or websites to anyone under 18.

Links to non-Company websites or social media
Our websites or services may provide links to third-party applications, products, services, or websites, or to social media features, for your convenience and information. If you access those links, you will leave our site and our policy no longer applies.

Your choices and selecting your privacy preferences
We give you the choice of receiving a variety of information that complements our products and services. You can choose to unsubscribe from marketing communications or general communications such as newsletters. This option does not apply to communications primarily for the purpose of administering order completion, contracts, support, product safety warnings, or other administrative and transactional notices where the primary purpose of these communications is not promotional in nature. For email preferences, select the email "opt out" or "unsubscribe" link, or follow the opt-out instructions included in each email subscription communication. For other means of communication please refer to the ‘contact us’ section of this Policy.

Accuracy of your information
We strive to keep your personal information accurately recorded, so we provide individuals with reasonable access to their own personal information and to review, correct or delete it, as applicable. To protect your privacy and security, we will take reasonable steps to verify your identity, such as requiring a password and user ID, before granting access to your data.

Keeping your personal information secure
To prevent unauthorised access or disclosure, to maintain data accuracy, and to ensure the appropriate use of the information, we utilise reasonable and appropriate physical, technical, and administrative procedures to safeguard the information we collect and process.
The personal information you provide us is stored on computer systems located in controlled facilities which have limited access.

Contacting us
If you have comments or questions or a complaint about our Privacy Policy please email or write to us at the address below. We will treat your requests or complaints confidentially.
Our representative will contact you within a reasonable time after receipt of your complaint to address your concerns and outline options regarding how they may be resolved. We aim to ensure that your complaint is resolved in timely and appropriate manner.

Email us: click here
Or write to us at:
channelcentral.net Limited
13 Freeport Office Village
Braintree
Essex, CM77 8YG,
United Kingdom.
© channelcentral.net Ltd