BACKGROUND
This Policy applies as between you, the User of this Web Site and 55 Above Limited, the owner and provider of this Web Site. This Policy applies to our use of any and all Data collected by us in relation to your use of the Web Site and any services or systems therein.
1.DEFINITIONS AND INTERPRETATIONS
In this Agreement the following terms shall have the following meanings:
“Account”
means collectively the personal information, Payment Information and credentials
used by Users to access Material and / or any communications System on the Web
Site;
“Content”
means any text, graphics, images, audio, video, software, data compilations and any
other form of information capable of being stored in a computer that appears on or
forms part of this Web Site;
“Cookie”
means a small text file placed on your computer by 55 Above Limited when you visit
certain parts of this Web Site. This allows us to identify recurring
visitors and to analyse their browsing habits within the Web Site. Where e-commerce
facilities are provided, Cookies may be used to store your shopping basket. Further
details are contained in Clause 10 and Schedule 1 of this Policy;
“Data”
means collectively all information that you submit to the Web Site. This includes, but
is not limited to, Account details and information submitted using any of our Services
or Systems;
“55 Above”
means 55 Above Limited, whose registered office is at 4 Langford Court, Ongar Road,
Kelvedon Hatch, Brentwood, Essex, CM15 0LB. Our company registration number is 09012055.
“Service”
means any online communications infrastructure that 55 Above makes
available through the Web Site either now or in the future. This includes, but is not
limited to, web-based email, message boards, live chat facilities and email links;
“System”
means any online communications infrastructure that 55 Above Limited makes available
through the Website either now or in the future. This includes, but is not limited to,
web-based email, message boards, live chat facilities and email links;
“User” / “Users”
means any third party that accesses the Website and is not employed by 55 Above
and acting in the course of their employment; and
“Website”
means the website that you are currently using (www.55above.co.uk) and
any sub-domains of this site unless expressly excluded by their own terms
and conditions
2 DATA COLLECTED
2.1 name;
2.2 date of birth;
2.3 gender;
2.4 job title;
2.5 profession;
2.6 contact information such as email addresses and telephone numbers;
2.7 demographic information such as post code, preferences and interests;
2.8 financial information such as credit / debit card numbers;
2.9 IP address (automatically collected);
2.10 web browser type and version (automatically collected);
2.11 operating system (automatically collected);
2.12 a list of URLS starting with a referring site, your activity on this Web Site, and the site you exit to (automatically collected); and
2.13 Cookie information (see Clause 10 below).
3 OUR USE OF DATA
3.1 Any personal Data you submit will be retained by 55 Above for as long as you use the services and systems provided on the Web Site. Data that you may submit through any communications system that we may provide may be retained for a period of up to six months.
3.2 Unless we are obliged or permitted by law to do so, and subject to Clause 4, your Data will not be disclosed to third parties.
3.3 All personal Data is stored securely in accordance with the principles of the Data Protection Act 1998. For more details on security, see Clause 9 below.
3.4 Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Web Site. Specifically, Data may be used by us for the following reasons:
3.4.1 internal record keeping;
3.4.2 improvement of our products / services;
3.4.3 transmission by email of promotional materials that may be of interest to you;
3.4.4 contact for market research purposes which may be done using email, telephone, fax or mail. Such information may be used to customise or update the Web Site.
4 THIRD PARTY WEB SITES AND SERVICES
55 Above may, from time to time, employ the services of other parties for dealing with matters that may include, but are not limited to, payment handling, delivery of purchased items, search engine facilities, advertising and marketing. The providers of such services may have access to certain personal Data provided by Users of this Web Site. Any Data used by such parties is used only to the extent required by them to perform the services that 55 Above requests. Any use for other purposes is strictly prohibited. Furthermore, any Data that is processed by third parties must be processed within the terms of this Policy and in accordance with the Data Protection Act 1998.
5 CHANGES OF BUSINESS OWNERSHIP AND CONTROL
5.1 55 Above may, from time to time, expand or reduce its business and this may involve the sale of certain divisions or the transfer of control of certain divisions to other parties. Data provided by Users will, where it is relevant to any division so transferred, be transferred along with that division and the new owner or newly controlling party will, under the terms of this Policy, be permitted to use the Data for the purposes for which it was supplied by you.
5.2 In the event that any Data submitted by Users will be transferred in such a manner, you will be contacted in advance and informed of the changes. When contacted you will be given the choice to have your Data deleted or withheld from the new owner or controller.
6 CONTROLLING ACCESS TO YOUR DATA
6.1 Wherever you are required to submit Data, you will be given options to restrict our use of that Data. This may include the following:
6.1.1 use of Data for direct marketing purposes; and
6.1.2 sharing Data with third parties.
7 YOUR RIGHT TO WITHHOLD INFORMATION
7.1 You may access certain areas of the Web Site without providing any Data at all. However, to use all services and systems available on the Web Site you may be required to submit Account information or other Data.
7.2 You may restrict your Internet browser’s use of Cookies. For more information see Clause 10 below.
8 ACCESSING YOUR OWN DATA
8.1 You may access your Account at any time to view or amend the Data. You may need to modify or update your Data if your circumstances change. Additional Data as to your marketing preferences may also be stored and you may change this at any time.
8.2 You have the right to ask for a copy of your personal Data on payment of a small fee.
9 SECURITY
9.1 Data security is of great importance to 55 Above and to protect your Data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure Data collected online.
10 COOKIES
10.1 55 Above may set and access Cookies on your computer. First-party Cookies that may be placed on your computer are detailed in Schedule 1. All Cookies used by the Web Site are used in accordance with the provisions of the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended by the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011. 55 Above has carefully chosen these Cookies and uses them to facilitate certain functions and features of the Web Site. We also use Cookies for analytics purposes. These Cookies track your movements and activities on the Web Site and are designed to give us a better understanding of our users, thus enabling us to improve the Web Site and our services.
10.2 Before the Web Site sets Cookies on your computer, you will be presented with a prompt requesting your consent to set those Cookies. You will be deemed to have given your consent if you continue to use the Web Site without expressly withdrawing your consent. None of the Cookies set by the Web Site jeopardise your privacy in any way and no personal data is collected. By giving your consent to the setting of our Cookies you are enabling us to provide the best possible experience and service to you through our Web Site. If you wish to deny your consent to the placing of Cookies, certain features of the Web Site may not function fully or as intended.
10.3 You can choose to enable or disable Cookies in your web browser. By default, your browser will accept Cookies, however this can be altered. For further details please consult the help menu in your browser. Disabling Cookies may prevent you from using the full range of Services available on the Web Site.
10.4 You may delete Cookies at any time however you may lose any information that enables you to access the Web Site more quickly.
10.5 It is recommended that you ensure that your Internet browser is up-to-date and that you consult the help and guidance provided by the developer of your browser if you are unsure as to how to adjust your privacy settings.
11 CHANGES TO THIS POLICY
55 Above reserves the right to change this Privacy Policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the Web Site and you are deemed to have accepted the terms of the Policy on your first use of the Web Site following the alterations
Schedule 1: First-Party Cookies
Name of Cookie
Purpose
‘CMS_toolbar-collapsed’
cookie used for django cms to produce a toolbar (admin users only)
‘_ga’
Google Analytics unique identifier
‘_gat’
Google Analytics tracking cookie
‘csrftoken’
Cross site request forgery token for validation
‘sessionid’
Used to identify a user in a web session, for example used for
maintaining the shopping basket when the user is not logged in
‘cb-enabled’
Tracks whether the user has agreed the usage of cookies
55 Above Limited
February 2015
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