This Policy explains what data we process, why, how it is legal and your rights.
- the matching of seekers of immigration advice and other visa or residency permit related services (‘customers’) with vetted providers of immigration advice and other visa or residency permit related services (‘Sellers’)
- the listing of Services provided by Sellers
- the booking of appointments for Customers with their chosen Seller
How to contact us
If you need to contact us about this Privacy Notice, use the details below.
Data Protection Officer: Gareth Richards
Address: 85 London Road, Cheltenham GL52 6HL, United Kingdom
Email: [email protected]
Useful words and phrases
This means any person who determines the purposes for which, and the manner in which, any personal data is processed.
CRIMINAL OFFENCE DATA
This means any information relating to criminal convictions and offences committed or allegedly committed.
DATA PROTECTION LAWS
This means the laws which govern the handling of personal data. This includes the General Data Protection Regulation (EU) 2016/679, the Data Protection Act 2018 and any other national laws related to data protection.
The person to whom the personal data relates.
This means the UK Information Commissioner’s Office which is responsible for implementing, overseeing and enforcing the Data Protection Laws.
This means any information from which a living individual can be identified. This will include information such as telephone numbers, names, addresses, e-mail addresses, photographs and voice recordings. It will also include expressions of opinion and indications of intentions about data subjects (and their own expressions of opinion/intentions). It will also cover information which on its own does not identify someone but which would identify them if put together with other information which we have or are likely to have in the future.
This covers virtually anything anyone can do with personal data, including: obtaining, recording, retrieving, consulting or holding it organising, adapting or altering it disclosing, disseminating or otherwise making it available aligning, blocking, erasing or destroying it.
SPECIAL CATEGORIES OF DATA
This means any information relating to:racial or ethnic origin, political opinions, religious beliefs or beliefs of a similar nature, trade union membership, physical or mental health or condition, sexual life, genetic data or biometric data for the purpose of uniquely identifying you.
What personal data do we collect?
While you visit our site, we’ll track:
- Products you’ve viewed: we’ll use this to, for example, show you products you’ve recently viewed
- Location, IP address and browser type: we’ll use this for purposes like estimating taxes
When you purchase from us, we’ll ask you to provide information including your name, billing address, email address, phone number, credit card/payment details and optional account information like username and password. We’ll use this information for purposes, such as, to:
- Send you information about your account and order
- Respond to your requests, including refunds and complaints
- Process payments and prevent fraud
- Set up your account for our store
- Share contact details with and only with your chosen service provider so that they may contact you to confirm service arrangements
- Comply with any legal obligations we have, such as calculating taxes
- Improve our store offerings
- Send you marketing messages, if you choose to receive them
If you create an account, we will store your name, address, email and phone number, which will be used to populate the checkout for future orders.
We generally store information about you for as long as we need the information for the purposes for which we collect and use it, and we are not legally required to continue to keep it. For example, we will store order information for 2 years for tax and accounting purposes. This includes your name, email address and billing and shipping addresses.
We will also store comments or reviews, if you choose to leave them.
Why do we process your personal data?
We use your personal data for the following purposes listed in this section. We are allowed to do so on certain legal bases (please see section ‘How is processing your data lawful‘ for further detail).
WHAT DATA DO WE NEED AND WHY DO WE NEED IT?
LEGAL BASIS FOR PROCESSING
Contact details and account details
So we can administer your account with us, including contacting you about the Services you have purchased from us or the Services you sell through us.
So that we can carry out the Services which you have purchased from us.
To enable secure payments to be made for services purchased.
Mailing list requests
So that we may keep you updated on developments, promotions and other areas of interest that you have given us explicit consent to contact you about.
Provision of Visa Signposting Call services
So that we may provide you with a high quality level of service and comply with any requests from regulators, law enforcement or other bodies to confirm the content of such calls where you have given us explicit consent to record the call.
Enquiries and complaints
To assist and respond to your enquiries and complaints about us and our services.
To fulfil your request to post a publicly accessible comments.
To provide our third-party advertisers with information used for the following purposes: delivering targeted advertisements to specific visitors, storing user identifiers, and collecting anonymous ad platform statistics.
How is processing your personal data lawful?
We are allowed to process your personal data for the following reasons and on the following legal bases:
It is necessary for our performance of the contract you have agreed to enter with us to use our Services. If you do not provide your personal data to us, we will not be able to carry out our obligations under the terms of the contract.
Where you have given us consent to do so, we will use your data for specific purposes which are optional, such as marketing. You can withdraw your consent at any time (see section ‘Your Rights’ for more information).
We need to process your personal data to defend or establish a legal claim (for example, claims relating to the sale of our products under contract law).
We are permitted to process your personal data if it is based on our ‘legitimate interests’ i.e. we have good, sensible, practical reasons for processing your personal data which is in our interests. To do so, we have considered the impact on your interests and rights, and have placed appropriate safeguards to ensure that the intrusion on your privacy is reduced as much as possible. You can object to any of the processing that we carry out on the grounds of legitimate interests (see the section ‘Your Rights’ to find out how).
Who will have access to your personal data?
We use the following categories of suppliers to support us in delivering our Services who will process your personal data: webhosting, cloud service providers and Sellers. We take steps to ensure that these suppliers treat your data in accordance with the law, only use it in accordance with our contract with them and keep it secure. If you would like to know the names of our suppliers, please contact us using the details at the section ‘How to Contact Us’. Your personal data will only be shared with the Seller you have contracted with through us and will not be made available to any other Seller.
We accept payments through PayPal. When processing payments, some of your data will be passed to PayPal, including information required to process or support the payment, such as the purchase total and billing information.
We use Jetpack for digital advertising, and we will collect and send the following information (made available from the visitor’s browser) to their Demand Partners: IP address, geographical data (derived from the IP address), user agent, operating system, device type, unique user ID (randomly generated identifier), current URL, and IAB (Interactive Advertising Bureau) interest category.
Data Retention: Log data (IP address, geographical data, user agent, operating system, device type) is stored for 30 days. The unique user ID is stored in cookies and is retained for 1 year.
Jetpack tracks ad impressions, video-related events (i.e. pause, mute, 100% plays, etc.) or errors, and ad click events.
Various cookies are used for the following purposes: delivering targeted advertisements to specific visitors, storing user identifiers, and collecting anonymous ad platform stats.
Transfers of your personal data outside the UK and the European Economic Area (EEA)
We do not transfer your personal data outside of the UK or European Union.
How we keep your personal data secure
We strive to implement appropriate technical and organisational measures in order to protect your personal data against accidental or unlawful destruction, accidental loss or alteration, unauthorised disclosure or access and any other unlawful forms of processing.
We aim to ensure that the level of security and the measures adopted to protect your personal data are appropriate for the risks presented by the nature and use of your personal data. We follow recognised industry practices for protecting our IT environment and physical facilities.
Personal data collected through web forms, purchases and offline sources such as expressly given consent to process data through another platform is stored in cloud-based storage solutions based in the UK and EU. All cloud-based storage solutions are certified to ISO 27001 for their Information Security Management Systems as well as ISO 20000 for their IT Service Management Systems.
When will we delete your data?
Personal and Special Categories of Data
Contact details and account details
Indefinite unless a request to delete is submitted by the data subject
Six years following purchase
Indefinite unless deleted
Enquiries and complaints
60 days after completed but longer if we need to retain complaint information for legal claims in relation to our services
Visa Signposting Call
90 days after the call but longer if we need to retain information for legal claims in relation to our services
Held for 30 days
Retained for 1 year
You have the following rights under the Data Protection Laws:
- the right to object to processing of your personal data
- the right of access to personal data relating to you (known as data subject access request)
- the right to correct any mistakes in your information
- the right to ask us to stop contacting you with direct marketing
- the right to prevent your personal data being processed
- the right to withdraw your consent
- the right to erasure
These rights are explained in more detail below. If you want to exercise any of your rights, please contact us (please see ‘How to contact us’).
We will respond to any rights that you exercise within a month of receiving your request, unless the request is particularly complex, in which case we will respond within three months.
Please be aware that there are exceptions and exemptions that apply to some of the rights which we will apply in accordance with the Data Protection Laws.
Right to object to processing of your personal data
You may object to us processing your personal data where we rely on a legitimate interest as our legal grounds for processing.
If you object to us processing your personal data we must demonstrate compelling grounds for continuing to do so. We believe we have demonstrated compelling grounds in the section headed ‘How is processing your personal data lawful’.
Right to access personal data relating to you
You may ask to see what personal data we hold about you and be provided with:
- a copy of the personal data
- details of the purpose for which the personal data is being or is to be processed
- details of the recipients or classes of recipients to whom the personal data is or may be disclosed, including if they are overseas and what protections are used for those overseas transfers
- the period for which the personal data is held (or the criteria we use to determine how long it is held)
- any information available about the source of that data
- whether we carry out an automated decision-making, or profiling, and where we do information about the logic involved and the envisaged outcome or consequences of that decision or profiling
To help us find the information easily, please provide us as much information as possible about the type of information you would like to see.
Right to correct any mistakes in your information
You can require us to correct any mistakes in your information which we hold. If you would like to do this, please let us know what information is incorrect and what it should be replaced with.
Right to ask us to stop contacting you with direct marketing
You can ask us to stop contacting you for direct marketing purposes. If you would like to do this, please contact us (see section ‘How to Contact Us’). You can also click on the ‘unsubscribe’ button at the bottom of our marketing emails. It may take up to five days for this to take place.
Right to restrict processing of personal data
You may request that we stop processing your personal data temporarily if:
- you do not think that your data is accurate. We will start processing again once we have checked whether or not it is accurate;
- the processing is unlawful but you do not want us to erase your data;
- we no longer need the personal data for our processing, but you need the data to establish, exercise or defend legal claims; or
- you have objected to processing because you believe that your interests should override our legitimate interests.
Right to withdraw consent
You may withdraw any consent that you have given us to process your personal data at any time. This means that we will not be able to carry out any processing that requires use of that personal data.
Right to withdraw consent
You can ask us to erase your personal data where:
- if you had given us consent to process your data, you withdraw that consent and we cannot otherwise legally process your data
- you object to our processing and we do not have any legitimate interests that mean we can continue to process your data
- your data has been processed unlawfully or have not been erased when it should have been
What will happen if your rights are breached?
You may be entitled to compensation for damage caused by contravention of the Data Protection Laws.
Complaints to the regulator
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