Any personal information provided to or gathered by affiliatecircle.co.uk is controlled by Paddock Media Services LTD registered at Motivo House, Bluebell Rd, Yeovil BA20 2FG (“we”, “us”, “our”).
Collection of your Personal Information
Our website, available at the domain name upon which this Notice appears (“Site”) provides a service intended to direct users, who complete an enquiry through our Site or related online platforms, to a service provider that may be able to assist them with a particular type of claim (“Service Providers”).
As the purpose of our Site is to direct you to an appropriate Service Provider, the information that you complete will be passed on in this way; you can be assured that with all third parties necessary to operate our business, we or where relevant Paddock Media, have adopted approved model data protection clauses in our arrangements with them, to ensure they meet the same high standards required in relation to the processing of your personal information under applicable data protection laws.
You have a choice whether to provide any information to us, except where this is necessary to fulfil any contract – such as in relation to the provision of our services (albeit recognising that such a decision may mean that we are unable to provide our services as you expect), or where we are required to do so by applicable law or a Government agency or law enforcement.
The purpose of our service is to help direct you to a relevant Service Provider for your needs. Paddock Media assists us in this respect and where a suitable provider is identified, your information will be transferred securely to that relevant Service Provider.
We may on occasion have the need to transfer your data to suppliers located outside of the European Economic Area (“EEA”), including in the USA. We will only do so where the legal regimes of those territories outside of the EEA offer an equivalent standard of data protection to our own.
Our Data Protection Obligations
All information provided to us through this Site will be treated as confidential and we will not abuse this trust by providing all or any part of your information toothers, except for Service Providers, unless you have consented to this or where this is in our legitimate interests, further outlined below. Except as outlined above, your information will not be sold, licensed, loaned or otherwise distributed to any other organisation unless we are required to do so by applicable law. Subject to any overriding obligation to which we are subject, you have the right to object to the processing of your personal information, by a simple request that we stop such processing.
Why we Process your Personal Information
Our use of your personal information will at all times be in accordance with applicable data protection laws; we rely on the following grounds justifying our processing of personal data:
• Consent – explicit consent for us to do so.
• A Contract or Legal Obligation – to fulfil our obligations under an existing contract or other legal obligation, in certain circumstances our right to process this information will override your right to object to us doing so.
• Legitimate Interests – we may judge that we have legitimate grounds to process your personal information in certain ways and where that is the case, we will balance our own interests against your own or the relevant individual whose data is being processed, to ensure that the rights and interests of those individuals who interact with us are protected.
Where information is obtained through or as a result of your use of our Site, we will only use this information for the following purposes:
• to understand and appreciate your needs and requirements as a user of our site or our services generally;
• for analysis in relation to the technical specification and user experience of our site, for the purposes of developing and improving our site and the services that we provide;
• to keep in contact with you.
Managing Your Preferences
You have the right to manage your preferences in relation to the kinds of information that we collect and the manner in which your information is processed – you can update these preferences at any time through our site; you can also withdraw your consent, either as a whole or in relation to particular kinds of information or delivery methods.
You may ask us to erase information that we hold about you, except where there is some other reason requiring us to maintain the information, such as for insurance purposes, for example. We monitor and will also delete information and data that we hold, where we reasonably consider this no longer to be required.
If you have accepted the relevant cookies, we may collect, store and process non-personal information about you automatically as a result of your use of this site, such as the type of internet or mobile browser that you are using to gain access and any website from which you linked to us, but you cannot be identified from this information. We will only use such non-personal information to help provide an effective and more relevant website offering.
Under GDPR (which, in this Privacy Notice, means EU Data Protection Regulation 2016/679 and laws implementing or supplementing GDPR as the data protection or privacy laws of any
other country), the nature of the processing that we undertake does not require us to appoint a formal Data Protection Officer (DPO); however, we may maintain equivalent standards and the nominated representative for the purposes of compliance with our data protection obligations is our founder/owner.
Technical and Organisational Measures and Security
The protection of our clients’ personal information is important to us and therefore we have and maintain appropriate technical and organisational measures to achieve these aims. These seek to protect the personal information that we process from and against unauthorised or unlawful use or accidental loss, damage or destruction and we review these measures, on a regular basis to ensure that they are appropriate.
These include encrypted access to our systems, only accessible by our personnel, utilising secure and regularly-‐updated passwords and access to and processing of information through our site, using secure HTTPS. We do not, however, process any bank or card details through our site; instead of using an established third-party provider to take payments online.
In relation to data security, you accept the risk that data transmitted to us through this site via electronic means may be intercepted before reaching us or may be accessed by unauthorised third parties, or exploited unlawfully. We do not assume any responsibility for guarding against the acts of third parties and shall not be liable for any direct, indirect or consequential losses or damages incurred or suffered as a result.
Sharing your Personal Information
We will never share your personal information with others for commercial gain or in ways that you would not reasonably expect of us.
Although we will share the personal information provided through our Site to relevant Service Providers and others, as explained above, we will not share your personal information with anyone else, unless we have your explicit consent to do so or where we have a legal obligation to do so.
In addition, we may process your information where we are required or permitted to do so under applicable law, where required to do so by any Government agency or law enforcement, where it is necessary in connection with the sale or potential sale of our business or where we conclude that we have and can show one or more legitimate interests for doing so.
If you are unhappy with the way in which we handle your information or any response from us, you may seek further guidance or file a complaint with the Information Commissioner’s Office (ICO), Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF. Tel: 0303 123 1113 (local rate); 01625 545745.
Linking to Other Sites
To add value to visitors’ experiences when using this Site, we may provide links to other websites or resources for you to access at your sole discretion, but you agree that we shall not be responsible or liable to you in respect of the availability or content of, or consequences of you linking to, any such external site; although we welcome links to this Site, we shall be entitled to demand that such links are broken if we consider the content or nature of the linking site to be unsuitable or unprofessional, as we see fit.
How long we Store Personal Data
We maintain the data that we collect in providing our services only for a limited time, to fulfil our obligation to send your enquiry data to Paddock Media, for the purposes of selecting relevant Service Providers, after which our need to use and process your personal data is completed; following this processing, your data will generally be erased or securely destroyed within a relatively short period of time, unless we determine that there is a legitimate interest in holding such data for longer.
Where we are able to fulfil a request to delete and erase your personal information, we will fulfil that request, unless there is some other obligation to which we are subject requiring us to retain your data, in which case we will retain it only for so long as is necessary to meet that other legal obligation.
Your Rights and how to Exercise Them
You may request a copy of the information that we hold about you (known as a Subject Access Request). In addition, under the GDPR, you may exercise the following rights:
• A right of access to the information that we hold about you– as above.
• A right to have your information corrected if it is inaccurate or incomplete.
• A right to have information removed or deleted from our records and systems.
• A right to block us from processing your personal data or to limit the way(s) in which we can use it.
• A right of portability; to request that we move your personal information to someone else, in a machine-‐ readable form.
Please contact us via a simple request, where you wish to exercise any of your above rights or if you wish to file a complaint about our collection, processing or use of your personal information.
Right to Object to Processing
Whatever justification we rely on, under GDPR you have a right to object to our processing of your personal information unless we have a separate legal or regulatory obligation to do so, in which case our processing will only be limited to the extent to which we need to process your information. However, except for this, you may confirm your objection to the extent and kinds of processing being undertaken, by sending us a simple request, updating your preferences.
Your Information and Keeping it Up-‐to-‐Date
You have the right to request details of the information that we hold about you. Should you wish to be provided with these details, please contact us with a simple request.
We wish to keep any information that we hold about you accurate and up to date and therefore please contact us if the information we hold about you needs updating.
If you have any questions or concerns regarding your privacy, or if you experience difficulties in accessing or viewing this Site, please contact us (details above, or via this Site) or Paddock Media, whose details can be found on their website at:http://paddockmedia.co.uk; their privacy notice can be found at: http://paddockmedia.co.uk/privacy
Changes to this Privacy Notice
We may change or modify this Privacy Notice at any time and we recommend that you check the latest version of this notice each time that you access the Site. The date of the most recent update will appear below. Any significant changes to this notice may be confirmed through direct communication with you, where we consider that such changes should specifically be brought to your attention.
This Privacy Notice was last updated on September 2019.