Information collection and use
This policy sets out the different areas where user privacy is concerned and outlines the obligations & requirements of the users, the website and website owners. Furthermore, the way this website processes, stores and protects user data and information will also be detailed within this policy.
This website and its owners take a proactive approach to user privacy and ensure the necessary steps are taken to protect the privacy of its users throughout their visiting experience. This website complies with the General Data Protection Regulation (EU) 2016/679 (GDPR) and all UK national laws and requirements for user privacy.
Whilst using our website, software applications or services, you may be required to provide personal information ( ie. email address). We will use this information to administer our website, applications, client databases and marketing material. We will ensure that all personal information supplied is held securely in accordance with the GDPR and all UK national laws and requirements for user privacy. Further, by providing telephone, fax and email details, you acknowledge that Seles Limited may contact you using that method. You have the right at any time to request a copy of the personal information we hold on you. Should you wish to receive a copy of this, or would like to be removed from our database, please contact us at firstname.lastname@example.org
Information collection and use
How do we collect information?
Seles Limited collects information in the following way:
When you directly give it to us (“Directly Provided Data”)
When you sign up for our site or communicate with us, you may choose to voluntarily give us certain information – for example, by filling in text boxes or completing registration forms. All this information requires a direct action by you at that time in order for us to receive it.
How do we use your personal data?
We will only use your personal data when 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 rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
The legitimate interests that we rely upon are business and commercial reasons, including conducting our business and providing services to our clients.
Note that we may process your personal data for more than one lawful basis. Please contact us if you have any questions about the specific legal grounds we are relying upon to process your personal data.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing.
We rely upon legitimate interests as the legal basis for sending marketing emails to you. We will only send marketing emails to you if you are a corporate subscriber, unless we have your prior consent.
You can unsubscribe from receiving marketing emails from us at any time by clicking the “unsubscribe” link at the bottom of any email. Once you do this, you will no longer receive any emails from us.
We may receive personal data about you from third party analytics providers, such as Google.
Automated decision making
Change of purpose
We will only use your personal information 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 information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
If you fail to provide personal information
If you fail to provide certain information when requested, we may not be able to enter into a contract with you or perform the contract we have entered into with you, or we may be prevented from complying with our legal obligations.
When we may share your personal data
We may have to share your data with third parties, including third-party service providers. We require third parties to respect the security of your data and to treat it in accordance with the law.
We may transfer your personal information outside the EEA. If we do, you can expect a similar degree of protection in respect of your personal information.
Why we may share my personal information with third parties
We may share your personal information with third parties where required by law, where it is necessary to administer our contract with you or where we have another legitimate interest in doing so.
We may share your personal data with other companies in the Seles Group acting as joint controllers or processors. We will keep your personal data secure and ensure we comply with the requirements of the GDPR when we share your personal data within Seles Group.
Which third-party service providers may process my personal information?
Our third party service providers change from time to time and we can let you have details of parties who are processing your data at any given time upon request. We routinely share personal data with IT service providers, cloud storage providers, our bank, legal and other professional advisers, and other service providers.
How secure is your personal data with third-party service providers?
All our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
What about other third parties?
We may share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business, or if it is required for legitimate business activities. We may also need to share your personal information with a regulator, HMRC or to otherwise comply with the law.
Transferring information outside the EEA
We may transfer your personal information outside the EEA. If we do, we will ensure there are appropriate measures in place to provide a similar degree of protection for your personal information as that required in the EEA.
- 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.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
- Where we are otherwise authorised to transfer your personal data, for example where you have given your explicit consent to the transfer, where it is necessary to performance of a contract between you and us, or where it is for the establishment, exercise or defence of legal claims.
Please contact us if you want further information on when we transfer your personal data out of the EEA and the specific mechanism used by us in such circumstances.
We have put in place measures to protect the security of your information. Details of these measures are available upon request.
Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
How long do we keep your data for?
Seles Limited will not retain your personal information longer than necessary. We will hold onto the information you provide either while your account is in existence, or as needed to be able to provide our services to you.
If legally required or if it is reasonably necessary to meet legal and regulatory requirements, resolve disputes, prevent fraud and abuse, or enforce our Terms and Conditions, we may also retain some of your information for a limited period of time as required, even after you it is no longer needed to provide our services to you.
Your duty to inform us of changes
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.
Your rights in connection with personal information
Under certain circumstances, by law you have the right to:
- Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).
- Object to processing of your personal information 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. You also have the right to object where we are processing your personal information for direct marketing purposes.
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal information to another party.
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact our data privacy manager in writing.
No fee usually required
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
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 the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
Right to withdraw consent
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. This will not affect the lawfulness of the processing based on your consent prior to you withdrawing your consent.
To withdraw your consent, please contact our data privacy manager. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
Data privacy manager
We have appointed a data privacy manager to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the data privacy manager.
Right to complain to the ICO
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.
Seles Limited will not sell or rent your personally identifiable information, gathered as a result of filling out the site registration form, to anyone.
Choosing how we use your data
We understand that you trust us with your personal information and we are committed to ensuring you can manage the privacy and security of your personal information yourself.
With respect to the information relating to you that ends up in our possession, and recognising that it is your choice to provide us with your personally identifiable information, we commit to giving you the ability to do all of the following:
- You can verify the details you have submitted to Seles Limited by contacting Data Privacy Manager (email@example.com). Our security procedures mean that we may request proof of identity before we reveal information, including your e-mail address and possibly your address.
- You can also contact us by the same method to change, correct, or delete your personal information controlled by Seles Limited regarding your profile at any time. Please note though that, if you have shared any information with others through social media channels, that information may remain visible, even if your account is deleted.
- You can always feel free to update us on your details at any point by emailing firstname.lastname@example.org
- You can unsubscribe from receiving marketing emails from us by clicking the “unsubscribe” link at the bottom of any email. Once you do this, you will no longer receive any marketing emails from us.
- You can request a readable copy of the personal data we hold on you at any time. To do this, please contact us at email@example.com
Seles Limited is a private limited liability company, incorporated and registered in England and Wales with company number 07012230 whose registered office is at 100 Pall Mall, 1st Floor, London, SW1Y 5NQ.
If you have any questions about this privacy notice, please contact our data privacy manager firstname.lastname@example.org.