AssureMore ("We") are committed to protecting and respecting your privacy.
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
The rules on processing of personal data are set out in the General Data Protection Regulation (the “GDPR”).
Data controller - A controller determines the purposes and means of processing personal data.
Data processor - A processor is responsible for processing personal data on behalf of a controller.
Data subject – Natural person
Categories of data: Personal data and special categories of personal data
Personal data - The GDPR applies to ‘personal data’ meaning any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier (as explained in Article 6 of GDPR). For example, name, passport number, home address or private email address. Online identifiers include IP addresses and cookies.
Special categories of personal data - The GDPR refers to sensitive personal data as ‘special categories of personal data’ (as explained in Article 9 of GDPR). The special categories specifically include genetic data, and biometric data where processed to uniquely identify an individual. Other examples include racial and ethnic origin, sexual orientation, health data, trade union membership, political opinions, religious or philosophical beliefs.
Processing - means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Third party - means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.
2. Who are we?
AssureMore is the data controller. This means we decide how your personal data is processed and for what purposes. For all data matters contact firstname.lastname@example.org.
3. The purposes of processing your personal data
We use your personal data for the following purposes:
· To provide you with information about our services, activities and events
· To deliver our professional services
· To maintain our own accounts and records
· To help us improve the services we offer
· You may give us information about you by filling in forms on our site www.assuremore.com (our site) or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you submit the ‘Contact Us’ form on our site or when you report a problem with our site.
4. The categories of personal data concerned
With reference to the categories of personal data described in the definitions section, we process the following category of your data:
Personal data – this can include your name, phone number, email address and IP address.
We do not process any special categories of personal data.
5. What is our legal basis for processing your personal data?
In some cases, the collection of personal data may be a statutory or contractual requirement, and we will be limited in the services we can provide you if you don’t provide your personal data in these cases.
Users of our services
In order to provide you with a service, we process your personal data on the basis of Article 6(1)(b) of the GDPR (entering into and performance of terms of service with you), or where that is not applicable, then on the basis of Article 6(1)(f) of the GDPR (necessity for our or a third party's legitimate interests in providing you with a high quality service, operating our business, and exercising our rights and obligations under our terms of service with you). GDPR Article 6(1)(f) also legitimises our use of personal data for the purpose of:
· Demonstrating, improving and promoting our services;
· The establishment, exercise or defence of legal claims.
6. Sharing your personal data
Your personal data will be treated as strictly confidential, and will be shared only with trusted third party companies and individuals to facilitate our services, to provide the services on our behalf, to perform related services or to assist us in analysing the performance of our services.
7. How long do we keep your personal data?
We will only retain your personal data for as long as necessary (i) to fulfil the purposes we collected it for, (ii) for the purposes of satisfying any related legal, regulatory, compliance or local authority requirements, (iii) in order to handle questions or complaints, and (iv) to establish, bring or defend legal claims.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
8. Your rights and your personal data
Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data:
· The right to request a copy of the personal data which we hold about you;
· The right to request that we correct any personal data if it is found to be inaccurate or out of date;
· The right to request your personal data is erased where it is no longer necessary to retain such data;
· The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), (where applicable i.e. where the processing is based on consent or is necessary for the performance of a contract with the data subject and where the data controller processes the data by automated means);
· The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
· The right to object to the processing of personal data, (where applicable i.e. where processing is based on legitimate interests; direct marketing and processing for the purposes of scientific/historical research and statistics).
9. Transfer of Data Abroad
We do not transfer personal data outside the EEA.
10. Automated Decision Making
We do not use any form of automated decision making in our business.
11. Further processing
If we wish to use your personal data for a new purpose, not covered by this Data Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions.
13. How to make a complaint
To exercise all relevant rights, queries or complaints please in the first instance contact our Data Privacy Representative on email@example.com.
If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 03031231113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England.