Holmes Media (UK) Ltd
1.1 We are committed to safeguarding the privacy of our website visitors and service users.
1.2 This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.
1.3 Our website incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can specify whether you would like to receive direct marketing communications and limit the publication of your information.
1.4 In this policy, “we”, “us” and “our” refer to Holmes Media (UK) Limited. For more information about us, see Section 9.
2. How we use your personal data
2.1 In this Section we have set out:
(a) the general categories of personal data that we may process;
(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
(c) the purposes for which we may process personal data; and
(d) the legal bases of the processing.
2.2 We may process data about your use of our website and services (“usage data”). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking systems. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.
2.3 We may process your business, enquirer and affiliate account data (“account data”). The account data may be processed for the purposes of operating our website, providing our services, operating our affiliate programme, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is:
(a) the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract; and/or
(b) our legitimate interests, namely the proper administration of our website and business.
2.4 We may process information that you post for publication on our website or through our services, including business listings and reviews (“listing and review data”). The listing and review data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is:
(a) the performance of a contract between you and us; and
(b) in all other cases, our legitimate interests, namely the proper administration of our website and business.
2.5 We may process information contained in any enquiry you submit to us regarding services (“enquiry data”). In some cases, we may obtain your enquiry data from our affiliate network. The enquiry data may be processed for the purposes of offering, marketing and selling services to you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business. In some cases, we may process information about your health relating to the social security benefits that you receive. Any such information will be processed as an element of your enquiry data. We will only process this information to the extent that it is necessary to do so for the purposes of your rights or obligations, or our rights or obligations, or those of our business partners, in the field of social security law. For example, we will ask whether you receive disability-related benefits when you enquire about services where special tariffs are available for persons in receipt of those benefits.
2.6 We may process information relating to transactions, including purchases of services, that you enter into with us and/or through our website (“transaction data”). The transaction data may include your contact details, and the transaction details. The transaction data may be processed for the purpose of supplying the purchased services, making affiliate payments and keeping proper records of transactions. The legal basis for this processing is:
(a) the performance of a contract between you and us; and/or
(b) our legitimate interests, namely our interest in the proper administration of our website and business.
2.7 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data”). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent.
2.8 We may process your personal information contained in or relating to any communication that you send to us or that we send to you, including telephone communications (“communications data”). The communications data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The communications data may be processed for the purposes of communicating with you, call recording and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with businesses, enquirers, affiliates and other website users.
2.9 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
2.10 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
2.11 In addition to the specific purposes for which we may process your personal data set out in this Section, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
2.12 Please do not supply any other person’s personal data to us, unless we prompt you to do so.
3. Providing your personal data to others
3.1 After you make an enquiry, we may disclose your enquiry data to one or more of the businesses we work with for the purpose of enabling them to contact you so that they can offer you relevant goods and/or services. Each such third party will act as a data controller in relation to the enquiry data that we supply to it. A directory of businesses is published on our website.
3.2 Financial transactions relating to our services, including payments we make to our affiliates and payments made by businesses we work with and other services providers to us, may be handled by our payment services provider, Stripe Payments Europe Ltd. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services provider’s privacy policies and practices at: https://stripe.com/gb/privacy
3.3 We may disclose your personal data to our suppliers and subcontractors in the following categories:
(a) hosting services suppliers; and
(b) communications services suppliers (including those providing call recording services).
3.4 Some of our suppliers may set cookies on your computer when you use our website, and through those cookies may gain access to your usage data. Details of these services providers are set out in our cookies policy.
3.5 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
3.6 In addition to the specific disclosures of personal data set out in this Section, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
4. Retaining and deleting personal data
4.1 This Section sets out our data retention policies, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
4.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
4.3 We will retain your personal data as follows:
(a) in the case of enquiries which do not result in a successful referral, enquiry data will be retained for a minimum period of 1 years following the date of submission of the enquiry, and for a maximum period of 2 years following that date;
(b) in the case of enquiries which do result in a successful referral, enquiry data will be retained for a minimum period of 6 years following the date of the submission of the enquiry data, and for a maximum period of 7 years following the end of your relationship with us;
(c) irrespective of whether an enquiry results in a successful referral, any health data included in enquiry data will be either deleted or combined with other data such that it ceases to be health data not more than 6 months following the date of submission of that data;
(d) listing and review data will be retained for as long as it remains published on our website, and for a maximum period of 7 years following the end of the publication period;
(e) usage data will be retained for a period of 26 months following collection; and
(f) all other personal data (including account data, transaction data, notification data and communications data including call recordings) will be retained for a minimum period of 6 years following the date of collection of the data, and for a maximum period of 7 years following the end of your relationship with us.
4.4 Notwithstanding the other provisions of this Section, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
5.1 We may update this policy from time to time by publishing a new version on our website.
5.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
5.3 We may notify you of significant changes to this policy by email.
6. Your rights
6.1 In this Section, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
6.2 Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
6.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. You can access your personal data by contacting us via the contact form.
6.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
6.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
6.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
6.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
6.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
6.9 To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract; and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
6.10 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
6.11 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
6.12 You may exercise any of your rights in relation to your personal data by written notice to us.
7.1 All personal data that we receive into our systems from our website forms or from our partners is transmitted in encrypted form; and personal data that we store in our core platform, and all call recordings, are encrypted at the filesystem level.
7.2 Our databases are protected by firewalls and access control mechanisms.
7.3 We regularly and systematically pseudonymize or anonymise sensitive personal data that we no longer require.
7.4 The systems and security measures that we use are subject to regular vulnerability checks and audits.
9. Our details
9.1 This website is owned and operated by Holmes Media (UK) Limited.
9.2 We are registered in England and Wales under registration number 06873930, and our registered office and principal place of business is at 11 The Point, Rockingham Road, Market Harborough, LE16 7QU.
9.3 We welcome your feedback and questions. If you wish to contact us, please do so:
(a) by post, to the postal address given above;
(b) using our website contact form; or
(c) by telephone, on 01858 461010.
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