This policy sets out how SimpleServe uses and protects any information that you give us when you use or interact with our website / place an order with us or contact us and where we otherwise obtain or collect information about you.
2. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
- Identity Data includes first name, last name, title and company name.
- Contact Data includes billing address, delivery address, email address, telephone numbers and website address.
- Financial Data includes bank account details.
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
- Usage Data includes information about how you use our website, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
3. How we collect your personal data
We use different methods to collect data from and about you including:
You may give us your identity, contact and financial data by filling in forms or by corresponding with us by post, phone, email, live-chat or otherwise. This includes personal data you provide when you:
- apply for our products or services;
- request marketing to be sent to you;
- enter a competition, promotion or survey; or
- give us some feedback.
Automated technologies or interactions:
Third parties or publicly available sources:
We may receive personal data about you from various third parties and public sources, including:
Technical Data from the following parties:
- analytics providers such as Google (based outside the EU);
- advertising networks such as Facebook and Google (based outside the EU); and
- search information providers such as Google (again, based outside the EU).
Identity and contact data from publicly available sources such as:
- Companies House; and
- the Electoral Register (based inside the EU).
If you give information on behalf of someone else you must ensure that you have their permission and that they have been provided with a copy of this policy before doing so.
If you are under 16 please do not provide us with any of your information unless you have the permission of your parent or guardian and in any case we only provide services to persons aged 18 years or above.
Please help us to keep your information up to date by informing us of any changes to your contact details or privacy preferences. You may change or review your preferences by clicking here.
4. How we use your personal data
We will only use your personal data when the law allows us to and where you give your permission for us to do so. 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 fundamental rights do not override those interests; or
- Where we need to comply with a legal or regulatory obligation.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
We have set out below a description of the ways we plan to use your personal data, and which of the legal basis’ we rely on to do so. We have also identified what our legitimate interests are, where appropriate.
Note: we may process your personal data for more than one lawful reason depending on the specific purpose for which we are using your data. Please contact us if you require additional details about the specific legal basis we are relying on to process your personal data where more than one basis has been set out in the table below.
|Purpose / Activity
||Type of data
||Lawful basis for processing / basis of legitimate interest
|To register you as a new customer
|Performance of a contract with you
|To process and deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(e) Marketing and Communications
|(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
|To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey
(d) Marketing and Communications
|(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
|To enable you to partake in a prize draw, competition or complete a survey
(e) Marketing and Communications
|(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
|(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
(e) Marketing and Communications
|Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
|Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
|To make suggestions and recommendations to you about goods or services that may be of interest to you
|Necessary for our legitimate interests (to develop our products/services and grow our business)
We provide you with choices regarding certain personal data uses, particularly around marketing and advertising and have therefore established the following personal data control mechanisms:
- Promotional offers from us
We may use your identity, contact, technical, usage and profile data to form a view on what we think you may want or need, or what may be of interest to you either now or in the future. This is how we decide which products, services and offers may be relevant for you (we call this marketing). You will only receive marketing communications from us if you have requested it or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not already opted out of receiving that marketing.
- Third-party marketing
We will get your express opt-in consent before we share your personal data with any company outside SimpleServe, and it’s subsidiaries, for marketing purposes.
You can ask us or, our chosen third parties, to stop sending you marketing information at any time by following the opt-out links on any marketing message sent to you, by updating your marketing preferences directly using our privacy options page or by contacting us at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product, service, purchase or other transaction.
Change of purpose
We will only use your personal data 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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose we will notify you and we will explain the legal basis which allows us to do so.
Note: we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or otherwise permitted by law.
SimpleServe may collect, store and process certain non-personal and personal information of users-of-users (“Users-of-Users Information”), solely on our users’ behalf and at their direction or if hosting is provided by us or one of our subsidiary companies. For example, each of our users are able to import their email contacts from third party services like Gmail, or otherwise collect and manage contacts via their user cPanel. Such contacts are then stored with SimpleServe on the user’s behalf. Alternatively, you may have a shared or dedicated hosting plan with us which means we have access to your customers (users) data.
For such purposes, SimpleServe shall be considered a “Data Processor” and not as the “Data Controller” (as both such capitalised terms are defined in the European Union General Data Protection Regulation) of such Users-of-Users Information. The users controlling and operating such user websites shall be considered the “Data Controllers” of such users-of-users information, and are responsible for complying with all laws and regulations that may apply to the collection and control of such users-of-users information, including all privacy and data protection laws of all relevant jurisdictions.
You are responsible for the security, integrity and authorised usage of your users-of-users’ personal information, and for obtaining consents, permissions and providing any fair processing notices required for the collection and usage of such information.
SimpleServe cannot provide legal advice to users or their users-of-users, however we do recommend that all users publish and maintain clear and comprehensive privacy policies on their user websites, in accordance with the applicable laws and regulations, and that all users-of-users carefully read those policies and make sure that they consent to them.
If you are a visitor, user or customer of any of our users, please read the following important notice: SimpleServe has no direct relationship with the individual users-of-users whose personal information it processes. If you are a visitor, user or customer of any of our users, and would like to make any requests or queries regarding your personal information, please contact the user(s) directly. For example, if you wish to access, correct, amend, or delete inaccurate information processed by SimpleServe on behalf of our users, please direct your query to the relevant user (who is the “Data Controller” of such data). If requested to remove any users-of-users’ personal information, we will respond to such request within thirty (30) days.
Unless otherwise instructed by our user, we will retain their users-of-users’ personal information for the period set forth in section 10 – Data retention below.
6. Disclosure of your personal data
We may have to share your personal data with the parties set out below and for the purposes set out throughout this policy:
- External third parties as set out in section 7 – Your data and third parties;
- Internally within our family of companies, for the purposes described in this policy. For example, we may share your personal information with SimpleStack Web Hosting or our client support portal if you have web-hosting or require support from us, in the course of facilitating and providing you (and your users-of-users) with our services;
Note: we insist that the parties noted above respect the security of your personal data and treat it in accordance with the data protection laws in force, the same ways we do. We do not allow these parties to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our explicit instructions.
7. Your data & third parties
We may have to share your data with selected third parties, including third-party service providers and other entities outside of our group of businesses. However, we demand that these third parties respect the security of your data and treat it in accordance with the law, whether that be your data held in the U.K or transfers of your personal information outside the EU. If we do share your data, you can expect a similar degree of protection in respect of your personal information, as you’d get from us.
We operate on a strict ‘need to know’ policy for all data that we work with, and that is particularly true for any personal data we collect, or that may be shared with selected third-parties / organisations. Therefore the only third parties that are granted access to your personal data are:
- Employees of SimpleServeWeb Design who provide design and/or support services.
- Our web hosting technology suppliers (SimpleStack Web Hosting) who provide the physical server infrastructures that our website(s) operate on. We ensure that all servers in use reside physically either in the UK or EU, and that no customer data is transferred to data centres outside the EU.
- Our cloud storage and technology supplier (SimpleStack Cloud Hosting) whose services we use for shared hosting, secure backup storage and email relay services. We may also utilise AWS data centres within the EU (Ireland) for such purposes.
- Analytics and other such anonymous information providers, such as Google Analytics, which allows us to monitor your visit anonymously, and to allow us to enhance your user experience on any future visits to our website(s).
- Law enforcement & legal requests, where permitted by local data protection laws, SimpleServe may disclose or otherwise allow others access to your personal information pursuant to a legal request, such as a subpoena, legal proceedings, search warrant or court order, or in compliance with applicable laws, if we have good faith and belief that the law requires us to do so, with or without notice to you.
Protecting our rights and your safety means we may share your personal information with others if we believe in good faith that in doing so will help protect the rights, property or personal safety of SimpleServe, our employees, our customers, our website users, any users-of-users, or any member of the general public, with or without notice to you.
Our Services include certain Social Media features and widgets, single sign on features, such as the ‘Facebook Connect’ or ‘Google Sign-in’, the ‘Facebook Like’ button, the ‘Share this’ button or other interactive mini-programs (“Social Media Features”).These Social Media Features may collect personal and anonymous information such as your IP address or which page you are visiting on our website, and may set a cookie to enable them to function properly. Social media features are either hosted by a third party or hosted directly on our services. Your interaction with these third parties’ social media features are governed by their own policies and not ours.
We are not responsible for the privacy policies or practices of third party websites but we check these practices when choosing the third party providers that we work with in order to ensure that they are compliant with the GDPR and that they take the security of your personal data as seriously as we do.
Note: we do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for limited and specified purposes, and in accordance with our instructions. We have a signed Data Privacy Agreement with all of the 3rd party technology suppliers used by us, which details our respective responsibilities for data security.
8. International transfers
Your information, including personal data, may be transferred to, or maintained on computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction. For instance, if you are located outside the United Kingdom and choose to provide information to us, we will transfer the data, including your personal data, to the United Kingdom and process it there as this is where our physical servers are situated.
Your consent to this policy followed by your submission of such information represents your agreement to that transfer.
SimpleServe has implemented security measures designed to protect the personal information you share with us, including physical, electronic and procedural measures. Amongst other things, we offer HTTPS secure access to most areas across our range of services; the transmission of sensitive payment information (such as a credit card number) through our designated purchase forms is protected by an industry standard SSL/TLS encrypted connection; and we regularly maintain a PCI DSS (Payment Card Industry Data Security Standards) certification. We also regularly monitor our systems for possible vulnerabilities and attacks, and regularly seek new ways and third-party services for further enhancing the security of our services and protection of our visitors and users privacy.
Regardless of the measures and efforts taken by SimpleServe, we cannot and do not guarantee the absolute protection and security of your personal information, your users-of-users information or any other user content you upload, publish or otherwise share with SimpleServe or anyone else.
We therefore encourage you to set strong passwords for your user account and your website, and avoid providing us or anyone with any sensitive information of which you believe its disclosure could cause you substantial or irreparable harm. Furthermore, because certain areas on our services are less secure than others (for example, if you browse to a non-SSL page), and since e-mail and instant messaging are not recognised as secure forms of communications, we request and encourage you not to share any personal information on any of these areas or via any of these methods.
In the unlikely event of a data breach
- Every precaution will be taken to avoid a breach of your data. However, if such a breach should occur, it will be documented, assessed as to its severity and appropriate action taken. The Information Commissioner’s Office (ICO) will be informed and you will be contacted to assist you in taking steps to mitigate the risks to yourself if the breach is deemed sufficiently severe to put you or your identity at risk.
If you have any questions regarding the security of our services, you are welcome to contact us via our Client Support Portal or by sending us an email to firstname.lastname@example.org.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
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.
By law we have to keep basic information about our customers (including contact, identity, financial and transaction data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete or correct your data. Similarly, we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes; in which case we may use this information indefinitely without further notice to you. See Request Erasure section below for further information.
Under certain circumstances, you have rights under the General Data Protection Regulations 2018 (GDPR) in relation to your personal data. You have the right to:
- Obtain details about how your data is processed by us;
- Obtain copies of personal data that we hold about you;
- Have incorrect or incomplete data corrected;
- Have your data erased where, for example, we have no legitimate reason for retaining the data;
- Obtain your data from us and to have that data transmitted to another organisation (data portability);
- Object to the processing of your data by us, in certain circumstances;
- Not to be subject to (with some exceptions) automated decision making, including profiling.
If you wish to exercise any of the rights set out above, please update your privacy options, alternatively you may contact us and have us perform any of the rights on your behalf.
Fee to access your personal information
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these 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 your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you by telephone to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. In line with current ICO guidance on extending personal information requests, we may need to extend our response by an additional 60 days.
12. Data controller & privacy settings
The data controller in respect of this website is SimpleServe Web Design Limited registered in England and Wales number: 10778148. Our registered office address is: 3 Chantry Court, Forge Street, Crewe, Cheshire, CW1 2DL. We are registered with the Information Commissioner and our registration number is: ZA255425.
You can contact the data controller by writing to: The Data Protection Manager, SimpleServe Web Design Limited, c/o KFH Accounts, 3 Chantry Court, Forge Street, Crewe, Cheshire, CW1 2DL or by sending an email to email@example.com.