Privacy and cookies policy
1. Introduction
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 such persons; in other words, where we determine the purposes and means of the processing of that personal data.
1.3 We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website, we will ask you to consent to our use of cookies when you first visit our website.
1.4 In this policy, “we”, “us” and “our” refer to Primary Live Ltd. For more information about us, see Section 17.
2. The personal data that we collect
2.1 In this Section 2 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 enabling us to get in touch with you “contact data“. The contact data may include your name, email address, telephone number. The source of the contact data is you and your employer. If you log into our website using a social media account, we will obtain elements of the contact data from the relevant social media account provider
2.3 We may process information contained in or relating to any communication that you send to us or that we send to you “communication data“. The communication data may include name, email address, company telephone number. Our website will generate the metadata associated with communications made using the website contact forms.
2.4 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 OR our legitimate interests, namely communications with our website visitors and service users
2.5 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 Google Analytics and Zoho Bigin.
2.6 Please do not supply any other person’s personal data to us, unless we prompt you to do so.
3. Purposes of processing and legal bases
3.1 In this Section 3, we have set out the purposes for which we may process personal data and the legal bases of the processing.
3.2 Operations – We may process your personal data for the purposes of operating our website, providing our services, supplying our goods, generating invoices, bills and other payment-related documentation, and credit control. The legal basis for this processing is our legitimate interests, namely the proper administration of our website, services and business.
3.3 Relationships and communications – We may process contact data, account data, customer relationship data, transaction data and communication data for the purposes of managing our relationships, communicating with you (excluding communicating for the purposes of direct marketing) by email, SMS, post, and telephone, providing support services and complaint handling. The legal basis for this processing is our legitimate interests, namely communications with our website visitors, service users, individual customers and customer personnel, the maintenance of our relationships, enabling the use of our services, and the proper administration of our website, services and business.
3.4 Direct marketing – We may process contact data, account data, profile data, customer relationship data for the purposes of creating, targeting and sending direct marketing communications by email, SMS, post and making contact by telephone for marketing-related purposes. The legal basis for this processing is consent OR our legitimate interests, namely promoting our business and communicating marketing messages and offers to our website visitors and service users.
3.5 Zoho Campaigns provide us with email marketing and CRM services, and we consider them as a third-party data processor. If you choose to sign up to our email newsletters the email address submitted will be stored within Zoho Campaigns.
Google provides us with analytics data and is also considered a third-party data processor.
Both of the aforementioned third-party data processors have been chosen very carefully and the Privacy Policies can be viewed here;
Zoho Campaigns https://www.zoho.com/en-uk/privacy.html.
Google https://policies.google.com/privacy?hl=en-GB&fg=1
3.6 Record keeping – We may process your personal data for the purposes of creating and maintaining our databases, back-up copies of our databases and our business records generally. The legal basis for this processing is our legitimate interests, namely ensuring that we have access to all the information we need to properly and efficiently run our business in accordance with this policy.
3.7 Insurance and risk management – We may process your personal data where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks and / or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
4. Providing your personal data to others
4.1 We may disclose your personal data to our insurers and professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice.
4.2 We may disclose name, email address and phone number and job title to our suppliers or subcontractors as required insofar as reasonably necessary for the our services to be delivered
4.3 In addition to the specific disclosures of personal data set out in this Section 5, 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 defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
5. International transfers of your personal data
5.1 We may transfer and process any personal information you provide to us to countries outside the European Economic Area whose laws may not afford the same level of protection to your personal information. We will therefore ensure that all adequate safeguards are in place and that all applicable laws and regulations are complied with in connection with such transfer.
6. Retaining and deleting personal data
6.1 This Section 6 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
6.2 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.
6.3 We will retain your personal data as follows:
(a) contact data will be retained for a minimum period of 6 years following the date of the most recent contact between you and us, and for a maximum period of 7 years following that date;
(b) account data will be retained for a minimum period of 6 years following the date of closure of the relevant account, and for a maximum period of 7 years following that date;
(d) customer relationship data will be retained for a minimum period of 6 years following the date of termination of the relevant customer relationship and for a maximum period of 7 years following that date;
(g) communication data will be retained for a minimum period of 6 years following the date of the communication in question, and for a maximum period of 7 years following that date;
(h) usage data will be retained for 6 years following the date of collection; and for a maximum period of 7 years following that date;
6.4 In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on that specific data.
6.5 Notwithstanding the other provisions of this Section 6, 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.
7. Security of personal data
7.1 We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.
8. Your rights
8.1 In this Section 8, we have listed the rights that you have under data protection law.
8.2 Your principal rights under data protection law are:
(a) the right to access – you can ask for copies of your personal data;
(b) the right to rectification – you can ask us to rectify inaccurate personal data and to complete incomplete personal data;
(c) the right to erasure – you can ask us to erase your personal data;
(d) the right to restrict processing – you can ask us to restrict the processing of your personal data;
(e) the right to object to processing – you can object to the processing of your personal data;
(f) the right to data portability – you can ask that we transfer your personal data to another organisation or to you;
(g) the right to complain to a supervisory authority – you can complain about our processing of your personal data; and
(h) the right to withdraw consent – to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.
8.3 These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by visiting [https://edpb.europa.eu/our-work-tools/general-guidance/gdpr-guidelines-recommendations-best-practices_en and https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.
8.4 You may exercise any of your rights in relation to your personal data by written notice to us, using the contact details set out below.
9. Third party websites
9.1 Our website includes hyperlinks to, and details of, third party websites.
9.2 In general we have no control over, and are not responsible for, the privacy policies and practices of third parties.
10. Personal data of children
10.1 Our [website and services are] targeted at persons over the age of 18
10.2 If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.
11. About cookies
11.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
11.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
11.3 Cookies may not contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.
12. Cookies that we use
12.1 We use cookies for the following purposes:
(a) authentication and status – we use cookies to identify you when you visit our website and as you navigate our website, and to help us determine if you are logged into our website.
(d) security – we use cookies [as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally.
(f) analysis – we use cookies to help us to analyse the use and performance of our website and services
(g) cookie consent – we use cookies to store your preferences in relation to the use of cookies more generally.
13. Cookies used by our service providers
13.1 Our service providers use cookies and those cookies may be stored on your computer when you visit our website.
13.2 We use Google Analytics, which gathers information about the use of our website and uses cookies for this purpose. We use the information gathered by Google Analytics to create reports about the use of our website. You can find out more about Google’s use of information by visiting https://policies.google.com/technologies/partner-sites and you can review Google’s privacy policy at https://policies.google.com/privacy. The cookies used by Google Analytics are named _ga and _ga+container-id.
14. Managing cookies
14.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser and from version to version. You can obtain up-to-date information about managing cookies via these links:
(a) https://support.google.com/chrome/answer/95647 (Chrome);
(b) https://support.mozilla.org/en-US/products/firefox/privacy-and-security (Firefox);
(c) https://help.opera.com/en/latest/security-and-privacy/ (Opera);
(d) https://support.apple.com/en-gb/guide/safari/welcome/mac (Safari); and
14.2 Blocking all cookies will have a negative impact upon the usability of many websites.
14.3 If you block cookies, you will not be able to use all the features on our website.
15. Cookie preferences
15.1 You can manage your preferences relating to the use of cookies on our website by visiting: www.primarylive.co.uk
16. Amendments
16.1 We may update this policy from time to time by publishing a new version on our website.
16.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
17. Our details
17.1 This website is owned and operated by Primary Live Ltd.
17.2 We are registered in England and Wales under registration number 7011278, and our registered office is at 2a Angel Court, High Street, Market Harborough, LE16 7NL
17.3 Our principal place of business is at the above address
17.4 You can contact us:
(a)by post, to the postal address given above;
(b)using our website contact form;
(c)by telephone, on the contact number published on our website; or
(d)by email, using the email address published on our website.
18. Data protection registration
18.1 We are registered as a data controller with the UK Information Commissioner’s Office
18.2 Our data protection registration number is ZA271610.