Privacy Policy - Collective Digital

Privacy Policy

This Privacy Policy sets out how we, Collective Creative Ltd. collect, store and use information about you when you use or interact with our website, www.collectivecreative.com (our website) and where we otherwise obtain or collect information about you. This Privacy Policy is effective from 23 may 2018¹.

Contents²

Summary
Our details
Information we collect when you visit our website
Information we collect when you contact us
[Information we collect when you interact with our website]³
[Information we collect when you place an order [on our website]]⁴
[Our use of automated decision-making and profiling]⁵
How we collect or obtain information about you from third parties
Disclosure and additional uses of your information
How long we retain your information
How we secure your information
Transfers of your information outside the European Economic Area
Your rights in relation to your information
Your right to object to the processing of your information for certain purposes
Sensitive Personal Information
Changes to our Privacy Policy
Children’s Privacy
California Do Not Track Disclosures
Copyright, credit and logo

Summary⁶

This section summarises how we obtain, store and use information about you. It is intended to provide a very general overview only. It is not complete in and of itself and it must be read in conjunction with the corresponding full sections of this Privacy Policy.

Data controller: Mark Palmer⁷

How we collect or obtain information about you:
- when you provide it to us (e.g. by contacting us,
- from your use of our website, using cookies, and
- occasionally,⁸ from third parties.

Information we collect: name, contact details, information from cookies, information about your computer or device (e.g. device and browser type), [information about how you use our website (e.g. which pages you have viewed, the geographical location from which you accessed our website (based on your IP address).
How we use your information: for administrative and business purposes (particularly to contact you to improve our business and website, to advertise our goods and services, to analyse your use of our website, in connection with our legal rights and obligations.

Disclosure of your information to third parties: only to the extent necessary to run our business.

Do we sell your information to third parties (other than in the course of a business sale or purchase or similar event): No

How long we retain your information: for no longer than necessary, taking into account any legal obligations we have (e.g. to maintain records for tax purposes), any other legal basis we have for using your information (e.g. your consent, performance of a contract with you or our legitimate interests as a business) How long we retain your information]. For specific retention periods in relation to certain information which we collect from you, please see the main section below entitled How long we retain your information.

How we secure your information: using appropriate technical and organisational measures such as storing your information on secure servers,⁹ encrypting transfers of data to or from our servers using Secure Sockets Layer (SSL) technology, only granting access to your information.

Use of cookies: we use cookies [and similar information-gathering technologies such as google analytics on our website. For more information, please visit our cookies policy here: [insert link to cookies policy]]¹⁰

Transfers of your information outside the European Economic Area: we will only transfer your information outside the European Economic Area if we are required to do so by law. Where we do so, we will ensure appropriate safeguards are in place.

Use of automated decision making and profiling: we do use automated decision making profiling. ie. web analytics, cookies, web beacons or server logs analysis tools (profiling) or use targeting cookies to display advertisements to your people who visit your website on other websites around the internet (e.g. using the Google AdSense network) (automated decision making)].

Your rights in relation to your information
- to access your information and to receive information about its use
- to have your information corrected and/or completed
- to have your information deleted
- to restrict the use of your information
- to receive your information in a portable format
- to object to the use of your information
- to withdraw your consent to the use of your information
- to complain to a supervisory authority

Sensitive personal information: we do not knowingly or intentionally collect what is commonly referred to as ‘sensitive personal information’. Please do not submit sensitive personal information about you to us. For more information, please see the main section below entitled Sensitive Personal Information.¹¹

Our details

The data controller in respect of our website is Collective Creative Ltd Registered Company in England 3413169 of 47 High Street, Hampton Wick, Kingston, Surrey KT1 4DG. You can contact the data controller by writing to Mark Palmer at the registered address or sending an email to welcome@collectivecreative.com.

If you have any questions about this Privacy Policy, please contact the data controller.

Information we collect when you visit our website

We collect and use information from website visitors in accordance with this section and the section entitled Disclosure and additional uses of your information.

Web server log information

We use a third party¹² server to host our website [called heart internet, the privacy policy of which is available on their website. [Our website server automatically logs the IP address you use to access our website as well as other information about your visit such as [the pages accessed,] [information requested,] [the date and time of the request,] [the source of your access to our website (e.g. the website or URL (link) which referred you to our website),] [and] [your browser version and operating system] [and] [insert any additional information your website’s server about an individual’s visit to your website.]¹³

Our server is located in the UK. For further information and information on the safeguards used, please see the section of this privacy policy entitled Transfers of your information outside the European Economic Area]].¹⁴

Use of website server log information for IT security purposes

[[We do not access log data from our website server] OR [[We] AND/OR [our third party hosting provider]]] collect(s) and store(s) server logs to ensure network and IT security and so that the server and website remain uncompromised. This includes analysing log files to help identify and prevent unauthorised access to our network, the distribution of malicious code, denial of services attacks and other cyber attacks, by detecting unusual or suspicious activity.

Unless we are investigating suspicious or potential criminal activity, we do not make, nor do we allow our hosting provider to make, any attempt to identify you from the information collected via server logs.¹⁵

Legal basis for processing: compliance with a legal obligation to which we are subject (Article 6(1)(c) of the General Data Protection Regulation).
Legal obligation: we have a legal obligation to implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk of our processing of information about individuals. Recording access to our website using server log files is such a measure.

Legal basis for processing: our and legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interests: we have a legitimate interest in using your information for the purposes of ensuring network and information security.

[Use of website server log information to analyse website use and improve our website

[We use the information collected by our website server logs to analyse how our website users interact with our website and its features. For example, we analyse the number of visits and unique visitors we receive, the time and date of the visit, the location of the visit [and] [the operating system and browser used.

We use the information gathered from the analysis of this information to improve our website. For example, we use the information gathered to change the information, content and structure of our website and individual pages based according to what users are engaging most with and the duration of time spent on particular pages on our website.]

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: improving our website for our website users and getting to know our website users’ preferences so our website can better meet their needs and desires.]¹⁶

[Cookies and [similar technologies]]

[Cookies are data files which are sent from a website to a browser to record information about users for various purposes.

We use cookies [and similar technologies] on our website, including analytical and targeting cookies . For further information on how we use cookies, please see our cookies policy which is available at our cookies policy link.¹⁷

You can reject some or all of the cookies we use on or via our website by changing your browser settings non-essential cookies by using our cookie control tool,¹⁸ but doing so can impair your ability to use our website or some or all of its features. For further information about cookies, including how to change your browser settings, please visit www.allaboutcookies.org or see our cookies policy.

Information we collect when you contact us

We collect and use information from individuals who contact us in accordance with this section and the section entitled Disclosure and additional uses of your information.

Email

When you send an email to the email address displayed on our website we collect your email address and any other information you provide in that email (such as your name, telephone number and the information contained in any signature block in your email).

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).

Transfer and storage of your information

We use a third party email provider to store emails you send us. Our third party email provider is Internetters. Their privacy policy is available on their website.¹⁹

Emails you send us will be stored within OR outside the European Economic Area on our Internetters servers in Scotland where your third party email provider stores your emails (usually where its servers are located)]²⁰. For further information please see the section of this privacy policy entitled Transfers of your information outside the European Economic Area.]²¹

Contact form

When you contact us using our contact form, we collect name, email address. We also collect any other information you provide to us when you complete the contact form, including any optional information, such as: any optional information you collect via your website form e.g. phone number or company name.²²

If you do not provide the mandatory information required by our contact form, you will not be able to submit the contact form and we will not receive your enquiry.

[If you do not supply the optional information required by our contact form, insert consequences of an individual not providing the optional information requested by your contact form (such as phone number) e.g. we will not be able to respond to your enquiry by phone.²³

Transfer and storage of your information

[Messages you send us via our contact form will be stored [within OR outside] the European Economic Area on our Heart Internet hosting OR Internetters servers in UK where your third party provider stores your emails . Our third party email provider is Internetters and hosting provider is Heart Internet OR located in UK. [Their privacy policy is available on their website²⁴

For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.²⁵

We use a third party contact form provider to store messages you send us. Our contact form provider is Apple Mail Their privacy policy is available on their website. Messages you send to us via our contact form will be stored [within OR outside] the European Economic Area on our contact form provider’s servers in the UK where your third party provider stores your emails (usually where its servers are located)]]²⁶

[For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.]²⁷

Phone²⁸

When you contact us by phone, we collect your phone number and any information provide to us during your conversation with us.

We do not record phone calls.²⁹

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation)
Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.

Transfer and storage of your information

Information about your call, such as your phone number and the date and time of your call, is processed by our third party telephone service voipfone. Their privacy policy is available on their website.³⁰

[Information about your phone call will be stored by our third party telephone service provider [within OR outside] the European Economic Area. [For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.]³¹

Post

If you contact us by post, we will collect any information you provide to us in any postal communications you send us.

Information we collect when you interact with our website

We collect and use information from individuals who interact with particular features of our website in accordance with this section and the section entitled Disclosure and additional uses of your information.

Legal basis for processing: your consent (Article 6(1)(a) of the General Data Protection Regulation).
Consent: you give your consent to us sending you our e-newsletter by signing up to receive it using the steps described above.

If you do not provide the mandatory information required by the registration form, you will not be able to register or create an account on our website.

Information collected or obtained from third parties

This section sets out how we obtain or collect information about you from third parties.

Information received from third parties

We do not receive information about you from third parties.

It is also possible that third parties with whom we have had no prior contact may provide us with information about you.

Information we obtain from third parties will generally be your name and contact details, but will include any additional information about you which they provide to us.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: where a third party has passed on information about you to us (such as your name and email address) in order for us to provide services to you, we will process your information in order to take steps at your request to enter into a contract with you and perform a contract with you (as the case may be).

Legal basis for processing: consent (Article 6(1)(a) of the General Data Protection Regulation).
Consent: where you have asked that a third party to share information about you with us and the purpose of sharing that information is not related to the performance of a contract or services by us to you, we will process your information on the basis of your consent, which you give by asking the third party in question to pass on your information to us.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interests: where a third party has shared information about you with us and you have not consented to the sharing of that information, we will have a legitimate interest in processing that information in certain circumstances.

For example, we would have a legitimate interest in processing your information to perform our obligations under a sub-contract with the third party, where the third party has the main contract with you. Our legitimate interest is the performance of our obligations under our sub-contract.

Similarly, third parties may pass on information about you to us if you have infringed or potentially infringed any of our legal rights. In this case, we will have a legitimate interest in processing that information to investigate and pursue any such potential infringement.

Where we receive information about you in error

If we receive information about you from a third party in error and/or we do not have a legal basis for processing that information, we will delete your information.

Information obtained by us from third parties

In certain circumstances (for example, to verify the information we hold about you or obtain missing information we require to provide you with a service) we will obtain information about you from certain publicly accessible sources, both EU and non-EU, such as [[the electoral register,] [Companies House,] [online customer databases,] [business directories], [media publications,] [social media,] [and] websites (including your own website if you have one) [and] [insert any additional public sources from which you collect or expect that you collect information about an individual]].³²

In certain circumstances will also obtain information about you from private sources, both EU and non-EU, such as [insert any private sources from which you collect or expect that you collect information about an individual e.g. data brokers]

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: where you have entered into a contract or requested that we enter into a contract with you, in certain circumstances, we will obtain information about you from public sources in order to enable us to understand your business and provide services to you or services to a sufficient standard.

For example, we would obtain and/or verify your email address from your website or from a directory where you ask us to send you information by email but we do not possess the information or we need to confirm that we have recorded your email address correctly.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interests: in certain circumstances, we will have a legitimate interest in obtaining information about you from public and private sources. For example, if you have infringed or we suspect that you have infringed any of our legal rights, we will have a legitimate interest in obtaining and processing information about you from such sources in order to investigate and pursue any suspected or potential infringement.

[Legal basis for processing: consent (Article 6(1)(a) of the General Data Protection Regulation).
Consent: we may obtain information from third parties, such as data brokers, where you have consented to them sharing information with us by [insert method by which individual consent e.g. ticking a box stating that you would like your information to be share with us.]]³³

[Our use of automated decision-making and profiling³⁴

We use google analytics on our website. We do not consider that this has any legal effect on you or similarly significantly affects you.³⁵

You have the right to object to our use of automated decision making and profiling described in this section. You can do that by opting-out of cookies and similar technologies in accordance with the method described in the relevant section below. If you do not want us to process your actual IP address (usually the IP address assigned to you by your Internet Service Provider) when you visit our website, you can use a Virtual Private Network (VPN) or a free service such as Tor.

You can find out more about our use of cookies and similar technologies (including the legal basis on which we use them) and how to opt out from them in our cookies policy, which is available on our website.

Automated decision making³⁶

Automated decision making is decision making by technological means (i.e. by a machine) without human involvement.

[Use of automated decision making for [display] advertising]³⁷

[We automate the display advertisements containing our products and services on other websites you visit, you based on the fact that you have visited our website using cookies. For further information on the cookies we use, please see our cookies policy which is available here: [insert link to cookies policy]

Logic involved: automatically displaying advertisements to individuals who have visited our website results in increased efficiencies and costs savings for us than manually displaying advertisements or displaying advertisements by different means.

Significance and envisaged consequences: cookies will be used to recognise the fact that you have visited our website in order to display advertisements to you (unless you have blocked such cookies) and will collect information about your online behaviour.

How to object: you can block these cookies by [using the cookies control management tool on your site (if you use one)]³⁸ [insert method of blocking cookies e.g. blocking third party cookies using browser settings, or insert specific method e.g. for Google DoubleClick, by opting out of seeing personalised ads by following the instructions here: https://support.google.com/ads/answer/2662922?hl=en-GB]. For further information, please see our cookies policy: [insert link to your cookies policy]

[Insert use of automated decision making]³⁹

[[We use automated decision making for [insert purposes for which you use automated decision making] OR [we do not use automated decision making].]

Logic involved: [insert the logic involved in you used automated decision making e.g. to increase efficiencies]

Significance and envisaged consequences: [insert the significance and envisaged consequences for the individual of your use of automated decision making]

How to object: [insert description of how individual may object i.e. stop the processing of their personal information for automated decision making purposes]

[Legal basis for processing: [insert legal basis for processing e.g. your legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).]]

[Legitimate interest: [describe your legitimate interest in the automated decision making activity (if you are relying on your legitimate interests as your legal basis for processing]]

Profiling

Profiling is any form of automated processing of your information to evaluate personal aspects about you, in particular to analyse or predict things like your performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.

[Use of profiling for web analytics

[Our web analytics service, [insert name of web analytics service e.g. Google Analytics] uses collects information such as your location (based on your IP address) and your behaviour (based on cookies) when you access our website (such as the pages you visit and what you click on) [and] [insert any other behaviours which are analysed when a user visits your website] We will only process information from cookies if you have consented to us setting cookies on your computer in accordance with our cookies policy ([insert link to cookies policy]). [Information collected about you, once collected is anonymised and stored on an aggregate basis.]⁴⁰

Logic involved: by automatically analysing and categorising information such as the location (based on IP address) as well as the behaviour and devices of visitors to our website (using cookies), we are able to gain a better understanding of what our website visitors want (in terms of the content of our website and our products), how to improve our website and how to advertise and market our services to them.

Significance and envisaged consequences: cookies will be used to track and store information about your behaviour and device on our website (unless you have opted out from receiving such cookies by [insert method of opting out from analytical cookies used on your website]) and your location will be analysed based on your IP address. [We may target advertisements based on the level of interest we receive from certain visitors and their behaviour on our website.]]

[Legal basis for processing: [insert legal basis for processing e.g. your legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).]]

[Legitimate interest: [describe your legitimate interest in the relevant profiling activity (if you are relying on your legitimate interests as your legal basis for processing]]

[Use of profiling in marketing emails]

[We use [[web beacons] AND/OR [insert other technologies]] in our marketing emails to analyse who opens our emails [and what actions they take (for example, what they click on)]. We will only process information from [[web beacons] AND/OR [insert other technologies you use]] if you have consented to their use in accordance with our cookies policy ([insert link to cookies policy]).

Logic involved: by analysing how our email recipients respond to our emails, we are able to improve the content and effectiveness of our emails and gauge who is most interested.

Significance and envisaged consequences: your behaviour when you open our emails will be tracked using [small gif files (web beacons)] [and] [insert any other technologies used]], including [open rates], [click through rates], [and] [insert any other information you measure about individuals in your marketing emails].

How to object: [insert method of allowing an individual to object to your use of web beacons and similar technologies e.g. contact you]⁴¹

Legal basis for processing: legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest: [analysing the level of engagement and effectiveness of our marketing emails and content]

[Insert use of profiling]⁴²

[[We use profiling for: [insert purposes for which you use profiling]]

Logic involved: [insert the logic involved in your use of profiling e.g. to increase efficiencies]

Significance and envisaged consequences: [insert the significance and envisaged consequences for the individual of your use of profiling]

How to object: [insert description of how individual may object i.e. stop the processing of their personal information for profiling purposes]

[Legal basis for processing: [insert legal basis for processing e.g. your legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).]]

[Legitimate interest: [describe your legitimate interest in the relevant profiling activity (if you are relying on your legitimate interests as your legal basis for processing]]

Disclosure and additional uses of your information

This section sets out the circumstances in which will disclose information about you to third parties and any additional purposes for which we use your information.

Disclosure of your information to service providers

We use a number of third parties to provide us with services which are necessary to run our business or to assist us with running our business [and who process your information for us on our behalf].⁴³ These include the following:⁴⁴

Telephone provider(s), including [insert name(s) of telephone provider(s) which your business uses]. Their privacy policy is available here: [insert link to privacy policy]
Email provider(s), including [insert name(s) of email provider(s) which your business uses]. Their privacy policy is available here: [insert link to privacy policy]
IT service provider(s), including [insert name(s) of IT provider(s) which your business uses]. Their privacy policy is available here: [insert link to privacy policy]
Web developer(s), including [insert name(s) of web developer(s) which your business uses]. Their privacy policy is available here: [insert link to privacy policy]
Hosting provider(s), including [insert name(s) of hosting provider(s) which your business uses]. Their privacy policy is available here: [insert link to privacy policy]
[insert any additional third party service providers which provide you with services which are commonly provided to any business and links to their privacy policies]

[Our third party service providers are located in [insert country in which your third party service providers are located e.g. England]] OR [Apart from [insert types of service providers], which are located in [insert locations of service providers e.g. the US], our service providers are located in [insert location of service providers e.g. England].⁴⁵

Your information will be shared with these service providers where necessary to provide you with the service you have requested, whether that is accessing our website or ordering goods and services from us.

[We do not display the identities of [all of] our service providers publicly by name for security and competitive reasons. If you would like further information about the identities of our service providers, however, please contact us directly [via our contact form] or [by email] and we will provide you with such information where you have a legitimate reason for requesting it (where we have shared your information with such service providers, for example).]⁴⁶

Legal basis for processing: legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest relied on: where we share your information with these third parties in a context other than where is necessary to perform a contract (or take steps at your request to do so), we will share your information with such third parties in order to allow us to run and manage our business efficiently.

Legal basis for processing: necessary to perform a contract and/or to take steps at your request prior to entering into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: we may need to share information with our service providers to enable us to perform our obligations under that contract or to take the steps you have requested before we enter into a contract with you.

Disclosure of your information to other third parties

We disclose your information to other third parties in specific circumstances, as set out below.

Providing information to third parties such as [Google Inc.] [, [and] insert any other third parties to whom information is provided]. [Google collects information through our use of Google Analytics on our website. Google uses this information, including IP addresses and information from cookies, for a number of purposes, such as improving its Google Analytics service. Information is shared with Google on an aggregated and anonymised basis. To find out more about what information Google collects, how it uses this information and how to control the information sent to Google, please see the following page: https://www.google.com/policies/privacy/partners/]⁴⁷

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s): meeting our contractual obligations to Google under our Google Analytics Terms of Service (https://www.google.com/analytics/terms/us.html)

You can opt out of Google Analytics by installing the browser plugin here: https://tools.google.com/dlpage/gaoptout

Transfer and storage of your information

Information collected by Google Analytics is stored outside the European Economic Area on Google’s servers in the United States of America.

Sharing your information with third parties, which are either related to or associated with the running of our business, where it is necessary for us to do so. These third parties include our [accountants,] [advisors,] [affiliates,] [business partners,] [independent contractors,] [and] [insurers,] [and] [insert any additional specific categories of individuals or entities with whom or which you share an individual’s personal data for managing your business]. Further information on each of these third parties is set out below.⁴⁸

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: running and managing our business efficiently.

[Accountants

We share information with our accountants for tax purposes. For example, we share invoices we issue and receive with our accountants for the purpose of completing tax returns and our end of year accounts.]

[Our accountants are [insert name of accountants]. Their privacy policy is available here: [insert link to privacy policy]] OR [Our accountants are located in [insert location of your accountants e.g. England].]

[Advisors

Occasionally, we obtain advice from advisors, such as [accountants,] [financial advisors,] [lawyers] [and] [public relations professionals] [and] [insert any additional advisors you may share an individual’s information with]. We will share your information with these third parties only where it is necessary to enable these third parties to be able to provide us with the relevant advice.]

[[Our advisors are [insert names of advisors]]. Their privacy policy is available here: [insert link to privacy policy] OR [Our advisors are located in [insert location of your advisors e.g. England].]]

[Affiliates

Affiliates are individuals or entities we work with to promote our business by various means, including by advertising our services on their websites, for example. Our affiliates can be in [insert the types of business or individual your affiliates are by industry, sector and sub-sector]. Affiliates will share information with us and we will share information with them where you have expressed an interest in our products or services.]

[[Our affiliates are [[insert names of affiliates] OR [industry, sector and sub-sector your affiliates are based in]. Their privacy policy is available here: [insert link to privacy policy]] OR [[Our affiliates are located in [insert location of your advisors e.g. England].]]

[Business partners

Business partners are businesses we work with which provide goods and services which are complementary to our own or which allow us to provide goods or services which we could not provide on our own. We share information with our business partners where you have requested services which they provide whether independently from, or in connection with or own services.]

[Our business partners are [[insert names of business partners] OR [industry, sector and sub-sector your business partners are based in]]. Their privacy policy is available here: [insert link to privacy policy]] OR [Our business partners are located in [insert location of your advisors e.g. England].]

[Independent contractors

[Occasionally,] we use independent contractors in our business. Your information will be shared with independent contractors only where it is necessary for them to perform the function we have hired them perform in relation to our business.]

[[Our independent contractors are [[insert names of independent contractors] OR [industry, sector and sub-sector your independent contractors are in]]. Their privacy policy is available here: [insert link to privacy policy]] OR [Our independent contractors are located in [insert location of your advisors e.g. England].]]

[Insurers

We will share your information with our insurers where it is necessary to do so, for example in relation to a claim or potential claim we receive or make or under our general disclosure obligations under our insurance contract with them.]

[[Our insurers are [insert name of insurers]]. Their privacy policy is available here: [insert link to privacy policy] OR [Our insurers are located in [insert location of your advisors e.g. England].]]

[Insert type of third party recipient of information]

[insert description of circumstances in which you will share an individual’s information with that third party recipient]

[[Our [insert name of third party recipient(s) is/are [insert name(s) of third party/third parties]]. OR [Our [insert name of third party recipient] is located in [insert location of third party recipient e.g. England].]]

[Sharing your information within our business’ group of companies, including [insert details of other entities in your corporate group with whom you share personal information] for internal administrative purposes, including client, customer and employee information.⁴⁹

[Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: running and managing our business effectively.

AND/OR

Legal basis for processing: necessary to perform a contract [or to take steps at your request prior to entering into a contract] (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: we need to share your information with other companies in order to be able to meet our contractual obligations to you [or to take steps at your request prior to entering a contract.], for example because of the services or information you have requested.

[We do not display the identities of [all of] the other third parties we may share information with by name for security and competitive reasons. If you would like further information about the identities of such third parties, however, please contact us directly [via our contact form] or [by email] and we will provide you with such information where you have a legitimate reason for requesting it (where we have shared your information with such third parties, for example).]⁵⁰

Sharing your information with a prospective or actual purchaser or seller in the context of a business or asset sale or acquisition by us, a merger or similar business combination event, whether actual or potential.

Legal basis for processing: legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s): sharing your information with a prospective purchaser, seller or similar person in order to allow such a transaction to take place.

Disclosure and use of your information for legal reasons

Indicating possible criminal acts or threats to public security to a competent authority

If we suspect that criminal or potential criminal conduct has been occurred, we will in certain circumstances need to contact an appropriate authority, such as the police. This could be the case, for instance, if we suspect that we fraud or a cyber crime has been committed or if we receive threats or malicious communications towards us or third parties.

We will generally only need to process your information for this purpose if you were involved or affected by such an incident in some way.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interests: preventing crime or suspected criminal activity (such as fraud).

In connection with the enforcement or potential enforcement our legal rights

We will use your information in connection with the enforcement or potential enforcement of our legal rights, including, for example, sharing information with debt collection agencies if you do not pay amounts owed to us when you are contractually obliged to do so. Our legal rights may be contractual (where we have entered into a contract with you) or non-contractual (such as legal rights that we have under copyright law or tort law).

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: enforcing our legal rights and taking steps to enforce our legal rights.

In connection with a legal or potential legal dispute or proceedings

We may need to use your information if we are involved in a dispute with you or a third party for example, either to resolve the dispute or as part of any mediation, arbitration or court resolution or similar process.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s): resolving disputes and potential disputes.

For ongoing compliance with laws, regulations and other legal requirements

We will use and process your information in order to comply with legal obligations to which we are subject. For example, we may need to disclose your information pursuant to a court order or subpoena if we receive one [or to the National Crime Agency in connection with suspected or potential money laundering matters]⁵¹.

Legal basis for processing: compliance with a legal obligation (Article 6(1)(c) of the General Data Protection Regulation).
Legal obligation(s): legal obligations to disclose information which are part of the laws of [England and Wales]⁵² or if they have been integrated into the United Kingdom’s legal framework (for example in the form of an international agreement which the United Kingdom has signed).

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: where the legal obligations are part of the laws of another country and have not been integrated into the United Kingdom’s legal framework, we have a legitimate interest in complying with these obligations.

How long we retain your information

This section sets out how long we retain your information. We have set out specific retention periods where possible. Where that has not been possible, we have set out the criteria we use to determine the retention period.

Retention periods⁵³

[Server log information: we retain information on our server logs for [insert period for which you retain information from server logs.]

[Order information: when you place an order for goods and services, we retain that information for six years following the end of the financial year in which you placed your order, in accordance with our legal obligation to keep records for tax purposes.]⁵⁴

Correspondence and enquiries: when you make an enquiry or correspond with us for any reason, whether [[by email] [or via our contact form] [or by phone]], we will retain your information for as long as it takes to respond to and resolve your enquiry, and for [[●] further month(s)],⁵⁵ after which point we will delete your information.

[E-Newsletter: we retain the information you used to sign up for our e-newsletter for as long as you remain subscribed (i.e. you do not unsubscribe) or if we decide to cancel our e-newsletter service, whichever comes earlier.]

[insert additional category of data stored]: [insert details of the specific retention period for additional category of data]⁵⁶

Criteria for determining retention periods

In any other circumstances, we will retain your information for no longer than necessary, taking into account the following:

[the purpose(s) and use of your information both now and in the future (such as whether it is necessary to continue to store that information in order to continue to perform our obligations under a contract with you or to contact you in the future);
whether we have any legal obligation to continue to process your information (such as any record-keeping obligations imposed by relevant law or regulation);
whether we have any legal basis to continue to process your information (such as your consent);
how valuable your information is (both now and in the future);
any relevant agreed industry practices on how long information should be retained;
the levels of risk, cost and liability involved with us continuing to hold the information;
how hard it is to ensure that the information can be kept up to date and accurate; and
any relevant surrounding circumstances (such as the nature and status of our relationship with you).]⁵⁷

How we secure your information⁵⁸

We take appropriate technical and organisational measures to secure your information and to protect it against unauthorised or unlawful use and accidental loss or destruction, including:

only sharing and providing access to your information to the minimum extent necessary, subject to confidentiality restrictions where appropriate, and on an anonymised basis wherever possible;
[using secure servers to store your information];⁵⁹
verifying the identity of any individual who requests access to information prior to granting them access to information;
[using Secure Sockets Layer (SSL) software to encrypt [any information you submit to us via any forms on our website] [and] [any payment transactions you make on or via our website];]⁶⁰
[only transferring your information via closed system or encrypted data transfers;] [and]
[insert any additional methods you use to ensure the security of personal information e.g. other technological measures or pseudonymisation.]

Transmission of information to us by email

Transmission of information over the internet is not entirely secure, and if you submit any information to us over the internet (whether by email, via our website or any other means), you do so entirely at your own risk.

We cannot be responsible for any costs, expenses, loss of profits, harm to reputation, damages, liabilities or any other form of loss or damage suffered by you as a result of your decision to transmit information to us by such means.⁶¹

Transfers of your information outside the European Economic Area⁶²

[All of your information is stored in the following European Economic Area (EEA) countries [country/countries]: [insert EEA countries in which you store individuals’ information].

Other than to comply with any legal obligations to which we are subject (compliance with a court order, for example), we do not intend to transfer your information outside the EEA or to an international organisation. In the unlikely event that we are required to transfer your information outside the EEA (or to an international organisation) for such a purpose, we will ensure appropriate safeguards and protections are in place.

[Your information will be transferred and stored outside the European Economic Area (EEA) in the circumstances set out below. We will also transfer your information outside the EEA or to an international organisation in order to comply with legal obligations to which we are subject (compliance with a court order, for example). Where we are required to do so, we will ensure appropriate safeguards and protections are in place.]⁶³

[Server log information

[Information collected when you visit our website is transferred outside of the EEA and stored on the servers of our [third party hosting company[, insert name of third party hosting company]. You can access their privacy policy here: [insert link to privacy policy].]

[Country of storage: [insert the country or countries where the relevant servers which collect information in relation to your website are located and where the information is stored]. This country [is/is not] subject to an adequacy decision by the European Commission.]⁶⁴

Safeguard(s) used: [our third party hosting provider has self-certified its compliance with the EU-U.S. Privacy Shield] OR [insert other safeguard which your third party hosting company uses to transfer information to a country which is outside the EEA (see Appendix 1 for the full list)] [which is available [here: [insert link to the safeguards used] OR [insert means of obtaining a copy of the safeguard]].⁶⁵

[Contact form

[Information you submit to us via our contact form is transferred outside the EEA and stored on our third party [[hosting] OR [email] OR [insert entity which stores information submitted by your contact form] provider’s servers. Our [insert type of third party provider (hosting provider, email provider)] is [insert name of third party provider]. You can access their privacy policy here: [insert link to privacy policy].]

Safeguard(s) used: [our [[third party hosting provider] OR [third party email provider] OR [insert entity which stores information submitted by your contact form]] has self-certified its compliance with the EU-U.S. Privacy Shield] OR [insert other safeguard which your third party hosting company uses to transfer information to a country which is outside the EEA (see Appendix 1 for the full list)] [which is available [here: [insert link to the safeguards used] OR [insert means of obtaining a copy of the safeguard]].⁶⁷

[Email

[Information you submit to us by email is transferred outside the EEA and stored on our third party email provider’s servers. Our third party email provider is: [insert name of third party email provider]. You can access their privacy policy here: [insert link to privacy policy].]

Safeguard(s) used: [our [third party email provider] OR [insert entity which stores information submitted by your contact form]] has self-certified its compliance with the EU-U.S. Privacy Shield] OR [insert other safeguard which your third party hosting company uses to transfer information to a country which is outside the EEA (see Appendix 1 for the full list)] [which is available [here: [insert link to the safeguards used] OR [insert means of obtaining a copy of the safeguard]].⁶⁹

[E-Newsletter

[Information you submit to us when you sign up for our e-newsletter is transferred outside the EEA and stored on our third party mailing list provider’s servers. Our third party mailing list provider is: [insert name of third party mailing list provider]. You can access their privacy policy here: [insert link to privacy policy].]

Safeguard(s) used: [our [third party mailing list provider] has self-certified its compliance with the EU-U.S. Privacy Shield] OR [insert safeguards used to transfer information to a country which is outside the EEA (see Appendix 1 for the full list)] [which is available [here: [insert link to the safeguards used] OR [insert means of obtaining a copy of the safeguard]].⁷¹

[Google Analytics

[Information collected by Google Analytics (your IP address and actions you take in relation to our website) is transferred outside the EEA and stored on Google’s servers. You can access Google’s privacy policy here: https://www.google.com/policies/privacy/

[Country of storage: United States of America. This country is not subject to an adequacy decision by the European Commission.]⁷²

Safeguard(s) used: Google has self-certified its compliance with the EU-U.S. Privacy Shield which is available here: https://www.privacyshield.gov/welcome. The EU-U.S. Privacy Shield is an approved certification mechanism under Article 42 of the General Data Protection Regulation, which is permitted under Article 46(2)(f) of the General Data Protection Regulation. You can access the European Commission decision on the adequacy of the EU-U.S. Privacy Shield here: http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm

[Insert additional data collection method or use e.g. information outside the EEA by payment processors]⁷³

[Information you submit to us by [insert method individual uses to submit information to you] is transferred outside the EEA] and stored on our [insert type of third party] servers. Our [insert type of third party provider e.g. email provider] is: [insert name of third party provider]. You can access their privacy policy here: [insert link to privacy policy].]

Safeguard(s) used: [our [insert third party provider for data collection and use] has self-certified its compliance with the EU-U.S. Privacy Shield] OR [insert safeguards used to transfer information to a country which is outside the EEA (see Appendix 1 for the full list)] [which is available [here: [insert link to the safeguards used] OR [insert means of obtaining a copy of the safeguard]].⁷⁵

Your rights in relation to your information

Subject to certain limitations on certain rights, you have the following rights in relation to your information, which you can exercise by writing to [insert address] [or sending an email to [insert email address]]:

to request access to your information and information related to our use and processing of your information;
to request the correction or deletion of your information;
to request that we restrict our use of your information;
to receive information which you have provided to us in a structured, commonly used and machine-readable format (e.g. a CSV file) and the right to have that information transferred to another data controller (including a third party data controller);
to object to the processing of your information for certain purposes (for further information, see the section below entitled Your right to object to the processing of your information for certain purposes); and
to withdraw your consent to our use of your information at any time where we rely on your consent to use or process that information. Please note that if you withdraw your consent, this will not affect the lawfulness of our use and processing of your information on the basis of your consent before the point in time when you withdraw your consent.
[the right not to be subject to a decision based solely on automated processing, including profiling which produces legal affects concerning you or similarly significantly affects you]⁷⁶

In accordance with Article 77 of the General Data Protection Regulation, you also have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or of an alleged infringement of the General Data Protection Regulation.

For the purposes of the UK, the supervisory authority is the Information Commissioner’s Office (ICO), the contact details of which are available here: https://ico.org.uk/global/contact-us/

Further information on your rights in relation to your personal data as an individual

The above rights are provided in summary form only and certain limitations apply to many of these rights. For further information about your rights in relation to your information, including any limitations which apply, please visit the following pages on the ICO’s website:

You can also find out further information about your rights, as well as information on any limitations which apply to those rights, by reading the underlying legislation contained in Articles 12 to 22 and 34 of the General Data Protection Regulation, which is available here: http://ec.europa.eu/justice/data-protection/reform/files/regulation_oj_en.pdf

Verifying your identity where you request access to your information

Where you request access to your information, we are required by law to use all reasonable measures to verify your identity before doing so.

These measures are designed to protect your information and to reduce the risk of identity fraud, identity theft or general unauthorised access to your information.

How we verify your identity

Where we possess appropriate information about you on file, we will attempt to verify your identity using that information.

If it is not possible to identity you from such information, or if we have insufficient information about you, we may require original or certified copies of certain documentation in order to be able to verify your identity before we are able to provide you with access to your information.

We will be able to confirm the precise information we require to verify your identity in your specific circumstances if and when you make such a request.

Your right to object to the processing of your information for certain purposes

You have the following rights in relation to your information, which you may exercise in the same way as you may exercise by writing to [insert address] [or sending an email to [insert email address]]:

to object to us using or processing your information where we use or process it in order to carry out a task in the public interest or for our legitimate interests, including ‘profiling’ (i.e. analysing or predicting your behaviour based on your information) based on any of these purposes; and
to object to us using or processing your information for direct marketing purposes (including any profiling we engage in that is related to such direct marketing).

You may also exercise your right to object to us using or processing your information for direct marketing purposes by:

clicking the unsubscribe link contained at the bottom of any marketing email we send to you and following the instructions which appear in your browser following your clicking on that link;
[sending an SMS message containing only the words “OPT OUT” in reply to any marketing communication we send by text message;]⁷⁷ [or]
sending an email to [insert email address], asking that we stop sending you marketing communications or by including the words “OPT OUT”.

For more information on how to object to our use of information collected from cookies and similar technologies, please see the section entitled How to accept or reject cookies in our cookies policy, which is available here: [insert link to your cookies policy]

Sensitive Personal Information

‘Sensitive personal information’ is information about an individual that reveals their racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic information, biometric information for the purpose of uniquely identifying an individual, information concerning health or information concerning a natural person’s sex life or sexual orientation.

[We do not knowingly or intentionally collect sensitive personal information from individuals, and you must not submit sensitive personal information to us.

If, however, you inadvertently or intentionally transmit sensitive personal information to us, you will be considered to have explicitly consented to us processing that sensitive personal information under Article 9(2)(a) of the General Data Protection Regulation. We will use and process your sensitive personal information for the purposes of deleting it.]

[insert details of the sensitive personal information you collect about individuals, how you collect it, what you use it for and the legal basis on which you process it.]⁷⁸

Changes to our Privacy Policy

We update and amend our Privacy Policy from time to time.

Minor changes to our Privacy Policy

Where we make minor changes to our Privacy Policy, we will update our Privacy Policy with a new effective date stated at the beginning of it. Our processing of your information will be governed by the practices set out in that new version of the Privacy Policy from its effective date onwards.

Major changes to our Privacy Policy or the purposes for which we process your information

Where we make major changes to our Privacy Policy or intend to use your information for a new purpose or a different purpose than the purposes for which we originally collected it, we will notify you by email (where possible) or by posting a notice on our website.

We will provide you with the information about the change in question and the purpose and any other relevant information before we use your information for that new purpose.

Wherever required, we will obtain your prior consent before using your information for a purpose that is different from the purposes for which we originally collected it.

Children’s Privacy

Because we care about the safety and privacy of children online, we comply with the Children’s Online Privacy Protection Act of 1998 (COPPA). COPPA and its accompanying regulations protect the privacy of children using the internet. We do not knowingly contact or collect information from persons under the age of 18. The website is not intended to solicit information of any kind from persons under the age of 18.

It is possible that we could receive information pertaining to persons under the age of 18 by the fraud or deception of a third party. If we are notified of this, as soon as we verify the information, we will, where required by law to do so, immediately obtain the appropriate parental consent to use that information or, if we are unable to obtain such parental consent, we will delete the information from our servers. If you would like to notify us of our receipt of information about persons under the age of 18, please do so by sending an email to [insert email address].

California Do Not Track Disclosures

“Do Not Track” is a privacy preference that users can set in their web browsers. When a user turns on a Do Not Track signal in their browser, the browser sends a message to websites requesting that they do not track the user. For information about Do Not Track, please visit www.allaboutdnt.org

[We respond to Do Not Track browser settings or signals by [insert details of how you recognise and respond to Do Not Track browser settings]] OR [[At this time, we do not respond to Do Not Track browser settings or signals. [In addition, we use other technology that is standard to the internet, such as pixel tags, web beacons, and other similar technologies, to track visitors to the website. Those tools may be used by us and by third parties to collect information about you and your internet activity, even if you have turned on the Do Not Track signal.] For information on how to opt out from tracking technologies used on our website, see our cookies policy which is available here: [insert link to cookies policy]]⁷⁹

Copyright, credit and logo

This Privacy Policy is based on a General Data Protection Regulation (Regulation (EU) 2016/769) (GDPR) compliant template provided by GDPR Privacy Policy. For further information, please visit https://gdprprivacypolicy.org

The copyright in this Privacy Policy is either owned by, or licensed to, us and is protected by copyright laws around the world and copyright protection software. All intellectual property rights in this document are reserved.

Where we display the GDPR Privacy Policy logo on our website, this is used to indicate that we have adopted a privacy policy template provided by GDPR Privacy Policy as the basis for this Privacy Policy.

Appendix 1

Safeguards for overseas transfers

NOTE TO USER: THIS APPENDIX IS FOR REFERENCE AND ASSISTANCE WITH COMPLETING YOUR PRIVACY POLICY AND SHOULD BE DELETED PRIOR TO YOU UPLOADING YOUR PRIVACY POLICY TO YOUR WEBSITE

[an adequacy decision by the European Commission. This is permitted under Article 45(1) of the General Data Protection Regulation. The adequacy decision relied on by us is [insert reference to adequacy decision e.g. Commission Decision 2004/411/EC in respect of the Isle of Man] and is available here: http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm]
[data protection policies adhered to by the data controller and other companies and entities within our corporate group from time to time, which comply with applicable laws, known as “binding corporate rules” or “BCRs” under Article 47 of the General Data Protection Regulation. This is permitted under Article 46(2)(b) of the General Data Protection Regulation. [These policies are available here [insert link to binding corporate rules if you have made them available].]
standard data protection clauses adopted by the European Commission in accordance with its committee examination procedure under Article 93(2) of the General Data Protection Regulation. This is permitted under Article 46(2)(c) of the General Data Protection Regulation. [These clauses are available here [insert link to your standard data protection clauses if you have made them available].]
standard data protection clauses adopted by the Information Commissioner’s Office and approved by the European Commission pursuant to the committee examination procedure under Article 93(2) of the General Data Protection Regulation. This is permitted under Article 46(2)(d) of the General Data Protection Regulation. [These clauses are available here [insert link to your standard data protection clauses if you have made them available].]
an approved code of conduct under Article 42 of the General Data Protection Regulation. This is permitted under Article 46(2)(f) of the General Data Protection Regulation. [This code of conduct is available here [insert link to your standard data protection clauses if you have made them available].]
[insert name of certification mechanism e.g. EU-U.S. Privacy Shield], an approved certification mechanism under Article 42 of the General Data Protection Regulation. This is permitted under Article 46(2)(f) of the General Data Protection Regulation. You can access [insert name of mechanism] here: [insert link to mechanism e.g. for the EU-U.S. Privacy Shield: https://www.privacyshield.gov/welcome] [and the European Commission decision on the adequacy of the EU-U.S. Privacy Shield here: http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm]⁸⁰.

1 You must insert the effective date of your privacy policy so your website users know when your privacy policy takes effect. If you have not previously uploaded a privacy policy to your website, or if you are replacing your existing privacy policy with this privacy policy, the effective date will be the date when you first upload this privacy policy to your website.

2 When you upload this privacy policy to your website, at a minimum, you should ensure that the titles in this “Contents” section link to the relevant headings in the main body of the privacy policy. For instance, the “Our details” title in this “Contents” section should link to the “Our details” heading in the main body of the privacy policy. An alternative and highly recommended way of ensuring your privacy policy meets the clear and accessible requirements of the General Data Protection Regulation is to use drop down boxes for each section of the privacy policy which expand and show the information in that section when clicked on. This allows a user to easily access the information they are interested in quickly and effectively.

3 Include this section if your website contains any particular functionality that collects information from users only if they specifically interact with it e.g. newsletters, registration forms and live chat functionality. Suggested text for some of these common functionalities is included in the main section below.

4 Delete this bullet point from the Contents section if your website is not an ecommerce website and there is no method of placing an order for goods or services (if you have a purely information based brochure style website, for example). If you take payments by other means (e.g. card payments over the phone for instance) you will need to amend this section accordingly to include the relevant information about how you take payments, the information you collect and the payment providers you use.

5 Where you use ‘automated decision-making’ or ‘profiling’, you must disclose this in your privacy policy. For information on what constitutes automated decision-making and profiling, see the footnote to the main section of this privacy policy entitled ‘Our use of automated decision making and profiling’.

6 This summary section is designed to meet the GDPR’s requirement for a privacy policy to be in a concise, transparent, intelligible and easily-accessible form and uses the ICO’s suggestion of adopting a layered approach in order to achieve this. The individual can then look at the corresponding section in the main body of the privacy policy if they require more information on any particular aspect of your privacy policy. If you use an individual’s personal data in a way they would not reasonably expect, you must ensure that you bring it to their attention in this summary section. The summary section can be contained in or separated from the rest of the privacy policy and inserted above it (with the rest of the full privacy policy below) to draw the summary section more clearly to the user’s attention.

7 The data controller is the person responsible for deciding the purposes for which personal information is processed (i.e. used) and the means by which such processing is done. In the vast majority of cases, this will be the company (if your business is a company) or you, the sole trader (if you run your business as a sole trader) which owns and runs the website and is therefore the same person or entity set out at the beginning of the privacy policy. You will normally be aware of who the data controller is if another person or entity is responsible for this role. If you are unsure about who the data controller is, you should seek appropriate professional advice. If you are a data controller and you have not already registered with the Information Commissioner’s Office, you must do so.

8 Include the word ‘occasionally’ if you only occasionally receive information from third parties (i.e. the nature of your business does not involve the regular receipt of information about individuals from third parties). If you regularly receive information from third parties you should delete the word occasionally, and include (wherever possible) the names of the specific third parties from whom you regularly receive information about individuals. If it is not possible to identify individual third parties by name, you should identify them by the nature of the source including the following information: (i) the type of organisation, industry and sector; and (ii) whether the information was held in or outside the EU. In either case, you should indicate whether the source was public or private.

9 Include this section if the servers on which you store personal information are secure. Amongst other obligations, you are required to put in place appropriate technical and organisational measures to minimise the risk of loss, corruption, damage and unauthorised access to personal information. If your servers are not secure, you will need to migrate your website hosting to secure servers in order to meet this legal requirement.

10 You must specify whether or not you use cookies and similar technologies on your website or in your emails, and what type of cookies and similar technologies you use (particularly, any analytical or targeting cookies or web beacons you use). We strongly recommend that you confirm with your web developer and software providers before stating that you do not use cookies as many websites, plugins or website-building platforms place cookies on users’ devices which the website operator may not be aware of. If you do use cookies and/or similar technologies, you should provide a link to your cookies policy here and set out the full details of the technologies you use there.

11 This privacy policy template envisages that you do not collect ‘sensitive personal information’ about individuals and is designed to deal with a situation where such information is accidentally or intentionally submitted by a website user to you. Sensitive personal information is information which reveals an individual’s racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership, genetic information, biometric information, information about an individual’s health or sex life or sexual orientation. If your business does collect sensitive personal information the requirements for processing such information are very strict (for example you will usually require the individual’s explicit consent) and you should seek appropriate legal advice.

12 Include the word third party if you do not host your website on your own server (i.e. a server owned and managed by you). In the vast majority of cases, your website will be hosted on a third party server, either on a shared (i.e. used by other websites) or dedicated (i.e. used only to host your own website) basis. If you do not have the relevant information already, you should independently confirm for yourself who your third party website hosting provider is, that they will be compliant with the GDPR and in particular that they store information securely using appropriate technical and organisational measures to protect the information stored on their servers. You will also need to enter into a data processing agreement with your hosting company if they fall under the definition of a ‘data processor’ under the GDPR (i.e. someone who processes personal data on your behalf (with you as the data controller). Whether or not your website hosting company is a data processor will depend on your individual circumstances and relationship with them but hosting companies are very often considered data processors for data controllers. The details of the requirements for data processing agreements are complex and unfortunately beyond the scope of the guidance in this privacy policy, but such agreements must satisfy the requirements of Article 28 of the GDPR at a minimum. You should speak with your website hosting company to confirm what steps they are taking to prepare for GDPR and analyse the nature of your relationship with them to determine whether or not they are a data processor or data controller. If you determine that they are a data controller, you will need to determine whether you and they are joint data controllers in respect of the data you both process, in which case you will need to enter into a joint data controller agreement to determine your respective responsibilities. You can find out more about the difference between data processors and data controllers in the ICO’s guidance which is available here: https://ico.org.uk/media/for-organisations/documents/1546/data-controllers-and-data-processors-dp-guidance.pdf.

13 You should amend, delete and add to any information your server collects about websites visitors. If you are unsure about the information collected by your server, you should contact your hosting provider. You also need to find out from your hosting provider how long they keep information collected by their servers (i.e. the retention period) and include this in the section of your privacy policy entitled ‘How long we retain your information

14 Include the second half of this sentence if your website’s server is based in a country which is outside the European Economic Area. You will also need to complete the relevant sections in the section of this privacy policy entitled ‘Transfers of your information outside the European Economic Area.

15 Include this paragraph if you do not attempt to identify individuals from your website server logs or if you only attempt to identify them when investigating suspicious or potentially criminal activity, as appropriate.

16 Include this section if you analyse your website server log information. If you do, you should make any amendments that are appropriate, such as amending the types of information you analyse and how you analyse and use it if they differ from the common types of information and uses already described in this section.

17 Insert and complete this section if your website uses cookies and similar technologies. You will need to complete your cookies policy with full details of the cookies you use on your website.

18 Express consent will be required to place non-essential cookies on users’ devices from 25 May 2018 onwards so you will need to install a cookie control solution on your website to allow users to accept and manage non-essential cookies, ideally by individual cookie in order to meet the GDPR’s requirements for ‘granular’ consent (i.e. that a user can consent to setting precisely which cookies they want rather than being forced to accept all cookies in order to accept the cookies they want). One potential solution, currently used by the ICO itself, is Cookie Control by Civic. You can find out more information about that solution here: https://www.civicuk.com/cookie-control

19 Include this paragraph if you use a third party email provider (e.g. Gmail, Webmail etc.) to store your emails (most businesses do). Article 29 Working Party Guidance indicates that you should mention any third party recipients of personal information by name unless you can demonstrate that it is ‘fair’ not to do so. If you decide not to provide the name of your third party email provider, however, you should provide their location (i.e. country in which they are located). If do provide the name of your third party email provider, you should include a link to their privacy policy.

20 You need to state where you store individuals’ personal information, in particular whether it is stored within or outside the European Economic Area. If you (or your third party email provider) store emails outside the European Economic Area, you will also need to complete and provide the relevant information in the section of this privacy policy below entitled ‘Transfers of your information outside the European Economic Area’ and indicate the safeguards you use to transfer personal information outside the EEA.

21 Include this sentence if your email provider stores emails outside of the European Economic Area (you will need to confirm with your email provider where they store your emails if you do not already know this information).

22 You should include any optional information that a user can submit via your contact form (i.e. optional (as opposed to mandatory) fields). Note that the principle of data minimisation requires that you do not collect more information than is required so only information that is strictly necessary to collect (such as name and email address) should be mandatory. Any information which is not strictly necessary for you to be able to respond to an enquiry, should be an optional field. You may want to include a phone number as an optional field if you prefer to respond to enquiries you receive by phone (or make phone number the mandatory field and email the optional field). Where you have any optional fields on the contact form, these should be clearly marked as optional and distinguished from mandatory fields e.g. by marking mandatory fields with a red asterisk and inserting the word optional in square brackets after optional fields e.g. Phone (optional).

23 Include this sentence if it is possible to insert optional information in your contact form. You should also explain at the ‘point of collection’ (i.e. on or around the contact form itself) what the consequences of not providing a particular piece of information are (e.g. the consequences of not providing a phone number) next to the appropriate field on the contact form.

24 When information is submitted via a contact form on a website, it is usually stored on the website or server or sent directly to an email address you have designated and therefore stored on your email provider’s servers. You will need to identify where information submitted via your contact form is stored and in particular whether it is stored inside or outside the European Economic Area.

25 Include this paragraph if information submitted via your contact form is stored outside the European Economic Area (e.g. because your website’s server is located in a country outside the European Economic Area). You will also need to complete the relevant sections in the section of this privacy policy entitled ‘Transfers of your information outside the European Economic Area’ below and indicate the safeguards you use to transfer personal information outside the EEA.

26 If you use a third party contact form provider (e.g. you have integrated a third party contact form plugin) which stores information on its servers, you will need to complete this paragraph. If any contact form provider you use does not collect or store any information which is submitted via your contact form (i.e. information is transmitted directly to your own email or website servers) you do not need to complete this clause and can delete it in its entirety (though you must first confirm that they do not in fact collect any information about individuals).

27 Include this paragraph if information submitted via your contact form is stored outside the European Economic Area (e.g. because your website’s server is located in a country outside the European Economic Area). You will also need to complete the relevant sections in the section of this privacy policy entitled ‘Transfers of your information outside the European Economic Area’ below and indicate the safeguards you use to transfer personal information outside the EEA.

28 This section is designed to deal with situations where you receive phone calls e.g. because you have made a phone number available on your website for customers to contact you. If you do not have a phone number available on your website, we would still recommend retaining this section as it is possible or even likely that you will collect information about individuals in the course of business (e.g. suppliers) or because individuals have otherwise obtained your phone number. This section also assumes that your telephone provider does not transfer personal information outside the EEA. If they do transfer the information they collect in relation to phone calls, however, you will need to ensure appropriate safeguards are in place. For further information, please see the section entitled ‘Transfers of your information outside the European Economic Area’.

29 It is recommended that you make it clear about whether you record or do not record phone calls. This privacy policy assumes that you do not record phone calls (as most businesses do not do so) and recorded phone calls are beyond the scope of this privacy policy. If you do record calls, you will need to obtain appropriate advice on how to ensure that your recording of phone calls complies with the law, including the Telecommunications (Lawful Business Practice) (Interception of Communications) Regulations 2000 (SI 2000/2699) (the ‘Lawful Business Regulations’) and the Regulation of Investigatory Powers Act 2000 (‘RIPA’), including making the appropriate disclosures at the beginning of your call and on your website (i.e. by inserting the wording ‘calls may be recorded’ next to your telephone number wherever it appears on your website) and explaining why you record calls in your privacy policy.

30 If you include the name of your third party telephone provider, you need to include a link to their privacy policy.

31 Include this paragraph if phone call information is stored outside the European Economic Area (e.g. because your telephone provider stores information about phone calls outside the EEA or if you do for any reason). You will also need to complete the relevant sections in the section of this privacy policy entitled ‘Transfers of your information outside the European Economic Area’ below and indicate the safeguards used to transfer personal information outside the EEA (e.g. because your telephone provider has self-certified its compliance with the EU-U.S. Privacy Shield (if for example, it is a US company and that is the safeguard it uses). You will need to confirm with your third party telephone provider what safeguards they use if you do not already know this information).

32 You should edit and amend this list as appropriate to reflect any public sources which you may obtain information about individuals from.

33 Include this clause if you purchase lists from third parties. Note that it is possible not to include this clause in your privacy policy providing that you meet the obligation (which you are required to meet in any event) to provide individuals with a copy of your privacy policy where you have obtained their details from third parties. You should also be aware of the very high risks associated with purchasing data lists and the effective need under GDPR to be named as a third party in order for an individual to be able to have consented to their information being purchased by you.

34 This paragraph should only be included if you use automated decision-making or profiling. Please note: this is a complex area of law, and if you are engaged in any automated decision making or profiling on your website, we strongly recommend that you obtain independent advice, as this is an area which carries a particularly high risk of fines.

If you do not use any automated decision-making or profiling, you can delete this section. The information below sets explains what these terms mean and how they are likely to apply to your website. Please note that this section envisages that you do not process any ‘sensitive personal information’.

‘Automated decision-making’ is where a decision is made by a machine in relation to an individual without any meaningful human involvement and where that decision significantly affects that individual (e.g. a decision whether to grant an individual credit).

‘Profiling’ is ‘any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.’

In terms of your website, the most likely activities that most websites will carry out that will be affected by the automated decision-making or profiling requirements are web analytics, server log information analysis tools and online advertising. Merely collecting information about who accesses your website is not profiling in itself, but the automated analysis and use of that information to categorise individuals in web analytics will constitute profiling if the processing of personal information is involved (this includes the processing of IP addresses and cookies which can be used to identify individuals (particularly if they are combined with other information)).

The most common and relevant forms of automated decision-making and profiling used by websites are targeted web advertising (e.g. remarketing advertisements, via AdSense, via Facebook Ads or any other advertisements targeting specific individuals or groups of individuals). Simply collecting information about the use of your website by an individual will not constitute profiling (e.g. via server logs) but the automated analysis and categorisation of such information by analytics providers such as Google Analytics will. If you use analytics or online advertising which is designed to target certain individuals, you must explain what information you use, how you use it and any consequences e.g. that information will be collected about them and they will receive targeted advertisements based on their actions or certain characteristics about them. If you are sure that your business does not use either automated decision-making or profiling, you can delete these provisions.

35 Include this clause if the automated decision making you use does not legally or otherwise similarly significantly affect individuals.

36 This privacy policy assumes that you do not engage in automated decision making that has legal effects or otherwise significantly affects an individual. To significantly affect someone, the decision making must have the potential to significantly influence an individual’s circumstances, behaviour or choices. Examples of significant effects would be the automatic refusal of an online credit application or e-recruiting practices without any human intervention. Sectors of businesses that are particularly likely to engage in such significant automated decision making in some way include banking and finance, healthcare, taxation, insurance, marketing and advertising.

37 Insert and amend this clause if you use remarketing style advertising across the internet (e.g. if you market to individuals who have visited your site by displaying advertisements to them on other sites e.g. using Google AdSense).

38 You will need to implement a cookies management tool on your website that allows to turn on and off cookies on your site. See Cookie Control by Civic for a potential solution (which the ICO uses): https://www.civicuk.com/cookie-control

39 Use this template clause to describe any automated decision making you use which is not already covered by this privacy policy template e.g. credit checks. Please note, however, that this privacy policy does not cover automated decision making in relation to individuals’ sensitive personal information. In order to do that, you will generally need their explicit consent.

40 Include this sentence if your analytics provider anonymises the data after it collects it and combines it with information from other website users to generate overall statistics that cannot be tied back to a particular user.

41 It is difficult to allow an individual to easily opt out of web beacon tracking in marketing emails in practice, but there is a legal requirement that you allow them to do so. One solution may therefore be to manually delete someone’s details from your mailing list which contains web beacons and move them to your list which does not use web beacons (however cumbersome and time consuming this may unfortunately be). In this case, their method for objecting should be to contact you and inform you that they object to your use of web beacons. In reality, we consider it is unlikely that someone will want to receive marketing communications but also be concerned about web beacons but you will still need to gain separate consent to the use of web beacons and similar technologies in your emails and record this (e.g. on your website’s database).

42 Use this template clause to describe any profiling you use which is not already covered by this privacy policy template e.g. automated analysis of web server logs.

43 Many of the entities in the following list can be classified as ‘data processors’ (though this will not necessarily be the case and will depend on your individual circumstances). You will need to conduct you own analysis to confirm whether such third party processors (and any other processors you use) are ‘data processors’ for the purposes of the GDPR and enter into data processing agreements with them if so. For further information, see the ICO’s guidance which is available here: https://ico.org.uk/media/for-organisations/documents/1546/data-controllers-and-data-processors-dp-guidance.pdf

44 Guidance issued by the Article 29 Working Party indicates that they expect you to provide the ‘names’ of the recipients of personal information unless you can show why it is ‘fair’ for you to only provide the categories of recipients. In order to be fully compliant, you should therefore provide the names of any third party service providers you use and provide links to their privacy policies. The actual GDPR legislation provides that ‘categories of recipient’ are sufficient. It is currently unclear to what extent the ICO would enforce a failure to provide named recipients of personal information or whether it would take any action at all. It is worth noting, however, that the ICO’s privacy policy that they do regularly provide named recipients as a matter of course in their privacy policy which you can access here: https://ico.org.uk/global/privacy-notice/). In any event, if you choose not to provide the identities of the third parties to whom personal data will be transferred you must document the reasoning behind your decision not to do so (i.e. keep a written record of that decision).

45 If you decide only to provide the categories or recipient, you must provide their location.

46 Insert this provision if you have decided not to disclose the identities of you third party service providers on your website and have used categories of recipient instead.

47 This paragraph explains how information is shared with Google Analytics as an example. If you use a different web analytics provider, you should provide a similar description of how information is shared with that third party provider and what it is used for. You will generally always need to disclose the identity of your analytics provider as they tend to collect information about website visitors by default.

48 You need to include the details of any organisations with whom you share individuals’ personal information. As far as possible, these should be indicated using their specific names. If that is not possible, they should be identified by specific categories of business (by industry, sector and sub-sector) and you should provide their locations (i.e. what country they are located in). A suggested list of third parties with whom a business might share third parties is set out below. You should include links to their privacy policies wherever they are publicly available. If you do not name the third parties with whom you share information you will need to be able to justify why it is fair not to do so and document your decision.

49 This provision covers a situation where your business is comprised of multiple companies within a corporate group. You should specify the details of other entities in the corporate group with whom you will share personal data. If your business is a single company or other legal entity, or are a sole trader, this provision should be deleted.

50 Insert this provision if you have decided not to disclose the identities of you third party service providers on your website and have used categories of recipient instead.

51 Include this sentence if your business is subject to anti-money laundering regulations such as the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017.

52 Amend this to the appropriate jurisdiction (e.g. the laws of Scotland) if your business is not incorporated (if you are a corporate entity) or registered (if you are an individual) in England or Wales.

53 As far as possible, you should state fixed time periods for your retention of information.

54 If you keep information for longer than the legal record keeping period you must be able to justify why you do so and provide your explanation here.

55 One of the most common sources of personal information is enquiries from customers or potential customers. There is no fixed time period specified by law for retaining the personal information you receive in connection with those enquiries. We would recommend setting a specific period which you can justify as reasonable. Ideally, any personal information should be deleted as soon as an enquiry has been resolved, but this may not be practical to implement for many businesses. We would anticipate that a period of one to three months would not be unreasonable for the vast majority of businesses, although a longer period may be acceptable provided that it can be justified. It is important to remember, however, that holding onto personal information generally increases the risk of liability so we would recommend that you delete such information as soon as you no longer require it, in particular to reduce the risk of you having to respond in detail to a subject access request, which can be very onerous.

56 If you store data collected for specific circumstances for any specific period of time or on any specific basis, you should insert the relevant information here.

57 These are general factors which the Information Commissioner’s Office recommends that you consider when determining the retention period for personal information. You should delete any factors that do not apply to your determination of how long you retain information and add any additional factors that you take into account (if any).

58 This section includes some mandatory security measures you are required to take as well as some suggested further actions methods of securing personal information which you may or may not use in practice. You should add to this list any additional methods which you use to secure personal information which are not covered in this list.

59 You need to ensure that personal information collected via your website is stored on secure servers.

60 Include this provision if you accept payment for goods and services online from your website.

61 Although transmission of information over the internet is inherently insecure, you need to ensure that personal information collected via your website is stored on secure servers.

62 Where personal information is transferred outside of the EEA you must inform users of the country where it will be stored and the safeguards used. This section is designed to cover off this requirement. It is possible that personal information you collect may be stored in different places depending on the methods you have collected it and the purposes for which you are processing it e.g. if you use a third party email list provider to administer your email marketing list, you will need to check where they store the information. For example, MailChimp, a popular mailing list provider, stores information on their servers in the US and the safeguard they use to do so is the EU-U.S. Privacy Shield. The annex to this privacy contains the wording to use for the relevant safeguards that you use. Information collected via the contact form on your website however, assuming the information is stored on your website (and not emailed to you), will be generally be stored on your website’s server, so the location of your server will be the relevant location (although you must confirm that this is in fact where the information collected on your website is stored). Regular emails that you receive to the email address on your website, however, could be stored somewhere else (e.g. your email provider’s servers). You will therefore need to do a review and analysis of where information collected by your website is stored and the safeguards you use for overseas data transfers before you can complete this section.

If you do no transfer personal information outside of the EEA in any circumstances (e.g. all personal information you collect is located in the UK (for as long as it remains a member of the EEA) or is only transferred to other EEA countries, you can simply include the statement at the beginning of this section (i.e. We do not transfer your information outside of the EEA) and delete the rest of the information in this section. However, you must be sure that you do not transfer any personal information outside of the EEA before you do so.

63 If you do not transfer any information outside the EEA, then you should complete the first paragraph and delete the rest of this section.

64 You must state whether the country to which information has been transferred is subject to an adequacy decision by the European Commission or not. If it is, you will be able to rely on that adequacy decision to transfer and store information in that country. If is it not, you will need to find another appropriate safeguard to use. The list of countries subject to an adequacy decision by the European Commission is available here: http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm. Please note that the US is not subject to an adequacy decision. Rather, certain US companies have self-certified their compliance with the EU-U.S. Privacy Shield, which is an appropriate safeguard. Only if the US company has self-certified its compliance with the EU-U.S. Privacy Shield can you transfer personal information to that company in the US.

65 Where you have made available any of the safeguards referred to in the bullet points, you must provide a means to obtain a copy of them i.e. a link to them or an email address that an individual can write to in order to request them.

66 You must state whether the country to which information has been transferred is subject to an adequacy decision by the European Commission or not. If it is, you will be able to rely on that adequacy decision to transfer and store information in that country. If is it not, you will need to find another appropriate safeguard to use. The list of countries subject to an adequacy decision by the European Commission is available here: http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm. Please note that the US is not subject to an adequacy decision. Rather, certain US companies have self-certified their compliance with the EU-U.S. Privacy Shield, which is an appropriate safeguard. Only if the US company has self-certified its compliance with the EU-U.S. Privacy Shield can you transfer personal information to that company in the US.

67 Where you have made available any of the safeguards referred to in the bullet points, you must provide a means to obtain a copy of them i.e. a link to them or an email address that an individual can write to in order to request them.

68 You must state whether the country to which information has been transferred is subject to an adequacy decision by the European Commission or not. If it is, you will be able to rely on that adequacy decision to transfer and store information in that country. If is it not, you will need to find another appropriate safeguard to use. The list of countries subject to an adequacy decision by the European Commission is available here: http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm. Please note that the US is not subject to an adequacy decision. Rather, certain US companies have self-certified their compliance with the EU-U.S. Privacy Shield, which is an appropriate safeguard. Only if the US company has self-certified its compliance with the EU-U.S. Privacy Shield can you transfer personal information to that company in the US.

69 Where you have made available any of the safeguards referred to in the bullet points, you must provide a means to obtain a copy of them i.e. a link to them or an email address that an individual can write to in order to request them.

70 You must state whether the country to which information has been transferred is subject to an adequacy decision by the European Commission or not. If it is, you will be able to rely on that adequacy decision to transfer and store information in that country. If is it not, you will need to find another appropriate safeguard to use. The list of countries subject to an adequacy decision by the European Commission is available here: http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm. Please note that the US is not subject to an adequacy decision. Rather, certain US companies have self-certified their compliance with the EU-U.S. Privacy Shield, which is an appropriate safeguard. Only if the US company has self-certified its compliance with the EU-U.S. Privacy Shield can you transfer personal information to that company in the US.

71 Where you have made available any of the safeguards referred to in the bullet points, you must provide a means to obtain a copy of them i.e. a link to them or an email address that an individual can write to in order to request them.

72 You must state whether the country to which information has been transferred is subject to an adequacy decision by the European Commission or not. If it is, you will be able to rely on that adequacy decision to transfer and store information in that country. If is it not, you will need to find another appropriate safeguard to use. The list of countries subject to an adequacy decision by the European Commission is available here: http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm. Please note that the US is not subject to an adequacy decision. Rather, certain US companies have self-certified their compliance with the EU-U.S. Privacy Shield, which is an appropriate safeguard. Only if the US company has self-certified its compliance with the EU-U.S. Privacy Shield can you transfer personal information to that company in the US.

73 If there are any other ways in which personal information is transferred outside the EEA, you should use and duplicate this template section to cover off those additional methods until you have described all of the circumstances in which you transfer personal information outside of the EEA.

74 You must state whether the country to which information has been transferred is subject to an adequacy decision by the European Commission or not. If it is, you will be able to rely on that adequacy decision to transfer and store information in that country. If is it not, you will need to find another appropriate safeguard to use. The list of countries subject to an adequacy decision by the European Commission is available here: http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm. Please note that the US is not subject to an adequacy decision. Rather, certain US companies have self-certified their compliance with the EU-U.S. Privacy Shield, which is an appropriate safeguard. Only if the US company has self-certified its compliance with the EU-U.S. Privacy Shield can you transfer personal information to that company in the US.

75 Where you have made available any of the safeguards referred to in the bullet points, you must provide a means to obtain a copy of them.

76 You will need to include this right if you engage in automated decision making which has a legal effect on individuals or which similarly significantly affects individuals. This will generally not be the case in relation to regular online advertising methods and web analytics. However, you should see the section and footnotes relating to the section entitled ‘Our use of automated decision making and profiling’ below.

77 Include this provision if you use text (SMS) marketing. If you only use email marketing, for example, you can delete this provision.

78 Sensitive personal information is outside the scope of this privacy policy as it is not ordinarily collected by most businesses. If you do collect sensitive personal information, you should seek appropriate advice on how to ensure your website and collection methods comply with the General Data Protection Regulation and any other applicable legislation. In many cases, the only legal basis on which you will be able to process sensitive personal information will be an individual’s explicit consent (under Article 9(2)(a) of the GDPR.

79 The legal status of a do not track request has not yet been confirmed (i.e. whether it should be considered an objection to processing or objection to profiling under the GDPR). As such, it is unclear whether there is any legal obligation to respond to such requests and whether any enforcement action will be taken against websites which do not recognise the request. We would recommend, however, that you err on the side of caution and assume that the GDPR will be recognised as a valid method of objecting to tracking technologies on your site and implement an appropriate solution to respond to this (e.g. Cookie Control by Civic: https://www.civicuk.com/cookie-control)This disclosure is required to satisfy The California Online Privacy Protection Act (CalOPPA) and there is no requirement to make such a disclosure under GDPR. Therefore, you may wish to delete this paragraph altogether although you would run the risk of being found to be in breach of CalOPPA, particularly if users from California access your website.

80 Insert this final section in square brackets if the mechanism used is the EU-U.S. Privacy Shield.