LAST UPDATED: 21st August 2020
Sellframe Ltd, we or the Company respect your privacy and are committed to safeguarding your personal data.
This policy describes the information we collect or you shared with us when you visit our website (regardless of where you visit it from), how it is used, stored and safeguarded, and your choices regarding this information.
This policy outlines how we collect and process your personal data through your use of this website.
This website is not intended for any individuals under the age of 18. If you are under 18, you are not permitted to access our website or Services and we do not knowingly collect data relating to under 18s.
DATA CONTROLLER AND CONTACT DETAILS
Our details are as follows:
Sellframe Ltd (A company registered in Scotland SC472357)
Email us at mail[atsymbol]sellframe[dot]com
HOW TO CONTACT US ABOUT YOUR RIGHTS AND DATA
By email at: mail[atsymbol]sellframe[dot]com
We are regulated by the Information Commissioner’s Office and you have the right to make a complaint at any time to them. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
INFORMATION COLLECTED ABOUT YOU
We have set out below the personal data about you we may collect, use, store and transfer when you interact with us through our website. Personal data means any information from which you can identify you, it does not include information we collected on an anonymous basis.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
- Usage Data includes information about how you use and interact with our website and services.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
How your data is collected
We use different methods to collect data from and about you including through:
- Automated technologies or interactions. As you interact with our website, we automatically collect data about the device you use when you interact with us, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.
- Third parties or publicly available sources. We may receive personal data about you from various third parties, in particular technical data from analytics providers such as Google Analytics
HOW WE USE YOUR INFORMATION
We collect, process, store and disclose personal data for a variety of different reasons, but in all cases only when the law allows us to. We will only share, collect or process your data for the purposes outlined in this policy, we will not process your personal data to fulfil another purpose without seeking you express consent. We use your data to provide our services and only our services.
The General Data Protection Regulation (“GDPR”) requires that companies processing personal data of EU data subjects set out the specific lawful basis on which they process that data. For the personal data identified in this policy we rely on the following lawful basis to processing your data:
- Consent: generally, we do not rely on consent as a legal basis for processing your personal data, unless when we are sending your data outside the EEA, where we are sharing it with various third-parties, or for the purposes of marketing communications. You have the right to withdraw consent at any time by contacting us.
- Contractual Obligations: where we need to perform our contractual obligations, either directly with you or our customers.
- Regulatory or Legal Obligations: where we need to comply with any applicable laws.
- Legitimate Interests: where it is necessary for our legitimate interests (or those of a third party) and these interests do not override your interests and fundamental rights.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. In general where we do use your personal data for the purposes of direct marketing, we will employ the following data control mechanisms.
We will only use your personal data for marketing purposes where you have consented to this; you can withdraw your consent at any time.
Promotional offers from us
We may use your Technical and Usage Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes. However, we may share aggregated and anonymized data generated from personal data we collect through your use of the website and services.
COOKIES AND OTHER TECHNOLOGIES
Cookies come in a variety of forms but are essentially small data files used to collect and store information about you. We use them on our website for a variety of different functions:
- for the smooth and safe operation of our website;
- to manage your preferences and remember you for future visits;
- to analyse how you use our website in order to continually make improvements.
INFORMATION SHARING AND DISCLOSURE
We share the information we collect or that is provided to us as follows:
Sharing with our Partners
We may share your personal data with the parties set out below for the purposes we have identified above.
- External Third Parties as set out in the table below.
Where we use Partners based in countries outside the European Economic Area or the UK, we ensure a similar level of protection is afforded to all data subjects prior to the transfer. Please contact us if you require further information on the specific mechanisms we use to transfer your personal data to a 3rd Country.
HOW WE SAFEGUARD YOUR DATA
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
RETENTION AND DELETION
We will only retain your personal data for as long as is necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
In some circumstances you can ask us to delete your data by contact us (see the below section for further information).
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case this information is no longer deemed personal information and we may continue to process this information indefinitely.
YOUR DATA, YOUR RIGHTS
The title of this section says it all and as an EU Data Subject you have a wide range of rights with regards to your data, which have, as of the 25 May 2018, been enhanced by the General Data Protection Regulation (“GDPR”), Data Protection Act 2018 and all of applicable data protection law.
You can enforce your rights by contacting us, or in most cases, ceasing your use of the website and/or services.
- Right to Rectification: if you believe any of the information on your profile to be inaccurate you have a right to request that we correct this. This right also extends to various other information we collect about you which you can request a copy of (see Right to Access below).
- Right to Access: you have a right to request a copy of the information that we hold about you along with an explanation from us as to why we process that information. We will provide this information to you free of charge for a first request, but will charge for reasonable administrative costs for further requests.
- Right to Erasure: you have a right to request the deletion of your data at any time. If you submit such a request to us we will consider carefully and reply with an explanation as to why we are required to retain certain information either by law or for our own legitimate reasons. Where, after review, we identify any data we do not need to retain for these purposes, we will delete that data as per your request.
- Right to Object or complain: you have a right to complain about how we are processing your data to our principal Data Protection Authority, the Information Commissioner’s Office here or in writing at the following address:
Customer ContactShould you have any concerns about how we are processing your data, we invite that you submit those questions to mail[atsymbol]sellframe[dot]com.
Information Commissioner's Office
UPDATES TO OUR POLICY
LAST UPDATED: 21st Aug 2020
This Policy applies to both the use of our “Website” (4dayweek.io).
When you visit our Website or interact with us through our Services we use a range of cookies, web beacons, pixel-tags, and other similar technologies to store information about you in order to provide you with a better and safer experience and, in some limited circumstances, for advertising purposes.
WHAT ARE COOKIES?
Cookies come in a variety of forms but are essentially small data files that include anonymous unique identifiers that can be used to collect and store information about you. Cookies are placed and stored on the device (be it your computer, tablet, mobile phone or through your browser) you use to access either of our “Website” (4dayweek.io). They allow us to record certain pieces of information whenever you visit or interact with us through the Website or our Services.
The types of information that we collect through cookies includes your device type, operating system, browser type, the website you visited, your time of visit, whether you have accessed our Website from another website (i.e., a referring website), your IP address, as well as information about your preferences (such as your language).
For further information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, you can visit www.allaboutcookies.org and www.youronlinechoices.eu.
TYPES OF COOKIES
Just like at your local supermarket, our cookies come in a variety of types.
Cookies come in a variety of forms and include:
- Web-beacons, pixel-tags or clear GIFs: these are small graphic images that may be included on our Website that work in conjunction with other cookies to identify you.
- Other similar technologies: we also use various other technologies to collect information which operate in the same way as cookies such as flash cookies or HTML cookies.
Session vs. Persistent
- Session Cookies: these are cookies that are linked to your browser session and allow us to link your actions during that particular session, they only last as long as your online session, and disappear from your computer or device when you close your internet browser.
- Persistent Cookies: these cookies are stored on your device after your browser has been closed and have a defined expiry date. Persistent cookies are helpful where we need to know who you are when you are using more than one browsing session, such as to remember you for your next visit or your selected preferences.
First-Party vs Third-Party
Cookies can be provided directly by us, via us on behalf of a third-party, or directly by a third-party themselves.
- First-Party cookies: These cookies are set by the website you’re visiting and only that website can read them.
- Thirty-Party cookies: These cookies are set by a third-party site you are visiting from or from a third-party who has integrated with our Website (such as through a social plugin allowing you to share a link to our content on that social media platform). We are not responsible for, or have any control over, these types of third-party cookies – you can still block or disable them, just not through us.
- To remember information about you when you log-in, so you do not have to give this information over and over again;
- To keep both our Website and Services secure and you secure when using them, such as by identifying irregular site behaviour, enabling security features and to allow access to secure areas of our Website and Services;
- To help us understand how people are using our Services (such as by providing statistics on which parts of the Website or Services you visit, or how easy it is to navigate our Website or Services). We use this to improve the look, feel and operation of our Website and Services;
- Specifically for our Website, to allow you to use social plugins and other customized content and experiences (such as posting our content to social media platforms). In addition, our third-party partners may use a cookie or similar technology in order to determine whether you arrive at our site via one of their ads.
- Strictly Necessary Cookies: These are cookies that are required for the smooth and safe operation of our Website and Services. These include, for example, cookies that enable you to log into secure areas of our Website or Services and remember any security settings. Without these types of cookies your use of the Website or Services as well as your security could be affected;
- Functionality Cookies: These cookies are used to recognise you when you return to our Website and Services. They enable us to personalise our content for you and remember your preferences (for example, your choice of language, region and landing page, font size etc.) and whether you have visited the Website or Services before so that bannering/messaging for new visitors is not displayed to you.
- Analytical/Performance CookiesThese help us understand how people are using our Website and Services, including the number of visitors, which pages and content is accessed and how those visitors navigate our Website and Services. Some of these cookies, whilst served by us, are provided by our partners, who help us analyse this information. We use these cookies to improve the way our Website and Services work, to make sure our Website and Services are working properly (which extends to fixing any identified errors) and to generally improve the experience we deliver to you.
- Targeting Cookies/Advertising Cookies: These cookies also record your visit to our Website and Services, the pages you have visited and the links you have followed. Our partners may use this information in order to determine whether you arrived at our site via one of their ads.
The below table sets out more information about the individual cookies we may use across our Website or Service and the purposes for which they are used;
You have the right to choose whether or not to accept cookies.
Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. For guidance on how to do this the following website may prove useful (http://www.whatarecookies.com/view.asp).
However, cookies are an important part of how our Website and Services work, so you should be aware that if you choose to remove cookies, this could affect the availability and functionality of the Services and, in some circumstances, you may not be able to access all or parts of our Website or Services.
Removing or rejecting browser cookies does not necessarily affect third-party flash cookies which may be used by us or our partners in connection with our Services. To delete or disable flash cookies please visit this site for more information.
If third-party flash cookies are disabled on your browser, some features on our Website may not work as you would expect. However, you can always set exceptions via your browser to allow third-party cookies for our website.