Who are we
This Privacy Policy sets out the data processing practices of Privacy Policy
Who are we
This Privacy Policy sets out the data processing practices of Crystal Data Ltd. Please note that all data thus captured will be used and held in accordance with the requirements of the Data Protection Act 2018.
Crystal Data Ltd, Devonshire House, Aviary Court, Wade Road, Basingstoke, RG24 8PE
Email: accounts@crystaldata.uk
Crystal Data provides telemarketing and lead generation services to its clients.
Crystal Data is the data controller. If you have any requests concerning your personal data or any queries with regard to how we handle your data you can contact the DPO using the information provided on our Contact Us page.
Purpose of Processing
We will only process your personal data in accordance with the services we provide to you based on the contract we have, or based on your consent in relation to any marketing activities we undertake. We will collect this consent when you first provide your personal data and you can withdraw that consent at any time by contacting us using the contact information provided above or by updating your online profile, if you have created one.
Activity Why we need to process your personal information Lawful basis to process personal information
Completing an account registration form
Processing the creation of your account
Provide you with information elating to our services
Contract
Completing an order form on the website
Dealing with an order / booking
Internal accounting processes
Provide you with information relating to the order
Contract
Data Screening, Cleansing or Telemarketing Dealing with data you supply to us for the purposes of providing the services you have requested Contract
User registration To enable login to your personalised area of the Crystal Data website Contract
Email marketing To send information and marketing messages by email During the signup process we rely upon Legitimate Interests, but in all other cases Consent
Postal Marketing To send occasional marketing communications by post Legitimate Interest
Segmentation, analytics, marketing profiling To provide targeted and appropriate marketing messages Legitimate interest
Consent
For email marketing and for passing data to third parties we will use consent, this will usually be in the form of an opt-in tick box, or when you submit an email address expressly for the reason of sending marketing. We will always make it clear what your data will be used for and provide a link to our privacy policy. You can change your mind at any time.
Contract
Processing of personal data is necessary for us to administer the pre-contract and contractual relationship between ourselves and our suppliers/members in connection with the performance of a contract.
Legitimate interests
We will use legitimate interests to send occasional marketing by email, post and for segmentation and profiling in order to send relevant targeted communications. Our legitimate interests are to communicate with our customers to keep them informed, to grow our business and promote best practice in the marketing industry.
1. Marketing
We would like to use your personal data to send you details of products or services that we offer that we have identified as likely to be of interest to you. We will only send you information in line with the preferences you indicated when you provided the personal data or have updated in your online profile.
If at any point you would like to opt-out of receiving communications from us or would like to change the channels (such as email or post) that we use to contact you, please contact us using the details provided on our Contact Us page.
2. Recipients/categories of recipients
In carrying out our business including our obligations to you, we may use sub-contractors. These may be IT Network Specialists or providers of some or all of the Services that we provide to you. We will ensure that they respect your privacy and abide by all data protection laws.
3. Transfers to third countries
As part of our processing activities if we ever require to transfer your personal data to another country, we will always ensure we have a written data processing agreement with these processors to ensure the same level of data protection in the United Kingdom will apply.
4. Retention periods
We will keep your personal data in connection with the services/products you have bought for approximately 1 year after your purchase. We need to retain this data for our own accounting purposes and for legal and tax purposes.
In terms of the personal data we use for marketing, we will keep this data for as long as we are able to market to you and if you withdraw your consent or opt-out of marketing communications, we will keep your contact details only to ensure that we do not contact you again for marketing purposes.
5. Data subject’s rights
You have rights in respect of your personal data. We will need to confirm your identity before we can consider your request so, if you wish to exercise any of these rights, we will need appropriate photo ID and a utility bill less than 90 days old.
The right to be informed – you have the right to be told about the collection and use of the personal data you provide. This privacy policy sets out the purpose for which we process your personal data, how long we will keep your data, who we will share your data with. If you have any questions on how and why we process your data please contact the DPO. If you want to know more about this right, the ICO has more guidance on their website:https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/right-to-be-informed/
Right of access – you have the right to know whether we are processing your personal data, and to a copy of that data. We would need as much information as possible to enable us to locate your data. We will respond to your request within 28 days of receipt of your request. If you want to exercise this right, please contact the DPO at the contact details above. If you want to know more about this right, the ICO has more guidance on their website: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/right-of-access/
Right to rectification – you have the right to have any incorrect personal data corrected or completed if it is incomplete. You can make this request verbally or in writing. We will need as much information as possible to enable us to locate your data. We will look at any request and inform you of our decision within 28 days of receiving the request. If you want to exercise this right, please contact the DPO at the contact details above. If you want to know more about this right, the ICO has more guidance on their website: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/right-to-rectification/
Right to erasure – this right, often referred to as the right to be forgotten allows you to ask us to erase personal data where there is no valid reason for us to keep it. We will look at any request and inform you of our decision within 28 days of receiving the request. If you want to exercise this right, please contact the DPO at the contact details above. If you want to know more about this right, the ICO has more guidance on their website: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/right-to-erasure/
Right to restrict processing – you have the right to ask us to restrict processing of your data. We will look at any request and inform you of our decision within 28 days of receiving the request. If you want to exercise this right, please contact the DP at the contact details above. If you want to know more about this right, the ICO has more guidance on their website: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/right-to-restrict-processing/
Right to data portability – you have the right to move, copy or transfer your personal data from one IT environment to another. This right applies to data that you have provided to us and that we are processing on the legal basis of consent or in the performance of a contract and that processing is by automated means. We will respond to your request within 28 days of receipt of your request. If you want to exercise this right, please contact the DPO at the contact details above. If you want to know more about this right, the ICO has more guidance on their website:https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/right-to-data-portability/
Right to object – you have the right to object to our processing of your personal data based on (i) legitimate interests, or for the performance of a task in the public interests/exercise of official authority (including profiling); (ii) direct marketing (including profiling); and (iii) for purposes of scientific/historical research and statistics.
(i) Legitimate interests/legal task – your objection should be based on your particular situation. We can continue to process the data if we can demonstrate compelling legitimate grounds which override your interests.
(ii) Direct marketing – you have an absolute right to ask us to stop processing for the purposes of direct marketing. We will action your request as soon as possible.
(iii) Scientific/historical research and statistics - your objection should be based on your particular situation. If we are conducting research where the processing is necessary for the performance of a public task, we can refuse to comply with your objection.
If you want to exercise this right, please contact the DPO at the contact details above. If you want to know more about this right, the ICO has more guidance on their website:https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/right-to-object/
Rights relating to automated decision making including profiling – you have the right in respect of automated decision making, including profiling. Where we carry out solely automated decision making, including profiling, which has legal or similarly significant effects on you, we can only do this if it is in connection with a contract with you, we have a right under law or you have provided your explicit consent. We will tell you if this happens and tell you how you can request human intervention or challenge the decision. If you want to exercise this right, please contact the DPO at the contact details above. If you want to know more about this right, the ICO has more guidance on their website:https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/rights-related-to-automated-decision-making-including-profiling/
6. Processing based on consent
Where we process your personal data based on your consent you have the right to withdraw that consent at any time without reason. You can opt-out by using the unsubscribe/opt-out in any marketing we send you and you can contact the DPO at the contact details above.
Who do we share your personal information with?
Data, like many other products and services can be sold or licensed. When We license data to third parties We call them Clients. We work hard to ensure that We only deal with reputable Clients who like Us operate in accordance with UK Data Protection Law. We enforce this through Our contractual relationships with Our Clients in which they undertake to operate in accordance with the UK Data Protection Law and continue to enforce the rights You have. More information about those rights is set out
in this Privacy Notice. Sometimes Our Clients operate in countries outside of the European Economic Area (EEA) who operate under different data protection laws. Where this happens We enforce additional contractual provisions to ensure they provide an adequate level of protection as required by UK Data Protection Law. Here is a list of business categories in which Our Clients operate.Depending on what personal information We hold about You Our Clients may contact You by telemarketing, post or email for direct marketing, debt collection and tracing.
What do we use your personal information for? (Our purpose for processing your data)
We Use Your Personal Information to:
• Pass your details on to selected Clients who will contact You with offers and promotions; • Help other companies to profile and extend their personal databases; • Provide You with information about the products and services We offer; • Conduct market research; • To unsubscribe You from Our databases; • To add You to Our suppression file/Do not contact file; • Send You newsletters with news items and blogs from our websites including competitions and promotions; • To communicate with You about an enquiry You have made; • To make a profile of You. A profile can be created by combining third party list information with information collected by Us. This information helps us to target advertising and promotions to You; • To wealth screen You to ascertain that You are likely to have sufficient financial capability to support specific fundraising or other activity; • Help Clients who undertake online marketing to help provide online advertisements that are relevant to You. You may be contacted by post or email only.
We will share your data with the Marketing Services Providers listed below, who will use it to create products and services to help organisations better understand the likely characteristics of their customers; communicate with them more effectively; and find others like them across a range of marketing channels. This may mean that you receive advertising that is more relevant to you via direct mail/telemarketing/email or when you visit a website.
Legitimate Interest: there is a legitimate interest for ourselves and our clients in processing data to provide products and services to consumers through marketing campaigns. On a case by case basis, a balancing test is performed to ensure that we balance the potential impact of the campaign on the consumer and their rights of processing data, with the interests of ourselves and our clients.
Third parties – marketing and relationship management
Your information will be passed to TIETA UK LTD for the purposes of promotions via telephone.
Your information will be passed to BHDB Associates for the purposes of promotions via telephone regarding advice related to personal debt.
Your information will be passed to OneFamily for the purposes of promotions via telephone.
Your data will be shared with third parties where the organisation has its own legitimate interest or where they have a lawful reason for processing. Use includes tracing of individuals, verification and/or validation of the identity of individuals for the purposes of, but not limited to, anti-money laundering regulations, national security, crime prevention and detection, anti-fraud processes, asset recovery and asset reunification.
What if I don't want to receive any more information form you?
You can opt out anytime from Us holding Your Personal Information on Our database by unsubscribing on our optout page. We call this process suppression. This is standard marketing industry practice approved by the ICO and means that just enough information about you is retained to ensure that Your wishes are respected. Suppressing, rather than deleting, your details has the objective of preventing Your records being reintroduced into Our database in the future. Following suppression of your details, marketing communications should stop within a maximum period of 28 days for electronic communications and two months for postal communications.
What other rights do I have?
You have the right to withdraw consent to the processing of Your information at any time. This includes the right to withdraw processing based on legitimate interests .You have the right to be forgotten / total erasure. This gives You the right to request Your information be removed completely. We would not recommend this but would strongly suggest the action referred to above as complete erasure of your data could lead to Us loading Your information again. You have the right to know what Personal Information We hold about You on Our database. You have the right to lodge a complaint with a supervisory authority, if you are not satisfied with the way we have dealt with your complaint.
7. The right to lodge a complaint to the supervisory authority
If you are unhappy with any aspect of our handling of your data you can make a complaint to the Information Commissioner’s Office - https://ico.org.uk/concerns/
8. Statutory/contractual requirement to provide personal data.
The personal data that you provide to us is necessary for us to carry out the contract you have entered into with us.
For example, we require a valid email address in order to register and maintain an online account for you, keep you updated with system changes and any changes to our services.
We also require valid address details in order to raise invoices to you for any purchases you make with us.
We require a valid contact telephone number in order to be able to contact you in the event of an issue regarding your account.
9. Automated decision making including profiling
We do not currently undertake any automated-decision making or automated profiling that might cause us to make a decision that could impact you other than anything already covered within this Privacy Policy.
10. Cookies.
A cookie is a small piece of information sent by a web server to a web browser, which enables the server to collect information from the browser.
Please refer to our Cookie Policy for more information.
11. Third party websites.
Our website may contain links to other websites that are outside our control and are not covered by this Privacy Policy. If you access other sites using the links provided, the operators of these sites may collect information from you that will be used by them in accordance with their privacy policy, which may differ from ours.
12. Changes to the privacy policy.
This privacy policy is regularly reviewed and will be updated when necessary. If we make any significant changes to the policy we will communicate these to you. Please note that all data thus captured will be used and held in accordance with the requirements of the Data Protection Act 2018.
Crystal Data Ltd, Devonshire House, Aviary Court, Wade Road, Basingstoke, RG24 8PE
Email: accounts@crystaldata.uk
Crystal Data provides telemarketing and lead generation services to its clients.
Crystal Data is the data controller. If you have any requests concerning your personal data or any queries with regard to how we handle your data you can contact the DPO using the information provided on our Contact Us page.
Purpose of Processing
We will only process your personal data in accordance with the services we provide to you based on the contract we have, or based on your consent in relation to any marketing activities we undertake. We will collect this consent when you first provide your personal data and you can withdraw that consent at any time by contacting us using the contact information provided above or by updating your online profile, if you have created one.
Consent
For email marketing and for passing data to third parties we will use consent, this will usually be in the form of an opt-in tick box, or when you submit an email address expressly for the reason of sending marketing. We will always make it clear what your data will be used for and provide a link to our privacy policy. You can change your mind at any time.
Contract
Processing of personal data is necessary for us to administer the pre-contract and contractual relationship between ourselves and our suppliers/members in connection with the performance of a contract.
Legitimate interests
We will use legitimate interests to send occasional marketing by email, post and for segmentation and profiling in order to send relevant targeted communications. Our legitimate interests are to communicate with our customers to keep them informed, to grow our business and promote best practice in the marketing industry.
1. Marketing
We would like to use your personal data to send you details of products or services that we offer that we have identified as likely to be of interest to you. We will only send you information in line with the preferences you indicated when you provided the personal data or have updated in your online profile.
If at any point you would like to opt-out of receiving communications from us or would like to change the channels (such as email or post) that we use to contact you, please contact us using the details provided on our Contact Us page.
2. Recipients/categories of recipients
In carrying out our business including our obligations to you, we may use sub-contractors. These may be IT Network Specialists or providers of some or all of the Services that we provide to you. We will ensure that they respect your privacy and abide by all data protection laws.
3. Transfers to third countries
As part of our processing activities if we ever require to transfer your personal data to another country, we will always ensure we have a written data processing agreement with these processors to ensure the same level of data protection in the United Kingdom will apply.
4. Retention periods
We will keep your personal data in connection with the services/products you have bought for approximately 1 year after your purchase. We need to retain this data for our own accounting purposes and for legal and tax purposes.
In terms of the personal data we use for marketing, we will keep this data for as long as we are able to market to you and if you withdraw your consent or opt-out of marketing communications, we will keep your contact details only to ensure that we do not contact you again for marketing purposes.
5. Data subject’s rights
You have rights in respect of your personal data. We will need to confirm your identity before we can consider your request so, if you wish to exercise any of these rights, we will need appropriate photo ID and a utility bill less than 90 days old.
The right to be informed – you have the right to be told about the collection and use of the personal data you provide. This privacy policy sets out the purpose for which we process your personal data, how long we will keep your data, who we will share your data with. If you have any questions on how and why we process your data please contact the DPO. If you want to know more about this right, the ICO has more guidance on their website:https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/right-to-be-informed/
Right of access – you have the right to know whether we are processing your personal data, and to a copy of that data. We would need as much information as possible to enable us to locate your data. We will respond to your request within 28 days of receipt of your request. If you want to exercise this right, please contact the DPO at the contact details above. If you want to know more about this right, the ICO has more guidance on their website: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/right-of-access/
Right to rectification – you have the right to have any incorrect personal data corrected or completed if it is incomplete. You can make this request verbally or in writing. We will need as much information as possible to enable us to locate your data. We will look at any request and inform you of our decision within 28 days of receiving the request. If you want to exercise this right, please contact the DPO at the contact details above. If you want to know more about this right, the ICO has more guidance on their website: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/right-to-rectification/
Right to erasure – this right, often referred to as the right to be forgotten allows you to ask us to erase personal data where there is no valid reason for us to keep it. We will look at any request and inform you of our decision within 28 days of receiving the request. If you want to exercise this right, please contact the DPO at the contact details above. If you want to know more about this right, the ICO has more guidance on their website: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/right-to-erasure/
Right to restrict processing – you have the right to ask us to restrict processing of your data. We will look at any request and inform you of our decision within 28 days of receiving the request. If you want to exercise this right, please contact the DP at the contact details above. If you want to know more about this right, the ICO has more guidance on their website: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/right-to-restrict-processing/
Right to data portability – you have the right to move, copy or transfer your personal data from one IT environment to another. This right applies to data that you have provided to us and that we are processing on the legal basis of consent or in the performance of a contract and that processing is by automated means. We will respond to your request within 28 days of receipt of your request. If you want to exercise this right, please contact the DPO at the contact details above. If you want to know more about this right, the ICO has more guidance on their website:https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/right-to-data-portability/
Right to object – you have the right to object to our processing of your personal data based on (i) legitimate interests, or for the performance of a task in the public interests/exercise of official authority (including profiling); (ii) direct marketing (including profiling); and (iii) for purposes of scientific/historical research and statistics.
(i) Legitimate interests/legal task – your objection should be based on your particular situation. We can continue to process the data if we can demonstrate compelling legitimate grounds which override your interests.
(ii) Direct marketing – you have an absolute right to ask us to stop processing for the purposes of direct marketing. We will action your request as soon as possible.
(iii) Scientific/historical research and statistics - your objection should be based on your particular situation. If we are conducting research where the processing is necessary for the performance of a public task, we can refuse to comply with your objection.
If you want to exercise this right, please contact the DPO at the contact details above. If you want to know more about this right, the ICO has more guidance on their website:https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/right-to-object/
Rights relating to automated decision making including profiling – you have the right in respect of automated decision making, including profiling. Where we carry out solely automated decision making, including profiling, which has legal or similarly significant effects on you, we can only do this if it is in connection with a contract with you, we have a right under law or you have provided your explicit consent. We will tell you if this happens and tell you how you can request human intervention or challenge the decision. If you want to exercise this right, please contact the DPO at the contact details above. If you want to know more about this right, the ICO has more guidance on their website:https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/rights-related-to-automated-decision-making-including-profiling/
6. Processing based on consent
Where we process your personal data based on your consent you have the right to withdraw that consent at any time without reason. You can opt-out by using the unsubscribe/opt-out in any marketing we send you and you can contact the DPO at the contact details above.
Who do we share your personal information with?
Data, like many other products and services can be sold or licensed. When We license data to third parties We call them Clients. We work hard to ensure that We only deal with reputable Clients who like Us operate in accordance with UK Data Protection Law. We enforce this through Our contractual relationships with Our Clients in which they undertake to operate in accordance with the UK Data Protection Law and continue to enforce the rights You have. More information about those rights is set out
in this Privacy Notice. Sometimes Our Clients operate in countries outside of the European Economic Area (EEA) who operate under different data protection laws. Where this happens We enforce additional contractual provisions to ensure they provide an adequate level of protection as required by UK Data Protection Law. Here is a list of business categories in which Our Clients operate.Depending on what personal information We hold about You Our Clients may contact You by telemarketing, post or email for direct marketing, debt collection and tracing.
What do we use your personal information for? (Our purpose for processing your data)
We Use Your Personal Information to:
• Pass your details on to selected Clients who will contact You with offers and promotions; • Help other companies to profile and extend their personal databases; • Provide You with information about the products and services We offer; • Conduct market research; • To unsubscribe You from Our databases; • To add You to Our suppression file/Do not contact file; • Send You newsletters with news items and blogs from our websites including competitions and promotions; • To communicate with You about an enquiry You have made; • To make a profile of You. A profile can be created by combining third party list information with information collected by Us. This information helps us to target advertising and promotions to You; • To wealth screen You to ascertain that You are likely to have sufficient financial capability to support specific fundraising or other activity; • Help Clients who undertake online marketing to help provide online advertisements that are relevant to You. You may be contacted by post or email only.
We will share your data with the Marketing Services Providers listed below, who will use it to create products and services to help organisations better understand the likely characteristics of their customers; communicate with them more effectively; and find others like them across a range of marketing channels. This may mean that you receive advertising that is more relevant to you via direct mail/telemarketing/email or when you visit a website.
Legitimate Interest: there is a legitimate interest for ourselves and our clients in processing data to provide products and services to consumers through marketing campaigns. On a case by case basis, a balancing test is performed to ensure that we balance the potential impact of the campaign on the consumer and their rights of processing data, with the interests of ourselves and our clients.
Marketing Service Providers
We will share your data with the Marketing Services Providers listed below, who will use it to create products and services to help organisations better understand the likely characteristics of their customers; communicate with them more effectively; and find others like them across a range of marketing channels. This may mean that you receive advertising that is more relevant to you via direct mail or when you visit a website. To understand more please click through to the websites of the companies below:
Tieta Uk LTD
BHDB Associates LTD
OneFamily
Third parties – marketing and relationship management
Your information will be passed to Tieta UK LTD for the purposes of promotions via telephone.
Your information will be passed to BHDB Associates LTD for the purposes of promotions via telephone.
Your information will be passed to OneFamily for the purposes of promotions via telephone.
Your data will be shared with third parties where the organisation has its own legitimate interest or where they have a lawful reason for processing. Use includes tracing of individuals, verification and/or validation of the identity of individuals for the purposes of, but not limited to, anti-money laundering regulations, national security, crime prevention and detection, anti-fraud processes, asset recovery and asset reunification.
What if I don't want to receive any more information form you?
You can opt out anytime from Us holding Your Personal Information on Our database by unsubscribing on our optout page. We call this process suppression. This is standard marketing industry practice approved by the ICO and means that just enough information about you is retained to ensure that Your wishes are respected. Suppressing, rather than deleting, your details has the objective of preventing Your records being reintroduced into Our database in the future. Following suppression of your details, marketing communications should stop within a maximum period of 28 days for electronic communications and two months for postal communications.
What other rights do I have?
You have the right to withdraw consent to the processing of Your information at any time. This includes the right to withdraw processing based on legitimate interests .You have the right to be forgotten / total erasure. This gives You the right to request Your information be removed completely. We would not recommend this but would strongly suggest the action referred to above as complete erasure of your data could lead to Us loading Your information again. You have the right to know what Personal Information We hold about You on Our database. You have the right to lodge a complaint with a supervisory authority, if you are not satisfied with the way we have dealt with your complaint.
7. The right to lodge a complaint to the supervisory authority
If you are unhappy with any aspect of our handling of your data you can make a complaint to the Information Commissioner’s Office - https://ico.org.uk/concerns/
8. Statutory/contractual requirement to provide personal data.
The personal data that you provide to us is necessary for us to carry out the contract you have entered into with us.
For example, we require a valid email address in order to register and maintain an online account for you, keep you updated with system changes and any changes to our services.
We also require valid address details in order to raise invoices to you for any purchases you make with us.
We require a valid contact telephone number in order to be able to contact you in the event of an issue regarding your account.
9. Automated decision making including profiling
We do not currently undertake any automated-decision making or automated profiling that might cause us to make a decision that could impact you other than anything already covered within this Privacy Policy.
10. Cookies.
A cookie is a small piece of information sent by a web server to a web browser, which enables the server to collect information from the browser.
Please refer to our Cookie Policy for more information.
11. Third party websites.
Our website may contain links to other websites that are outside our control and are not covered by this Privacy Policy. If you access other sites using the links provided, the operators of these sites may collect information from you that will be used by them in accordance with their privacy policy, which may differ from ours.
12. Changes to the privacy policy.
This privacy policy is regularly reviewed and will be updated when necessary. If we make any significant changes to the policy we will communicate these to you.