Privacy Policy

Website privacy notice


Privacy Notice

This is the privacy notice of Faces
by Vincent Ford.
In this document, "we", "our", or
"us" refer to Faces by Vincent Ford.

Our registered office is in London, United Kingdom.


This privacy notice aims to inform you about
how we collect and process any information that we collect from you, or that
you provide to us. It covers information that could identify you (“personal
information”) and information that could not. In the context of the law and
this notice, “process” means collect, store, transfer, use or otherwise act on
information. It tells you about your privacy rights and how the law protects

We are committed to protecting your privacy and
the confidentiality of your personal information. Our policy is not just an
exercise in complying with the law, but a continuation of our respect for you
and your personal information.

We undertake to preserve the confidentiality of
all information you provide to us, and hope that you

Our policy complies with the Data Protection
Act 2018 (Act).

The law requires us to tell you about your
rights and our obligations to you in regard to the
processing and control of your personal data. We do this now, by requesting
that you read the information provided at

Except as set out below, we do not share, or
sell, or disclose to a third party, any information collected through our

Data Protection Officer

We have appointed a data protection officer
(DPO) who is responsible for ensuring that our policy is followed.

If you have any questions about this privacy
notice, including any requests to exercise your legal rights, please contact our
DPO,[DPO’s first name and surname] at [e-mail

Data we process

We may collect, use, store and
transfer different kinds of personal data about you. We have collated these
into groups as follows:

Your identity includes
information such as first name, last name, title, date of birth, and other
identifiers that you may have provided at some time.

Your contact information includes
information such as billing address, delivery address, email address, telephone
numbers and any other information you have given to us for
the purpose of
communication or meeting.

financial data includes information such as your bank account and payment card

data includes details about payments or communications to and from you and
information about products and services you have purchased from us.

Technical data includes your
internet protocol (IP) address, 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.

profile includes information such as your username and password, purchases or
orders made by you, your interests, preferences, feedback and survey responses.

data includes your preferences in receiving marketing from us; communication
preferences; responses and actions in relation to your use of our services.

We may aggregate anonymous data such as statistical
or demographic data for any purpose. Anonymous data is data that does not identify
you as an individual. Aggregated data may be derived from your personal data
but is not considered personal information in law because it does not reveal
your identity.

For example, we may aggregate profile data to assess
interest in a product or service.

However, if we combine or connect aggregated data
with your personal information so that it can identify you in any way, we treat
the combined data as personal information and it will be used in accordance
with this privacy notice.

Special personal information

Special personal information is data 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.

It also includes information
about criminal convictions and offences.

We do not collect any special
personal information about you.


We may collect special
personal information about you if there is a lawful basis on which to do so.

If you do not provide personal information
we need

Where we need to collect personal data by law, or under
the terms of a contract we have with you, and you fail to provide that data
when requested, we may not be able to perform that contract. In that case, we
may have to stop providing a service to you. If so, we will notify you of this
at the time.

The bases on which we process information about you

The law requires us to determine under which of
six defined bases we process different categories of your personal information,
and to notify you of the basis for each category.

If a basis on which we
process your personal information is no longer relevant
then we shall immediately stop processing your data.

If the basis changes then if
required by law we shall notify you of the change and
of any new basis under which we have determined that we can continue to process
your information.

Information we process because we
have a contractual obligation with you

When you create an account on our website, buy a
product or service from us, or otherwise agree to our terms and conditions, a
contract is formed between you and us.

In order to carry out our
obligations under that contract we must process the information you give us.
Some of this information may be personal information.

We may use it in order to:

verify your identity for security purposes

sell products to you

provide you with our services

provide you with suggestions and advice on
products, services and how to obtain the most from using our website

We process this information on the basis there is a
contract between us, or that you have requested we use the information before
we enter into a legal contract.

We shall continue to process this information until
the contract between us ends or is terminated by either party under the terms
of the contract.

Information we process with your

Through certain actions when otherwise there is no
contractual relationship between us, such as when you browse our website or ask
us to provide you more information about our business, including [job opportunities and] our products and services,
you provide your consent to us to process information that may be personal

Wherever possible, we aim to obtain your explicit
consent to process this information, for example, by asking you to agree to our
use of cookies.

If you have given us explicit permission to do so,
we may from time to time pass your name and contact information to selected
associates whom we consider may provide services or products you would find

We continue to process your information on this
basis until you withdraw your consent or it can be
reasonably assumed that your consent no longer exists.

You may withdraw your consent at any time by
instructing us [at email address or webpage]. However,
if you do so, you may not be able to use our website or our services further.

Information we process for the
purposes of legitimate interests

We may process information on the basis there is a
legitimate interest, either to you or to us, of doing so.

Where we process your information on this basis, we
do after having given careful consideration to:

whether the same objective could be achieved
through other means

whether processing (or not processing) might
cause you harm

whether you would expect us to process your data,
and whether you would, in the round, consider it reasonable to do so

For example, we may process your data on this basis
for the purposes of:

record-keeping for the proper and necessary
administration of our [organisational or business]

responding to unsolicited communication from you
to which we believe you would expect a response

protecting and asserting the legal rights of any

insuring against or obtaining professional
advice that is required to manage [organisational or business]

protecting your interests where we believe we
have a duty to do so

Information we process because we
have a legal obligation

Sometimes, we must process your information in order to comply with a statutory obligation.

For example, we may be required to give information
to legal authorities if they so request or if they have the proper
authorisation such as a search warrant or court order.

This may include your personal information.

Specific uses of information you provide to us

Information provided on the
understanding that it will be shared with a third party

Our website allows you to post information with a
view to that information being read, copied, downloaded, or used by other

Examples include:

posting a message our forum

tagging an image

clicking on an icon next to another visitor’s
message to convey your agreement, disagreement or thanks

In posting personal information, it is up to you to
satisfy yourself about the privacy level of every person who might use it.

We do not specifically use this information except to allow
it to be displayed or shared.

We do store it, and we reserve a right to use it in
the future in any way we decide.

Once your information enters the public domain, we
have no control over what any individual third party may do with it. We accept no
responsibility for their actions at any time.

Provided your request is reasonable and there is no
legal basis for us to retain it, then at our discretion we may agree to your
request to delete personal information that you have posted. You can make a request
by contacting us at [email address or webpage].

Complaints regarding content on our

Our website is a publishing medium. Anyone may register and
then publish information about himself, herself or some other person.

We do not moderate or control what is posted.


We attempt to moderate user generated content, but we are
not always able to do so as soon as that content is published.

If you complain about any of the content on our
website, we shall investigate your complaint.

If we feel it is justified or if we believe the law
requires us to do so, we shall remove the content while we investigate.

Free speech is a fundamental right, so we have to make a judgment as to whose right will be
obstructed: yours, or that of the person who posted the content that offends

If we think your complaint is vexatious or without
any basis, we shall not correspond with you about it.

Information relating to your method
of payment


We store
information about your debit or credit card or other means of payment when you
first provide it to us.

We store
this payment information [at your request] in order to
make repeat purchasing of goods and services easier next time you visit our

[We also
store it to help us prevent fraud.]

We take
the following measures to protect your payment information:

We keep your payment
information encrypted on our servers.

We do not keep all your
payment information so as:

to prevent the
possibility of our duplicating a transaction without a new instruction from

to prevent any other
third party from carrying out a transaction without your consent

Access to your payment
information is restricted to authorised staff only.

If we ask you questions
about your payment information, we only show [partial detail OR the first four
OR the last four digits of the debit or credit card number], so that you can
identify the means of payment to which we refer.


automatically delete your payment information [after X days OR when a credit or
debit card expires].


information is never taken by us or transferred to us either through our
website or otherwise. Our employees and contractors never have access to it.

At the
point of payment, you are transferred to a secure page on the website of
[WorldPay / SagePay / PayPal / MoneyBookers
/ Stripe] or some other reputable payment service provider. That page may be
branded to look like a page on our website, but it is not controlled by us.

Information about your direct debit

When you agree to set up a direct debit arrangement,
the information you give to us is passed to our own bank [name of bank] for processing according to our
instructions. We [do / do not] keep a copy.

[We keep this information
only for the duration of the direct debit arrangement.]

We are registered under the direct debit guarantee
scheme. This provides for the customer’s bank to refund disputed payments
without question, pending further investigation. Direct debits can only be set
up for payments to beneficiaries that are approved originators of direct
debits. In order to be approved, these beneficiaries
are subjected to careful vetting procedures. Once approved, they are required
to give indemnity guarantees through their banks.

Job application and employment

If you send us information in connection with a job
application, we may keep it for up to [three years] in
case we decide to contact you at a later date.

If we employ you, we collect information about you
and your work from time to time throughout the period of your employment. This information
will be used only for purposes directly relevant to your employment. After your
employment has ended, we will keep your file for [six
before destroying or deleting it.

Communicating with us

When you contact us, whether by telephone, through
our website or by e-mail, we collect the data you have given to us in order to reply with the information you need.

We record your request and our reply in order to increase the efficiency of our [business / organisation].

We do not keep any personally identifiable information
associated with your message, such as your name or email address.


We keep personally identifiable information associated with
your message, such as your name and email address so as to be able to track our
communications with you to provide a high quality


When we receive a complaint, we record all the
information you have given to us.

We use that information to resolve your complaint.

If your complaint reasonably requires us to contact some
other person, we may decide to give to that other person some of the
information contained in your complaint. We do this as infrequently as
possible, but it is a matter for our sole discretion as to whether we do give
information, and if we do, what that information is.

We may also compile statistics showing information
obtained from this source to assess the level of service we provide, but not in
a way that could identify you or any other person.

Affiliate and business partner

This is information given to us by you in your
capacity as an affiliate of us or as a business partner.

It allows us to recognise visitors that you have
referred to us, and to credit to you commission due for such referrals. It also
includes information that allows us to transfer commission to you.

The information is not used for any other purpose.

We undertake to preserve the confidentiality of the
information and of the terms of our relationship.

We expect any affiliate or partner to agree to
reciprocate this policy.

Use of information we collect through automated systems when you visit our


Cookies are small text files that are placed on your
computer’s hard drive by your web browser when you visit any website. They
allow information gathered on one web page to be stored until it is needed for
use on another, allowing a website to provide you with a personalised
experience and the website owner with statistics about how you use the website
so that it can be improved.

Some cookies may last for a defined period of time, such as one day or until you close your
browser. Others last indefinitely.

Your web browser should allow you to delete any you
choose. It also should allow you to prevent or limit their use.

Our website uses cookies. They are placed by
software that operates on our servers, and by software operated by third
parties whose services we use.

When you first visit our website, we ask you whether you
wish us to use cookies. If you choose not to accept them, we shall not use them
for your visit except to record that you have not consented to their use for
any other purpose.

If you choose not to use cookies or you prevent their use
through your browser settings, you will not be able to use all the
functionality of our website.

We use cookies in the following ways:

to track how you use our website

to record whether you have seen specific
messages we display on our website

to keep you signed in to our website

to record your answers to surveys and
questionnaires on our site while you complete them

to record the conversation thread during a live
chat with our support team

[We provide more information about the cookies we use in our
cookie policy].

Personal identifiers from your
browsing activity

Requests by your web browser to our servers for web
pages and other content on our website are recorded.

We record information such as your geographical
location, your Internet service provider and your IP address. We also record
information about the software you are using to browse our website, such as the
type of computer or device and the screen resolution.

We use this information in aggregate to assess the
popularity of the webpages on our website and how we perform in providing
content to you.

If combined with other information we know about you
from previous visits, the data possibly could be used to identify you
personally, even if you are not signed in to our website.                    

Our use of re-marketing

Re-marketing involves placing a cookie on your
computer when you browse our website in order to be
able to serve to you an advert for our products or services when you visit some
other website.

We may use a third party to provide us with
re-marketing services from time to time. If so, then if you have consented to
our use of cookies, you may see advertisements for our products and services on
other websites.

Disclosure and sharing of your information

Information we obtain from third

Although we do not disclose your personal
information to any third party (except as set out in this notice), we sometimes
receive data that is indirectly made up from your personal information from
third parties whose services we use.

No such information is personally identifiable to you.

Third party advertising on our

Third parties may advertise on our website. In doing
so, those parties, their agents or other companies working for them may use
technology that automatically collects information about you when their
advertisement is displayed on our website.

They may also use other technology such as cookies
or JavaScript to personalise the content of, and to measure the performance of
their adverts.

We do not have control over these technologies or
the data that these parties obtain. Accordingly, this privacy notice does not
cover the information practices of these third parties.

Credit reference

To assist in combating fraud, we share information
with credit reference agencies, so far as it relates to clients or customers
who instruct their credit card issuer to cancel payment to us without having
first provided an acceptable reason to us and given us the opportunity to
refund their money.

Data may be processed outside the
European Union

Our websites are hosted in [country].

We may also use outsourced services in countries
outside the European Union from time to time in other aspects of our business.

Accordingly data obtained
within the UK or any other country could be processed outside the European

We use the following safeguards with respect to data
transferred outside the European Union:

the processor is within
the same corporate group as our business or organisation and abides by the same
binding corporate rules regarding data processing.

the data protection
clauses in our contracts with data processors include transfer clauses written
by or approved by a supervisory authority in the European Union [, specifically
that in the country of …].

we comply with a code
of conduct approved by a supervisory authority in the European Union [,
specifically that in the country of …].

we are certified under
an approved certification mechanism as provided for in the Act.

both our organisation
and the processor are public authorities between whom there is either a legally
binding agreement or administrative arrangements approved by a supervisory
authority in the European Union relating to protection of your information.

Control over your own information

Your duty to inform us of changes

It is important that the personal data we hold about
you is accurate and current. Please keep us informed if your personal data

Access to your personal information

At any time you may review or update personally identifiable
information that we hold about you, by signing in to your account on our

To obtain a copy of
any information that is not provided on our website you should contact us to
make that request.

After receiving the
request, we will tell you when we expect to provide you with the information,
and whether we require any fee for providing it to you.

Removal of your information

If you wish us to remove personally identifiable
information from our website, you should contact us to make your request.

This may limit the service we can provide to you.

Verification of your information

When we receive any request to access, edit or delete
personal identifiable information we shall first take reasonable steps to
verify your identity before granting you access or otherwise taking any action.
This is important to safeguard your information.

Other matters

Use of site by children

We do not sell
products or provide services for purchase by children, nor do we market to

If you are under 18,
you may use our website only with consent from a parent or guardian

areas of our website are designed for use by children over [15] years of age.
These areas include [description or name or areas designed for children].

collect data about all users of and visitors to these areas regardless of age,
and we anticipate that some of those users and visitors will be children.

child users and visitors will inevitably visit other parts of the site and will
be subject to whatever on-site marketing they find, wherever they visit.

Encryption of data sent between us

We use Secure Sockets Layer (SSL) certificates to verify our
identity to your browser and to encrypt any data you give us.

Whenever information is transferred between us, you can
check that it is done so using SSL by looking for a closed padlock symbol or
other trust mark in your browser’s URL bar or toolbar.

How you can complain

If you are not happy
with our privacy policy or if you have any complaint
then you should tell us.

[You can find further information about our complaint
handling procedure at webpage URL]

If a dispute is not settled then we hope you will agree to attempt to resolve it
by engaging in good faith with us in a process of mediation or arbitration.

If you are in any way
dissatisfied about how we process your personal information, you have a right
to lodge a complaint with the Information Commissioner’s Office (ICO). This can
be done at
We would, however, appreciate the opportunity to talk to you about your concern
before you approach the ICO.

Retention period for personal data

Except as otherwise mentioned in this privacy
notice, we keep your personal information only for as long as required by us:

to provide you with the services you have

to comply with other law, including for the
period demanded by our tax authorities;

to support a claim or defence in court.   

Compliance with the law

Our privacy policy has been compiled so as to comply with the law of every country or legal
jurisdiction in which we aim to do business. If you think it fails to satisfy
the law of your jurisdiction, we should like to hear from you.

However, ultimately it is your choice as to whether
you wish to use our website.

Review of this privacy policy

We may update this privacy notice from time to time
as necessary. The terms that apply to you are those posted here on our website
on the day you use our website. We advise you to print a copy for your records.

If you have
any question regarding our privacy policy, please contact us.

Explanatory notes

Privacy policy notice

General notes

In the UK, the rights and
obligations regarding protection of an individual’s personal information are
written in the Data Protection Act 2018.

The requirements under the Act
are similar in extent to prior data protection law in the UK. If your business
complies with prior law, then the changes you need to make are likely to be

The possible implications
for non-compliance are now much more severe. In theory, the Information
Commissioner’s Office (the ICO) has the power to fine a business 4% of its annual
worldwide turnover.

However, regarding selling
to consumers we believe that the ICO in practice is unlikely to fine many small
businesses and organisations without having first given a warning. Having a
privacy notice (such as one based on this template) that shows some effort to
comply with the law is likely, in our opinion, to generate enough goodwill with
the ICO to avoid a fine in the first instance.

Updating your website
privacy notice is not the only requirement for compliance with the Act. You are
also likely to need to change how customers and visitors can access personal
data held about them, and create new procedures for
obtaining compliance to collect and use personal data.

You may also need to update
other legal documents, in particular, your website
terms and conditions. Free versions of these are also available from our

More information can be
found at:

Using this template as the basis for your privacy notice

Your privacy policy should
be concise (while also being comprehensive), transparent, easy to understand
and easily accessible.

We aim to balance those
qualities in this document. However, we cannot know exactly how your business
works, so you may need to edit the document significantly in certain places.

We offer this template free
as an example of a Net Lawman document. We hope that you like it, and that you
may buy other documents and services from us in the future.

Regardless of the price, we
assert our copyright in the document. Our standard licence terms apply. While
you may not distribute the template without including our copyright, you may remove our copyright notice from
the version you edit and use

In addition to these
paragraph specific guidance notes to help you edit the template, we also
publish a free, more general guide to editing our legal documents, which you
can download at:
Legal Document Templates.pdf

If you have any questions,
please contact us at

Paragraph specific notes

Numbered notes refer to specific numbered paragraphs in the

Identification of the
owner of the website

The Act requires that you identify the business or the
organisation that operates the website. Using the domain name as the business
name is not enough. You need to provide a business or organisation name and an

In practice, you may decide that you do not want to provide
your name and address (for your own privacy reasons). You may be more likely to
get away with doing this if you don’t trade from your website.

If you have appointed a data protection officer, you should
name that person here using words such as “Our Data Protection Officer is [Name]”. Most businesses or organisations that use
this template will not be large enough to require one.


Leave these items in place unless there is a good reason to
edit or remove. Each of these items has been carefully considered in the
context of this document and has been included for a purpose.

The first paragraph sets out the purpose of the document and
explains terms used throughout it.

The second and the third paragraphs aim to reassure readers that
you take privacy seriously.

The fourth paragraph demonstrates awareness of the Act and

A key requirement of the law is that you tell your visitors
and customers that they have rights with respect to how their personal
information is processed. Rather than cluttering your privacy notice with an
explanation of their rights, we recommend referring your visitors to this
explanatory website.

1        Data protection officer

Unless your organisation processes large volumes of personal
information, you are unlikely to be required to appoint a data protection

If you have nominated an individual, you may mention him or her
in this paragraph.

Otherwise, you can delete this section.

2        Data we process

The Act only applies to personal data.

Any of these paragraphs can be deleted or edited, although
the ones in blue are most likely to be those that either do or don’t apply.

3        Special personal information

If you process certain types of personal information, you
are required to disclose that you do so.

Use either the first two sentences or the last one.

4        If you do not provide the personal
information we need

This is a reminder to your customer or visitor that you may
not be able to provide services if you are not given information.

The bases on which we
process information about you

A requirement of the Act is that you tell the data subject why
you process the data and which legal basis you have chosen to use as the
justification to process his or her data.

Most websites will process different types of data on different
bases. The two most likely to apply are “Contract” (after the visitor has
accepted your terms and conditions) and “Consent” (after the visitor has agreed
to your use of his or her data – usually by taking some affirmative action such
as clicking on a button). Some data may also be processed because of a legal
requirement or a legitimate interest.

All the bases are described at:

The reasons why you process the data arise as
a result of
the basis. If there is a contract, there is a contractual
obligation to carry out the service. If the basis is consent, then there will
probably be some benefit to the data subject of you using the information.

You may want to edit these sections in minor ways (certainly
where we have highlighted in blue).

More importantly, you should make design changes to how your
website works so as to obtain explicit consent, or
have a visitor agree to your terms earlier in your relationship.

For most websites, contract
is the strongest basis for processing. If you can design your website
experience such that a visitor agrees to your terms early on, before providing
personal information, you will have fewer grounds for complaints. For example,
you might reduce the requirement to provide detailed information when a visitor
registers a basic account on your website, but place
more content or functionality in an area of the website that requires the
visitor to have such an account. At the registration point, the visitor must
tick a box to say that he or she has read and agrees to your terms and

If you are relying on
consent, then you might design a banner to appear when a visitor first arrives
at your site (for example, encouraging him or her to read your cookies policy).
That banner might have two buttons – one that gives explicit agreement and one
that doesn’t. If the visitor does not give explicit consent, then you redirect
him or her to another “safe” website or state that certain functionality will
be limited.

Positive action needs to be
taken by the visitor when agreeing to anything – pre-ticked boxes or close
buttons don’t count as affirmative action.

Legitimate Interests is a
basis that is fairly subjective. For it to be used,
you must have decided that there is a legitimate interest, that processing the
data is necessary to protect that interest, and that the data subject’s
interests (or other interests) do not override it. In some circumstances, it is
most appropriate, but if possible, we would recommend using Contract or Consent
as better alternatives. The reason is simply that the data subject is less
likely to complain if he or she has clearly asked you to process his or her

Data subjects have a legal
right to see the personal information you hold about them. You need both an
internal process as to how to provide this, and a means for the data subject to
request the information.

If the data subject is a
registered visitor, then providing his or her data in an account area is a good
way of providing this data. You can also provide a way of giving consent to use
of the data in the same place.

If the data subject does not
have an account, then you should give either an e-mail address or a physical
address to which the data subject can send a request for his or her

Lastly, for each basis you
need to state when you stop processing the data. We suggest that you don’t edit
our text.

Specific uses of
information you provide to us

This section provides more
information about specific types of information. The paragraphs within it are
as much designed to reassure a visitor reading your policy than to aid
compliance with the law.

9        Information
provided on the understanding that it will be shared with a third party

This paragraph serves as a reminder that information
that a visitor posts on your website may be available for public viewing, and
that you cannot be held responsible if someone else copies it and uses it
without the author’s permission.

It creates a licence for you to use it in any way
you wish, which may be useful.

You should provide a way for someone to contact you
and request that content is removed. This could be as simple as an e-mail

10       Complaints
regarding content on our website

This paragraph is a reminder to visitors that
moderation of all user generated content is not always viable.

It shows that you take complaints about content
seriously, and also that a decision to remove content
remains with you.

11       Information relating to
your method of payment

There are two options here. Delete whichever is not

The first covers the situation where you do record
card information. You should edit the “measures to protect your information” so
that they are relevant to your business.

The second covers the situation where card
information stays with the payment service provider.

If you don’t take payment at all, of course delete
this paragraph completely.

12       Information about your
direct debit

If you do not take payment by direct debit, delete
this paragraph. Otherwise edit the wording in blue appropriately.

13       Job application and

The purpose of this paragraph is to set out for how
long personal information is processed. It is a requirement of the Act.

14       Communicating with us

We suggest you keep this paragraph in your notice.
However, you should edit it to suit how your organisation works.

15       Complaining

This paragraph deals with how information collected as a result of a complaint is used. It should not be
confused with an explanation of how to complain (which is dealt with later). We
suggest you leave this paragraph as is.

16       Affiliate and business
partner information

Information relating to affiliates is not subject to
the Act. This paragraph should reassure business partners.

17       Cookies

The start of this paragraph is an explanation of
what cookies are.

It is good practice to display a message when a
visitor first comes to your website asking whether he or she accepts use of
cookies. The paragraph in blue supports this.

We take the approach here of not listing every
single cookie.

The reason is that you not know this information
yourself, especially if you use third party add-ons or plug-ins to your
website. For example, Google provides visitor tracking software (Analytics)
that is popular. It could at any point change the name or purpose of the many
cookies it uses without telling you.

There are so many cookies that software you use is
likely to place that to list them here would increase the size and complexity
of the notice, and to keep the notice up-to-date as they change would be time

Listing every cookie’s file name, purpose and
expiration period could be done in a separate cookie notice, linked from this

We prefer the approach of explaining in what ways
they are used. Add or delete to this list as appropriate.

18       Personal identifiers from
your browsing activity

Most web servers log requests for pages. We suggest
you leave this paragraph as is, even if you don’t use this information.

19       Our use of re-marketing

Re-marketing is the name given to the practice of
advertising your products and services on third party websites based on pages
on your website that the visitor has already seen.

It requires you as the website owner to be the
client of an advertising service provider.

When a visitor visits a page of your website, the
advertiser’s software through your website places a cookie on the visitor’s
computer. When he or she visits another webpage on a third
website, you can choose whether or not to pay to show him or her
an advert for your product or service.

For example, you might sell fruit from your website.
A visitor visits a page about the health benefits of eating a particular tropical fruit. Later, the same visitor visits
another website about cookery, and specifically a page that describes a recipe
that requires the tropical fruit. Both your website and the cookery website use
the same advertising service provider. You can choose to pay to have your
adverts for that tropical fruit to be displayed on the cookery website.

The advertising service provider usually allows you
to specify exactly what criteria must be met in order to display your advert,
making re-marketing a cost efficient way of

Some people feel very strongly about re-marketing.
It can elicit fears of “being followed around the web”, particularly if the
topic of the advert is sensitive.

You can choose to delete this paragraph entirely if
you do not use re-marketing. However, keeping it in place will allow you to
experiment with different types of display marketing later.

Disclosure and
sharing of your information

20       Information we obtain
from third parties

This paragraph is a reminder to visitors that you
may use third party information provision services. Delete if not appropriate
to your organisation.

21       Third party advertising
on our website

Delete if not appropriate to your organisation.

22       Credit reference

We suggest that you leave this paragraph in place
even if you have no immediate intention of liaising with debt collectors. It
may be a useful “reminder” to users of your website.

23       Data may be processed outside the
European Union

It is a legal requirement to tell the visitor if his
or her information is processed outside the EU. It is especially important if
you have your own business operations outside the EU.

If you want to be as compliant as possible, you
should also identify carefully whether you use services outside the EU. You may
use, for example, a US-based online software service to provide your chat

In practice, it might be very difficult to identify
exactly where software has been written, whether the software house processes
your data in any way, and where this might take place.

The clause giving examples (in blue) could be
deleted entirely if you don’t want possibly to mislead readers.

The safeguards (bullet points at the end of the
paragraph) seem verbose, but are copied verbatim from
the legislation. Choose the most appropriate (one, maybe two) and delete the

Control over your own

Under the Act, a data subject has a right to access
information about him or her, and a right for that information to be kept
up-to-date and only for as long as required.

You should leave these three paragraphs in place, editing
the addresses.

Other matters

28       Use of site by children

Under UK law, you cannot form a contract with a
child. So a child cannot agree to your terms and
conditions, which means that he or she cannot agree to your terms regarding use
of his or her information. Additionally, only a parent or guardian can give

So it is very difficult to
have a lawful basis for processing personal information about children.

Additionally, personal information about children is
regarded as more sensitive than the same information about an adult. The
consequences for data breaches could be much greater.

We suggest you edit this paragraph to suit your
website and keep it in.

29       Encryption of data sent between us

This paragraph is included to reassure visitors. If
you do not use SSL then remove the paragraph.

30       How you can complain

This paragraph sets out standard wording that tells
visitors how to make a complaint.

It gives you a stronger argument to use arbitration
or mediation as a means of resolving a complaint, rather than going to court.

In any case, you must tell visitors to your site
about their right to complain to the supervisory body, the Information
Commissioner’s Office.

31       Retention period for personal data

It is a requirement of the Act to tell data subjects
for how long personal information will be kept. This paragraph is a catch-all
if the information is not provided elsewhere.

Basic UK law relating to limitation for bringing a
claim, contract matters, tax and other areas often requires data to be retained
for six years. You will be “safe” if you specify that period for commercial

32       Compliance with the law

Leave this paragraph in place.

33       Review of this privacy policy

Leave this paragraph in place.


We may amend this Privacy Policy from time to time. When we amend this Privacy Policy, we will update this page accordingly and require you to accept the amendments in order to be permitted to continue using our services.