Privacy
Policy

Personal data, or personal information, means any information about an individual from which that person can be identified.

We may collect and process the following data about you:

• Identity data: name, gender, date of birth and nationality;
• Contact data: postal address, email address and telephone number;
• Employment/Corporate data: current employer or owned business/businesses, industry;
• Financial data: payment card details (should you transact with us); and
• Technical and usage data: 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.

We may collect this information from you when you:

• engage with us to provide you with our products and services and those of affiliated third-parties’;
• engage with us to receive relevant information and updates on our projects, products and services and those of our affiliated third parties;
• complete our online or paper data collection forms, including those relating to marketing communications;
• use our applications, wifi channels and other products/services, or communicate any problems with the same;
• provide your information to use while attending a sales or other promotions event;
• contact us via email, mail or telephone;
• transact with us; or
• give us feedback or otherwise contact us.

As you interact with our website, we will also automatically collect the technical and usage data noted above about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.

What are cookies?

We may collect information using “cookies.” Cookies are small data files stored on the hard drive of your computer or mobile device by a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience on our site/application(s)/services.

We use two broad categories of cookies: (1) first party cookies, served directly by us to your computer or mobile device, which are used only by us to recognise your computer or mobile device when it revisits our website/application(s)services; and (2) third party cookies, which are served by service providers on our website/application(s)/services, and can be used by such service providers to recognise your computer or mobile device when it visits other websites.

Cookies we use

Our website/application(s)/services use the following types of cookies for the purposes set out below:

• Essential cookies: These cookies are essential to provide you with services available through our website/application(s)/services and to enable you to use some of its features. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.
• Functionality cookies: These cookies allow our website/application(s)/services to remember choices you make when you use our website/application(s)/services, such as remembering your language preferences, remembering your login details and remembering the changes you make to other parts of our website/application(s)/services which you can customize. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you visit our website/application(s)/services.
• Analytics and performance cookies: These cookies are used to collect information about traffic to our website/application(s)/services and how users use our website/application(s)/services. The information gathered does not identify any individual visitor. We use this information to help operate our website/application(s)/services more efficiently, to gather broad demographic information and to monitor the level of activity on our website/application(s)/services. We use Google Analytics for this purpose. Google Analytics uses its own cookies. It is only used to improve how our website/application(s)/services works. You can find out more information about Google Analytics cookies here: https://developers.google.com/analytics/resources/concepts/gaConceptsCookies. You can find out more about how Google protects your data here: www.google.com/analytics/learn/privacy.html. You can prevent the use of Google Analytics relating to your use of our website/application(s)/services by downloading and installing the browser plugin available via this link: http://tools.google.com/dlpage/gaoptout?hl=en-GB
• Targeted and advertising cookies: These cookies track your browsing habits to enable us to show advertising which is more likely to be of interest to you. These cookies use information about your browsing history to group you with other users who have similar interests. Based on that information, and with our permission, third party advertisers can place cookies to enable them to show adverts which we think will be relevant to your interests while you are on third party websites.

Disabling Cookies

You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings,” “help” “tools” or “edit” facility). Many browsers are set to accept cookies until you change your settings.

Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.com.uk.

If you do not accept our cookies, you may experience some inconvenience in your use of our website/application(s)/services. For example, we may not be able to recognise your computer or mobile device and you may need to log in every time you visit our website/application(s)/services.

We use your personal data for the following reasons:

• to engage with you to assess and discuss your potential interest in our products, projects and/or services;
• to better understand your interests and needs in order to allow us to design, tailor and/or improve our products, projects and/or services;
• to send you marketing materials and other similar communications about our own or affiliated or related third-parties’ products, projects and services that may be of interest to you;
• to speed up and tailor your preferred searches on our website;
• to provide you with our products or services;
• to respond to any of your queries; and/or
• in order to ensure compliance with prevailing applicable laws and regulations by employing recommended security practices.

We only process your personal data when it is lawful for us to do so. We rely on the following lawful grounds to process your personal data:

• consent of the data subject, particularly in relation to marketing communications;
• performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract;
• compliance with a legal obligation to which we are subject; and
• legitimate interests pursued by us, as the controller, or by a third party.

Our legitimate interests include the interests of ours as a business in conducting and managing our business to enable us to provide you with our products, projects and services and those of affiliated third-parties.

We take your privacy very seriously and work hard to protect your data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We have put in place appropriate security measures to prevent this from happening. In addition, we limit access to your personal data to those employees, volunteers, agents, contractors and other third parties who have a need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent your data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

We will only retain your personal data for as long as reasonably 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.

We may share your personal data in the following scenarios:

• We may share your personal data with our group companies and affiliates.
• We may share your personal data with your consent.
• We may share your personal data with certain service providers to help us provide the best services to you and others.
• We may share your personal data if we are required to respond to law enforcement, officials, regulatory agencies and other lawful requests or legal processes, or to comply with a legal obligation to which we are subject.

As we are based outside the European Union, your personal information will be transferred and stored outside the European Union where data protection and privacy regulations may not offer the same level of protection as in other parts of the world. We will however take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

In certain circumstances, you may have the right to:

• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in certain scenarios.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format.
• Withdraw consent at any time where we are relying on consent to process your personal data.
• Complain to a data protection authority for any data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach a data protection authority so please contact us in the first instance.

To exercise one of the above rights, please contact us using the details provided above.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

This website may include links to third-party websites, plug-ins and applications, for example on our news page. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

We keep our policies and practices under review in accordance with applicable laws and this Privacy Policy was last updated on the date given above.

We reserve the right in our discretion to change without prior warning or notice our Privacy Policy and practices, and any information or material contained on our website and any mobile applications related thereto, under which our products and services are used and offered. You are responsible for periodically visiting our website and this Privacy Policy for any policy changes. Please note that should we wish to process your personal data in a manner not foreseeable in this Privacy Policy, we will contact you in advance of doing so.