This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data
In this policy, “we”, “us” and “our” refer to Buy Time (UK) Ltd.
How we use your personal data
In this Section we have set out: (a) the general categories of personal data that we may process; (b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data; (c) the purposes for which we may process personal data; and (d) the legal bases of the processing.
We use Google Analytics to track user activity on our Site and may process data about your use of our website and services (“usage data”). This data may include your IP address, geographical location, age range, gender, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. This usage data may be processed for the purposes of analysing the use of and optimising our Site and services. The legal basis for this processing is our legitimate interests, which are monitoring and improving our Site and services.
We usually collect and process information that you provide to us when you fill out forms on our Site, enquire about our service by email, telephone or in person (“enquiry data”). We do so for the purposes of offering, marketing and selling relevant services to you. Information that you submit may include your personal and contact details, age, gender, employment status among other details you choose to provide, and it may include Metadata. The legal basis for this processing is both our and your legitimate interests, namely taking steps to provide you with the information you have requested.
We usually collect and process information that you provide to us when you register as a subscriber to our service (“registration data”). Information that you submit may include your personal and contact details, age, gender, employment status and payment details along with other details you choose to provide. The legal basis for this processing is both our and your legitimate interests which are the performance of a contract between you and us and/ or taking steps at your request to enter into such a contract.
During the course of your use of our service you may provide us with personal data for the purposes of providing our services and communicating with you (“service data”). This may be information about you which you include in emails, letters, face-to-face meetings or telephone conversations with us. This may include “sensitive” personal information (such as information regarding your physical condition, ethnic origin, sexual orientation and religious beliefs). The legal bases for this processing is the performance of a contract between you and us.
We may process information relating to our customer relationships, including customer contact information (“customer relationship data“). The customer relationship data may include your name, your job title or role, your contact details, and information contained in communications between us and you. The customer relationship data may be processed for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications and promoting our products and services to customers. The legal basis for this processing is our legitimate interests, which are the proper management of our customer relationships.
We may process information relating to transactions, including purchases of services, that you enter into with us (“transaction data”). This data may include your contact details, your card details and the transaction details and may be processed for the purpose of supplying the purchased services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
For security purposes, we require debit/credit card details for our clients to be held in our secure payments system, SagePay. Your card details will not be used in settlement of your Buy Time invoices should you prefer to pay by Direct Debit.
We may process information that you provide to us for the purpose of subscribing to our email newsletter mailing list (“newsletter data”). This data may be processed for the purposes of sending you the relevant newsletters. The legal basis for this processing is consent.
We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, which are the proper protection of our business against risks.
In addition to the specific purposes for which we may process your personal data set out in this Section, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or to protect your vital interests or the vital interests of another natural person.
At times, we may also use your personal data for marketing and profiling. Where appropriate and practicable, we will seek your consent before undertaking some of these activities.
As a subscriber to our service, you may at times request that we process the data of third party individuals on your behalf. Further information about our role as Data Processor on behalf of our clients is available in our terms and conditions.
Providing your personal data to others
We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
We may also disclose your personal data to our suppliers, subcontractors and other third parties, insofar as you have requested or to whom disclosure is necessary and as you would expect in order for us to provide you with any service to which you have subscribed.
Financial transactions relating to our services are handled by our secure payment services providers, SagePay (for credit and debit card payments) and GoCardless (for payment by direct debit). We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers’ privacy policies and practices at www.sagepay.co.uk and https://gocardless.com/.
We may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
We may disclose your personal data in the event of the sale of the business, in which case the personal data of our customers will be one of the transferred assets.
International transfers of your personal data
We’re based in the UK but sometimes your personal information may be transferred to countries outside the European Economic Area. If we do so we’ll make sure that suitable safeguards are in place, for example by using approved contractual agreements, unless certain exceptions apply.
Our customer relationship management and mailing list servers and accounting software are based in the US at this time. The European Commission has made an “adequacy decision” with respect to the data protection laws of the US. Transfers to the US will be protected by appropriate safeguards, namely the use of the EU-US Privacy Shield approved by the European Commission, a copy of which can be obtained from https://www.privacyshield.gov/.
Our time-tracking software and the platform we use for password and/or cardholder encryption are based in Canada which The European Commission has identified as providing adequate protection
Retaining and deleting personal data
Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes. We will retain your personal data as follows:
- For as long as we have reasonable business needs, such as managing our relationship with you and managing our operations
- For as long as we provide services to you and then for as long as someone could bring a claim against us; and/or
- Retention periods in line with legal and regulatory requirements or guidance
Notwithstanding the other provisions, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
Where we store and how we protect your data
We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.
We will store all your personal data on secure servers, personal computers and mobile devices, and in secure manual record-keeping systems.
Data relating to your financial transactions that is sent from your web browser to our web server, or from our web server to your web browser, will be protected using SSL/TLS encryption technology.
You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
Using your personal data for marketing
In some cases, we rely on Soft opt-in consent to market to you. Soft opt-in consent applies where you have previously engaged with us (for example by subscribing to our services), and we are marketing other related services to you. Under ‘soft opt-in’ consent, we will take your consent as given unless or until you opt out.
For most people, this is beneficial as it allows us to keep you informed of updates to the services we’re able to provide or suggest helpful ways you might like to use our service. For other types of e-marketing, we are required to obtain your explicit consent.
We may update this policy from time to time by publishing a new version on our website.
You should check this page occasionally to ensure you are happy with any changes to this policy.
We will notify you of significant changes to this policy by email.
In this Section we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,
and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
You may exercise any of your rights in relation to your personal data by written or verbal notice to us in addition to the other methods specified in this Section. We will respond as soon as we can, and will do so within 28 days.
Third party websites
Our website includes hyperlinks to, and details of, third party websites.
We have no control over, and are not responsible for, the privacy policies and practices of third parties.
Personal data of children
Our website and services are targeted at persons over the age of 18.
At times, our clients may provide us with personal data about their children. This data may include name, address, date of birth and other information as provided by the parent-guardian and required in order for us to fulfil our services to them. The legal basis for this processing is the legitimate interests of the parent-guardian, which, for example, is to enable us to book appointments, arrange birthday parties, complete school application forms etc. We have put adequate measures in place to safeguard against any potential risks this might pose to the fundamental rights and freedoms of the child.
If we have reason to believe that we hold personal data of a person under the age of 18 our databases, other than for the reason stated above, we will delete that personal data.
Please let us know if the personal information that we hold about you needs to be corrected or updated.
Acting as a data processor
In respect of third-party data provided to us by you, we do not act as a data controller; instead, we act as a data processor.
Insofar as we act as a data processor rather than a data controller, this policy shall not apply. Our legal obligations as a data processor are instead set out in the contract between us and the relevant data controller.
A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
Cookies that we use
Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
Google Chrome https://support.google.com/chrome/answer/95647?hl=en
Mozilla Firefox https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
Internet Explorer https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies
Microsoft Edge https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy
Use of Wifi and telecommunications at our offices
The free Wi-Fi service offered within our offices is an unsecured network provided for your convenience; its use is solely at your own risk
This website is owned and operated by Buy Time UK Ltd. We are registered in England and Wales under registration number 09146272 and our registered office and principal place of business is at 27 Gloucester Place, London, W1U 8HU.
post, to the postal address given above;
by telephone on 0203 292 0566;
or by email using firstname.lastname@example.org
Data protection registration
Buy Time UK Ltd are registered as a data controller with the UK Information Commissioner’s Office under registration reference: Z242987X.