For the purpose of this Privacy Policy and the Data Protection Act 1998, Orwell Independent Ltd., registered at Fulford House, Newbold Terrace, Leamington Spa, Warks, CV324EA, company number: 14337675, is the ‘data controller’.
Questions regarding this privacy policy should be directed to OrwellIndependent via our contact form on our website or via email info@orwellindependent.co.uk
Our primary goal in collecting personal information from you is to provide you with a smooth, efficient, and personalised experience while using our services, and to customise our service to make your experience easier and quicker.
We obtain personal data about you, for example, when:
· you request information about the services we provide;
· you engage us to provide services and also in the course of providing those services;
· you contact us via, including but not limited to; email, telephone, messenger service, or social; or
· we transact with third party provider and/or publicly available resources
The data we hold may include:
· personal details such as name, address, phone number, email address
· details of communication in relation to enquiries or the provision of services
· details of provision of services
· details about any complaints
· details related to any surveys that we have carried out per your instructions
· information generated from marketing activities
· information from other sources, for example your employer or subsidiary, or publicly available sources
We will only use your personal data where there is a justifiable and reasonable business and lawful reason to do so. There maybe more than one, and these may include:
· to fulfil provision of such services as have been requested of us, whether you are client, or customer or subcontractor of our client
· to provide you with information that we feel will interest you, as long as you have given us consent to do so.
· to ask for feedback or comments relating to our services or our website
· if we are legally required to do so
There may be other examples where we may wish or need to use or process you personal data but we will seek your consent, and youare able to withdraw that consent at any time. Our legitimate reasons to process your personal data may not compromise or supersede your own priorities around privacy of personal data.
Data will only be held as long as is necessary.When reviewing data retention periods we will consider;
· what we collected and why we originally collected it
· what the lawful reasons to collect it were
· whether the business case for collecting and processing it have been satisfied
· the level of detail and categorisation of the data we collected
In the unlikely event we need to process your data for a reason other than that which we initially collected it, we will contact you to explain the new justification before proceeding.
We may share your data in order to fulfil our business obligations to you, where we are lawfully required to do so, or if there is another legitimate reason for doing so. These may include;
· Web-hosting platforms (e.g. Webflow)
· IT & cloud services (e.g. Google)
· Survey/engagement tools (e.g. Survey Monkey)
· Telecoms/messenger services (e.g. WhatsApp)
· External accountancy (services to Orwell Independent Ltd.)
We only use the services of providers who are recognised as market leaders in their field, but some are located outside the EEA. This includes but is not limited to the following organisations. All of these organisations have subscribed to theEU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework
With regard to each of your visits to our sites and applications, we use a web analytics tool to analyse site usage, how our users arrive at our site, what they do on the site, what browser they are using and on what operating system etc. However, this analytics data, collected via a JavaScript tag in the pages of our site, is not tied to personally identifiable information. We use Google Analytics (http://www.google.com/analytics/) for this purpose.
Other reasons we may have to share your personal data with third partiesmay include;
· the optimisation of our site(for example Google for the purpose of its Google Analytics service);
· if we sell or buy any business or assets, in which case we may need to disclose your personal information to the prospective parties;
· if Orwell is acquired by a third party, in which case personal information held by it about its customers will be one of the transferred assets; and if we are under a duty to disclose or share your personal information in order to comply with any legal obligation, for example investigation of fraud, Intellectual Property Rights infringements, or other activity that is illegal or may expose us to legal liability
· in order to enforce or applyAcceptable Use Policy
· Terms and Conditions and other agreements; or to protect our rights, property, or safety or those of our customers or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
You have the following rights in respect of the personal data held by us;
· Right to erasure, where there is no justifiable reason for us to hold it (or in relation to an upheld objection; see below)
· Right to access, to check what we are holding and are holding it lawfully
· Right to correction
· Right to object to the way we are processing your data
· Right to restrict the procession of your data, pending changes related to other rights, e.g. correction
· Right to transfer the information to you
· Right to withdraw consent (for example for a request to use your personal data in a marketing exercise that we have contacted you to receive consent for)
If you wish to exercise any of these rights please contact us via the website or by email at info@orwellindependent.co.uk
We are committed to ensuring that your information is secure. However, transmission of information via the internet is not completely secure. We do our best to protect your personal data, but we cannot guarantee the security of your data transmitted to our sites. Any transmission is at your own risk.
The data that we collect from you will be typically transferred to, and stored at, a destination inside the European Economic Area (“EEA”). It will also be processed by staff operating inside the EEA who work for us or for one of our suppliers. This includes staff engaged in, among other things, the provision of support services.
Where we need to transfer and store your data outside the EEA, we will do so only where we have assessed that equivalent data protection measures are in place. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.
Where we have given you (or where you have chosen) a password which enables you to access certain parts of our sites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
We use cookies on our site. Cookies make the interaction between users and websites faster and easier. Websites use cookies mainly because they save time and make the browsing experience more efficient and enjoyable. You can find more information about cookies here http://www.aboutcookies.org.
You can disable specific Cookies using the links at the bottom of the site.
Our website includes a 'social button' for LinkedIn. In order to implement social buttons, and connect them to the relevant social networks and external sites, there are scripts from domains outside of Orwell Independent. These sites are likely to be collecting information about what you are doing all around the internet, including on Orwell’s site. You should check the respective policies of these sites to see how exactly they use your information and to find out how to opt out, or delete, such information.
From time to time we may use external web services on Orwell’s website, for example to display content within our web pages we may use YouTube. This is not the only service we use, or might use in the future, when embedding content, but it is the most common. As with the social buttons we cannot prevent these sites, or external domains, from collecting information on your usage of this embedded content. If you are not logged in to these external services then they will not know who you are but are likely to gather anonymous usage information e.g. number of views, plays, loads etc.
Most standard emails that we send you have no tracking in at all. Some marketing and all platform emails we track, at an individual level, to understand open and click rates. If you want to be sure that none of your email activity is tracked then you should opt out of Orwell’s marketing emails which you can do at the bottom of every email you receive.
From time to time our site may request information from users via surveys, or for a particular service. Participation is completely voluntary and the user therefore has a choice whether or not to disclose this information.Information requested will include contact information (as supplied to the site during registration) and supplementary information on your interests, opinion sand preferences (e.g. feedback on Orwell’s service). We will only share your details on our site (for example to highlight a case study) with your express written (including emailed) consent.
We will not request or hold any credit card information via our website, but during the process of transacting through Orwell, we collect and store information that we require in order to fulfil the service. This may include your name, address, email address, phone number as well as similar information about other people in your business. If you should require more information, please contact us via the website contact page.
As part of any registration process you have the opportunity to opt in or out of various email communications. If at any stage you wish no longer to receive any emails that you receive you can unsubscribe or change your preferences on any of the emails that you receive.
If we are going to use your personally identifiable information in a manner different from that stated at the time of collection we will make any changes to this Privacy Policy and post them to our site. It is up to you whether you then continue to use the site and Orwell Independent Ltd’s services following such changes. However, it is assumed that you accept such changes if you continue to browse the Orwell website. If you do not accept such changes then you should stop using Orwell’s website and services and contact us should you wish to have any of your details removed.