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You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO) (Adipex Order Canada). However, we would appreciate the chance to deal with your concerns first.

Changes

This first version was created on 25/05/2018. As and when changes/updates are made to this document, historic versions can be obtained by contacting us. It is important that the personal data we hold about you is accurate and current. Please keep us informed of any changes.

How we collect your personal data

You may give us data orally, by filling in forms, or by corresponding with us by post, phone, email, social media or otherwise, for example when you:

How we use your data

We will only use your personal data when the law allows us to. In each case, we may rely on three reasons to do so. These are:

(a) The performance of a contract with you.
(b) Because it is necessary to comply with a legal obligation.
(c) Because it is necessary for our legitimate interests.

These three reasons for using your personal data overlap and there may be more than one ground to justify our use of your personal information on any occasion.

We have set out below how and why we plan to use your personal data.

Purpose / Activity Lawful basis for processing including basis of legitimate interest
To register you with our business Performance of a contract/booking with you
To perform any contract/booking with youincluding:
(a) Managingpayments, fees and charges
(b) Collectingand recoveringmoney owed to us
(c) Addressing any breach
(d) Preparing for arrivals, departures and individual requests
(a) Performance of a contract/bookingwith you
(b) Necessary for our legitimate interests (to recover debts due to us)
(c) Necessary for our legitimate interests (to ensure compliance with contract terms)
To manage our relationship with you which will include:
(a) Notifying you about changes to any of our terms or privacy policy
(b) Notifying you about changes to our business, which are relevant to you
(a) Performance of a contract/bookingwith you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updatedand to study how people use our business)
To administer and protect our business and ourwebsite (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary tocomply with a legal obligation
To make suggestions and recommendations to you about goods or services that may be of interest to you Necessary for our legitimate interests (to develop and grow our business)
Asking you to partake in a review, prize draw, competition or complete a survey Necessary for our legitimate interests (to study how people use our business, todevelop and grow our business)
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you Necessary for our legitimate interests (to study how people use our business, to develop and grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, relationships and experiences Necessary for our legitimate interests (to define types of people for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

Promotional offers from us

We may use your personal data to form a view on what we think you may want or need, or what may be of interest to you.

We may then use your personal data to send you marketing communications from us if you have requested information from us, or purchased goods or services from us, or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

Other marketing

We will get your express opt-in consent before we use your personal data for any other marketing purpose or share it with any third party for marketing purposes.

Opting out

You can ask us, or third parties, to stop sending you marketing messages at any time by contacting our DPM.

Change of purpose

Please note that we may process your personal data without your knowledge or consent where this is required or permitted by law.

However, if we need to use your personal data for a new purpose and the law allows us to do so, we will notify you and explain the legal basis for our actions.

Visitors to our website

If we want to collect personally identifiable information through our website, we will be up front about this.

When someone visits our website, we may use a third-party service to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way, which does not identify anyone.

Third-party links and websites

Our website may include links to third-party websites, plug-ins and applications. 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 notice of every website you visit.

If you contact us via a third-party website, whether social media (e.g. Facebook, Twitter) or a feedback review website, we do not control these third-party websites and are not responsible for their privacy statements. We encourage you to read the privacy notice of every website you use or visit. Our use of your data provided via these platforms will be as per this Notice.

If you fail to provide personal data

If you do not provide personal data to us and this would prevent us from performing the contract/booking we have, or are trying to enter into with you, or place us in breach of the law, we may have to cancel the contract/booking. We will notify you if this is the case.

Disclosures of your personal data

We may share your personal data with third parties to help us run our business or carry out our obligations to you:

Name Lawful basis for processing including basis of legitimate interest
Service providers for IT and system administration Performance of a contract with you. Necessary for our legitimate interests (performing the contract, using your data as we have described in this notice).
Our professional advisers including lawyers, bankers, auditors and insurers Necessary for our legitimate interests (complying with our legal obligations).
HM Revenue & Customs, regulators and other authorities, government departments or law enforcement agencies Necessary for our legitimate interests (complying with our legal obligations).
Third party booking agents Performance of a contract with you. Necessary for our legitimate interests (performing the contract, using your data as we have described in this notice).

We may also share your personal data with any third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

International transfers

We do not transfer your data outside the European Economic Area.

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

How long will we use your personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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 requirements.

You can ask us about the retention periods for different aspects of your personal data by contacting our DPM.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Your legal rights

You have the right to: