PRIVACY POLICY

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Global Recourse respects your privacy and is determined to protect your personal data. The purpose of this privacy policy is to inform you as to how we look after your personal data when you visit our website regardless of where you visit it from. We’ll also tell you about your privacy rights and how the data protection laws protect you.

1. WHO WE ARE AND IMPORTANT INFORMATION

This privacy policy aims to give you information on how we collect and process your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter or use a product or service.

By visiting this site, you are accepting the practices described in this privacy policy.

You must read this privacy policy together with any other privacy policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements the other policies and is not intended to override them.

In this privacy policy, unless the context requires a different interpretation:

  1. the singular includes the plural and vice versa;
  2. references to sub-clauses, clauses, schedules or appendices are to sub-clauses, clauses, schedules or appendices of this privacy policy;
  3. a reference to a person includes firms, companies, government entities, trusts and partnerships;
  4. “including” is understood to mean “including without limitation”;
  5. reference to any statutory provision includes any modification or amendment of it;
  6. the headings and sub-headings do not form part of this privacy policy.

We may change this policy from time to time. The date this policy was last updated is shown at the end of this document.

Data controller

Global Recourse is the controller and responsible for your personal data, collectively referred to as Global Recourse, “we”, “us” or “our” in this privacy policy.

We are registered in England and Wales under company number 10768960 and have our registered office at Unit 7A Waterside, Waterside Business Park, Chesham HP5 1PE, United Kingdom.

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

For all data matters contact amadlung@globalrecourse.com

Third-party links outside of our control

This 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 policy of every website you visit.

2. THE PERSONAL DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information relating to an identified or identifiable individual. You can find out more about personal data from the Information Commissioner’s Office.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

  • Profile Data may include your name, password, job title, organisation, contact details, and a record of any conversation relating to a request for information and/or orders and purchases made by you, feedback, survey responses and preferences.
  • Contact Data may include billing address, delivery address, email address, telephone numbers.
  • Financial Data includes bank account, billing information, payment card information
  • Transaction Data may include your contact details and the transaction details about payments to and from you and other details of products and services you have purchased from us.
  • Usage Data may include your IP address, geographical location, login data, browser type and version, browser plug-in types and versions, 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.
  • Marketing and Communications Data includes your communication preferences and preferences for receiving newsletters and/or other relevant notifications and marketing from.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you. This includes details 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. Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect your 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 the contract we have or are trying to enter into with you, for example, to provide you with goods or services. In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

3. HOW WE COLLECT YOUR PERSONAL DATA

We collect data in the following ways:

Directly

You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise.

This includes personal data you provide when you –

  • Apply for our products or services;
  • Create an account on our website;
  • Subscribe to our service or publications;
  • Request marketing to be sent to you;
  • Respond to a survey or give us otherwise feedback

Automatically

As you interact with our website, we may automatically collect Usage Data. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Usage Data about you if you visit other websites employing our cookies.

Please see our Cookie Policy for further details.

4. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Performance of Contract this means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
  • Legitimate Interest this means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the most secure experience, and in particular for the following reasons: internal record keeping; to improve our products and services; to periodically send marketing emails about new products or services, special offers or other information which we think you may find interesting using the email address which you have provided.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

Global Recourse will not rent, sell or distribute your personally identifiable information to third parties unless we have your permission or are required by law to do so.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.

Opting out

If you are a newsletter subscriber, you always have the option of no longer receiving them. At the bottom of each newsletter there is an opt-out option. Simply click on “Please click here to unsubscribe”.

Where you opt out of receiving marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. WHO WE SHARE YOUR PERSONAL DATA WITH

We may share personal data with:

  • External Third Parties
    • Providers we use to help deliver our services to you, e.g. payment service providers, our associates;
    • Providers we use to help us run our business, e.g. marketing services (Mailchimp for Newsletter distribution) or website hosts;

We or the third parties mentioned above occasionally also share personal data with:

    • Our external auditors, e.g. in relation to the audit of our accounts, in which case the recipient of the information will be bound by confidentiality obligations;
    • Our and their professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations;
    • Law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations;

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.

6. 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.

7. DATA RETENTION

Our retention periods are driven by legislation and/or business need. 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.

When personal data is no longer needed, we either irreversibly anonymise the data (in which case we may further retain and use the anonymised information) or securely destroy the data.

In some circumstances you can ask us to delete your data: see Your Legal Rights below for further information.

Even if we delete your Data, it may persist on backup or archival media for legal, tax or regulatory purposes.

8. YOUR LEGAL RIGHTS

Unless subject to an exemption under the data protection laws, you have the following rights with respect to your personal data:

  • The right to request a copy of the personal data which we hold about you;
  • The right to request that we correct any personal data if it is found to be inaccurate or out of date;
  • The right to request your personal data is erased where it is no longer necessary to retain such data;
  • The right to withdraw your consent to the processing at any time, where consent was the lawful basis for processing your data;
  • The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), where applicable, i.e. where our processing is based on consent or is necessary for the performance of our contract with you or where we process your data by automated means);
  • The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
  • The right to object to our processing of personal data, where applicable i.e. where processing is based on our legitimate interests (or in performance of a task in the public interest/exercise of official authority); direct marketing or processing for the purposes of scientific/historical research and statistics).

Queries and complaints

To exercise all relevant rights, queries or complaints in relation to this policy or any other data protection matter between you and us, please in the first instance contact us via the email address: amadlung@globalrecourse.com

If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office (ICO), the UK’s independent authority set up to uphold information rights in the public interest, promoting openness by public bodies and data privacy for individuals.

You can contact the ICO on 03031231113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England, UK.

No fee required – with some exceptions

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable admin fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

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.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may 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.

General

  • You may not transfer any of your rights under this privacy policy to any other person. We may transfer our rights under this privacy policy where we reasonably believe your rights will not be affected.
  • If any court or competent authority finds that any provision of this privacy policy (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this privacy policy will not be affected.
  • Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.
  • This policy will be governed by and interpreted according to the law of England and Wales. All disputes arising under the Agreement will be subject to the exclusive jurisdiction of the English and Welsh courts.

9. CHANGES TO THIS POLICY AND YOUR DUTY TO INFORM US OF CHANGES

Global Recourse reserves the right to change this privacy policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the website, and you are deemed to have accepted the terms of the privacy policy on your first use of the website following the alterations.

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

You may contact Global Recourse by email at amadlung@globalrecourse.com.

This document was last updated on 5th May 2022