1. Introduction

1.1  Structure Source Ltd are committed to safeguarding the privacy of our website visitors and customers. In this policy we explain how we will handle your personal data.

1.2  By using our website and agreeing to this policy, you consent to our use of cookies in accordance with the terms of this policy.

1.3  Our website incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can specify whether you would like to receive direct marketing communications from Structure Source Ltd. You can unsubscribe from our email marketing at any time – the unsubscribe facility is clearly published at the bottom of all marketing emails.

2. How we use your personal data

2.1 In this Section 2 we have set out:

(a)  the general categories of personal data that we may process;

(b)  the purposes for which we may process personal data; and

(d) the legal bases of the processing.

2.2  We may process data about your use of our website and services (“usage data”). The usage data may include your IP address, geographical location, 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. The source of the usage data is our analytics tracking system ‘Google Analytics’. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.

2.3  We may process your account data (“account data”). The account data may include your name and email address. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.

2.4  We may process your information included in your personal profile on our website (“profile data”). The profile data may include your name, address, telephone number, email address, profile pictures, gender, date of birth, relationship status, interests and hobbies, educational details and employment details. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.

2.5  We may process your personal data that are provided in the course of the use of our services (“service data”). The service data may include your name, company, telephone number and email address. The service data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.

2.6  We may process information that you post for publication on our website or through our services (“publication data”). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.

2.7  We may process information contained in any enquiry you submit to us regarding products and/or services (“enquiry data”). The enquiry data may be processed for the purposes of offering, marketing and selling relevant products and/or services to you. The legal basis for this processing is by your request. Enquiry data is often logged in our CRM system (Customer Relationship Management) for the purposes of contacting customers at a future date.

2.8  Transactions are not currently not available through our website so we do not process this type this information (“transaction data”)

2.9  We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data”). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent by means of the new opt in laws.

2.10  We may process information contained in or relating to any communication that you send to us (“correspondence data”). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.

2.13  In addition to the specific purposes for which we may process your personal data set out in this Section 2, 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 in order to protect your vital interests or the vital interests of another natural person.

2.14  Please do not supply any other person’s personal data to us, unless we prompt you to do so.

3. Providing your personal data to others

3.1  We do not exchange or sell your data to any third party web sites or external data suppliers. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.

3.2  We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of [obtaining and maintaining insurance coverage, managing risks, obtaining professional advice and managing legal disputes.

3.3  We may disclose your data to our web site suppliers or IT subcontractors insofar as reasonably necessary for accurate digital back-ups, web site maintenance and internal IT systems efficiency.

3.4  We do not conduct financial transactions relating to our website.

3.5  We will not disclose your enquiry data to one or more of those selected third party suppliers of goods and services identified on our website for the purpose of enabling them to contact you so that they can offer, market and sell to you relevant goods and/or services.

3.6  In addition to the specific disclosures of personal data set out in this Section 3, we may also 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.

4. International transfers of your personal data

4.1  In this Section, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).

4.2  Structure Source Ltd have offices and facilities in the UK Spain and China. The European Commission has made an “adequacy decision” with respect to the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission.

4.3  The hosting facilities for our website are situated in the UK with Birch Hosting and then go through 1 and 1 for extra security. The European Commission has made an “adequacy decision” with respect to the data protection laws of this country. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission. You can see Birch Hosting privacy policy here https://www.birchhosting.com/privacy-statement/ and 1 and 1’s privacy policy here https://www.1and1.co.uk/terms-gtc/terms- privacy/

4.4  You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

5. Retaining and deleting personal data

5.1  This Section 5 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

5.2  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.

5.3  We will retain and delete your personal data as follows:

(a) All personal data will be retained for 5 years following the date you register any enquiry at the end of which period it will be deleted from our systems.

5.4 In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:

(a) the period of retention of your personal data will be determined based on any ongoing legal or insurance issues.

5.5 Notwithstanding the other provisions of this Section 5, 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.

6. Amendments

6.1  We may update this policy from time to time by publishing a new version on our website.

6.2  You should check this page occasionally to ensure you are happy with any changes to this policy.

6.3  We may or may not notify you of changes to this policy by email.

7. Your rights

7.1  You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to:

(a)  the payment of a fee currently fixed at GBP 10

(b)  the supply of appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address).

7.2  We may withhold personal information that you request to the extent permitted by law.

7.3  You may instruct us at any time not to process your personal information for marketing purposes. This includes unsubscribing from emails and deleting you from some/or all social media marketing projects.

7.4  In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.

8. Third party websites

8.1 Our website does not include hyperlinks to, and details of, third party websites.

9. Personal data of children

9.1  Our website and services are targeted at persons over the age of 16.

9.2  If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.

10. Updating information

10.1 Please let us know if the personal information that we hold about you needs to be corrected or updated.

11. About cookies

11.1  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.

11.2  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.

11.3  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.

12. Cookies that we use

12.1 We do not use cookies on our website.

13. Cookies used by our service providers

13.1  Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

13.2  We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our

website. Google’s privacy policy is available at: https://www.google.com/policies/privacy/. The relevant cookie is the ‘_ga’ cookie.

13.3 We do not publish Google AdSense interest-based advertisements on our website.

14. Our details

14.1  This website is owned and operated by Structure Source Ltd.

14.2  We are registered in England and Wales under registration number 06826602 and our registered office is at The Retreat, 24A Hollybush Lane, Harpenden, Herts, AL5 4AT, UK

14.3  Our principal place of business is given above.

14.4  You can contact us:

(a)  by post, using the postal address given above

(b)  using our website contact form

(c)  by telephone, on the contact number 01582 235000

(d)  by email, using the email address sales@structuresource.com

15. Representative within the European Union

15.1 Our representative within the European Union with respect to our obligations under data protection law is Richard Clark and you can contact our representative by email richard@structuresource.com

16. Data protection officer

16.1 Our data protection officer’s contact details are: richard@structuresource.com