3SIX5 DIGITAL | PRIVACY POLICY
3SIX5 Digital Privacy PolicyThis website (https://www.3SIX5Digital.co.uk) is owned and operated by 3SIX5 Digital. This policy explains how we collect and use your information. In this Policy, “we”, “us” and “our” means 3SIX5 Digital Ltd.We keep our Privacy Policy under regular review and we will place any updates on this web page, so please check back when you use our services to ensure you have seen the most up to date version. This Privacy Policy was last updated on 17th October 2019. Who we are 3SIX5 Digital are a partnership based at Dragon Coworking, Rochester, Kent.

2. YOUR CONSENT
By using the Website and/or Customer Services and submitting information, you consent to:
the collection and use of your personal data by us as described in section 1 above; and
the sharing of your personal data with third parties strictly in accordance with section 6 below.

3. USES MADE OF THE INFORMATION
Here at 3SIX5 Digital we take your privacy seriously and will only use your personal data to manage your account and provide tailored services to you. What is GDPR? From 25th May 2018 the new General Data Protection Regulation (GDPR) comes into force. It updates the Data Protection Act 1998 (DPA) which was developed before the development and use of social media, cloud based IT systems etc, and puts the rights of data subjects – that’s you as individuals – at the very heart of the Regulation of data.

Why do we process your personal data? Data protection laws state six lawful reasons why a company may collect and process your personal data: Consent: The individual has given consent to process their personal data for a specific purpose.Contract: The processing is necessary to fulfil a contract with the individual, or because we have asked you to take specific steps before entering into a contract. We will process your personal data to fulfil an order, deliver a service and essentially comply with our contractual obligations.Legal compliance: The processing is necessary for us to comply with the Law. If the law or government requires us to, we may need to collect and process your data. An example might be passing on details of fraud to law enforcement. Vital interests: The processing is necessary to protect someone’s life. Public task: The processing is necessary for us to perform a task in the public interest or for our official functions, and the task or function has a clear basis in Law. Legitimate interests: The processing is necessary for our legitimate interests or the legitimate interests of a third party unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests. In cases, we require personal data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business. This does not impact your freedom or rights. Examples might be using your postal or email details to send direct marketing information on content, products and services that we think might interest you with the aim of raising awareness of our business with yours and you, as an employee of that business.

What personal data do we collect and process? We process the following kinds of personal data:Information about you, including your name, postal address, telephone number and email address.Information through communicating with us, whether by email, post, telephone, in person or through our Website, for example submitting information through our contact form. Each time you visit our website we may automatically gather the following information: Technical information about your computer such as domain name, browser type and version, operating system and platform, IP address, cookie information and time zone setting; andInformation about your visit including the full Uniform Resource Locators (URL) clickstream to, through and from the Website (including date and time), what web pages you visited on the Website and how long you spend on each page, page interaction information(such as clicks), page response times, download errors, traffic data, location data, weblogs, and history of resources accessed on the Website. When do we collect your personal data? We collect your Personal data when:You make an enquiry through our Website form or sign up to receive our newsletter;You visit our Website and cookies are placed on your computer.

4. IP ADDRESSES AND COOKIES
4.1 We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual.
4.2 For the same reason, we may obtain information about your general internet usage by using a cookie file which is stored on the hard drive of your computer. Cookies contain information that is transferred to your computer’s hard drive. They help us to improve the Website and to deliver a better and more personalised service. They enable us to:
4.2.1 estimate our audience size and usage pattern;
4.2.2 store information about your preferences, and so allow us to customise the Website according to your individual interests;
4.2.3 speed up your searches; and
4.2.4 recognise you when you return to the Website.
4.3 You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. However, if you select this setting you may be unable to access certain parts of the Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you log on to the Website.
4.4 Please note if we carry any external advertising on the Website or have sponsors, that they themselves may also use cookies over which we have no control.

5. WHERE YOUR PERSONAL DATA MAY BE STORED
We want to give you the best possible experience. One way to achieve that is to get the richest picture we can of who you are by combining the data we have about you. We then use this to offer you content, products and services that are most likely to interest you. The data privacy law allows this as part of our legitimate interest in understanding our customers and potential customers and providing the highest levels of service.Of course, if you wish to change how we use your data, you’ll find details in the ‘Controlling your personal data’ section below.Remember, if you choose not to share your personal data with us, or refuse certain contact permissions, we might not be able to provide the best experience.
5.2 All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of the Website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
How do we use your personal data and why? Your personal data is used: To process any orders or hold negotiations that you make by using our sales team or sales agents. If we don’t collect your personal data during negotiations or ordering, we won’t be able to process your order and comply with our legal obligations. We would then keep those details for reasonable period afterwards in order to fulfil contractual obligationsTo respond to your queries. Handling the information you sent enables us to respond. We may also keep a record of these to inform any future communication with us and to demonstrate how we communicated with you throughout. We do this on the basis of our contractual obligations to you, our legal obligations and our legitimate interests in providing you with the best service and understanding how we can improve our service based on your experience.

6. INFORMATION DISCLOSURE TO THIRD PARTIES
You email, call us or write to us, visit our offices or provide us with information in any other way including by interacting with us via social media such as Facebook, Twitter, Google+ or LinkedIn. You have given your consent for publicly-available sources to share your information publicly such as online directories or LinkedIn. You have given a third party permission to share with us the information they hold about you. You book any kind of appointment with us or book to attend an event, for example a meeting to discuss an opportunity. Why do we use your personal data?
To protect our business and yours from fraud and other illegal activities. We’ll also monitor your browsing activity with us to quickly identify and resolve any problems and protect the integrity of our websites. We’ll do all of this as part of our legitimate interest.To market our products and services to you. We will use your personal data, preferences and details of your transactions to keep you informed by email, web, telephone about relevant content, products and services including information, tailored offers, discounts, promotions, events, competitions and so on. We market on the basis of legitimate interest and in a way which might reasonably be expected as part of running our business. This does not impact your freedom or rights. Our marketing will follow best practice laid out by the Information Commissioner’s Office (ICO) when dealing with corporate subscribers under the PECR. Direct MarketingWe use a marketing platform known as MailChimp to send out information which we think is valuable to you. You have the right to Opt-out of marketing communications at any time. We will always respect your wishes. If you wish to no longer be contacted for marketing purposes then please click here. Cookies on our website Our Website uses cookies to distinguish you from other users of the Website, to provide you with a better experience when browsing the Website. They also help us to improve the Website. Cookies and tracking software are used on a temporary basis and expire when the site has been left. These are used for purposes such as website improvement. Google Analytics is also used for the same reason of website improvement and understanding how you use it. This information is not shared with anyone.

7. TRACKING SOFTWARE
By using our website, you are consenting to the use of cookies to retain session information for the purposes listed above. This information is held in your web browser and is removed at the end of your session. The personal information we collect and hold via Tracking software is the following: –Browser used (Bing, Chrome, Internet Explorer etc.)Location (based on IP address)GenderAge groupSite searchesDevice(s) usedFrequency on SiteSession duration (time spent on the site)Page(s) visitedPage session duration (time spent on specific page)Web Surfing BehavioursFor further information on what cookies are then please visit http://allaboutcookies.org.Security

8. OUR PROMISE
We will treat your data with the utmost care, taking all appropriate steps to protect it and aim to keep your personal information secure. In order to prevent unauthorised access or disclosure, we use appropriate technical and organisational measures to keep all personal information we collect secure.However, transmission of information via the internet is not completely secure. While we do the best we can to ensure the security of your personal data once we receive it, we cannot guarantee the security of your personal information transmitted to our Website; any transmission is at your own risk.When your personal information is received we use strict procedures and security features to try and prevent unauthorised access or loss. We regularly monitor our system to identify ways to further strengthen security.Where is your personal data stored?When we collect information about you, it all gets stored into our Enterprise Resource Planner system. This system helps us organise your personal information so that we can ensure our communications with you are as relevant and as tailored as possible. We do not use any source of automatic profiling.

9. HOW LONG WE KEEP YOUR DATA
How long do we keep your personal data?We hold your personal information for as long as we need to for legitimate legal or business reasons, including to comply with any regulatory obligations. The retention periods of personal information range from 3 months to 10 years, or for the period during which you request our services. Controlling Your Personal InformationYou are free to opt out of hearing from us at any time about the following:Relevant, personalised communications by post or email in relation to updates, content, offers, services and products. These would be sent on the basis of our legitimate business interest. Communications required by law or which are necessary to inform you about our changes to the services we provide you. For example, updates to this Privacy Notice, marketing data misuse issues, and legally required information relating to your orders. These service messages will not include any promotional content and do not require prior consent when sent by email or text message. If we do not use your personal data for these purposes, we would be unable to comply with our legal obligations.Developing, testing and improving the systems, services and products we provide to you. We’ll do this on the basis of our legitimate business interests. Complying with our contractual or legal obligations to share data with law enforcement. Survey and feedback requests to help improve our services. These messages will not include any promotional content and do not require prior consent when sent by email or text message. We have a legitimate interest to do so as this helps make our products or services more relevant to you.You have the right to ask us to stop processing your personal Information for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes.


10. UNSUBSCRIBE TO US
You can tell us that you do not want to receive information about related services or specific content related to web development which we provide by not ticking the relevant check boxes on the forms we use to collect your personal information. Alternatively there is an unsubscribe button on all of our marketing emails which you can use, this will remove your personal information from our email list.You can also ask us to stop sending you marketing communications at any time by sending us a written request to our contact form here or by using any of the other methods set out in our ‘contact us’ section below.We will never sell your personal information, and we will only share your Personal Information as described in this Policy. Furthermore, if we are processing your Personal Information on the basis of your consent, you have the right to withdraw your consent at any time.What are your Data Subject Rights?Subject Access Request, erasure, restriction, rectification and transfer:You have the right to ask for information we hold for you (Subject Access Request) which will be provided free of charge and if requested, can be presented in a spreadsheet based format.The data we hold will be corrected when we are notified of errors.Information we hold for you will no longer be processed if requested to do so.Information we hold for you will be deleted if requested to do so. It is possible we may contact you at a later date as we will hold no record of you.You have to right to withdraw consent at any time.You have the right to stop the use of your personal data for direct marketing through selected or all channels.You have the right to stop processing your personal data under legitimate interest for individual reasons. We will comply unless we believe there is a legitimate overriding reason to continue processing.When exercising your rights, our response will depend on which legal grounds we are using to process the data in question, and the circumstances of the particular processing. You can find out more about your rights by viewing guidance from the Information Commissioner’s Office here.You can exercise your rights by sending us a written request to our contact form here or by using any of the other methods set out in our ‘contact us’ section of the privacy policy outlined below.With each request we will ask for a piece of identification such as a copy of your passport/driving license and a recent utility bill, this is to ensure we maintain our strict security protocols by issuing personal information to the correct individual. If there is any particular information in mind, please be specific so that we can respond to you as quickly as possible.Links to other websitesOur Website contains links to other Websites however this privacy policy only applies to this website. When you link to other websites, their own privacy policies will apply.Complaints to the ICOIf you are unhappy with us, our service, or the way that we treat your personal information then please contact us and we will work with you to resolved your issue.You also have the right to contact the UK data protection authority, ICO. You can contact the ICO through their website: https://ico.org.uk/global/contact-us/. You can also call the ICO helpline from the UK on 0303 123 1113 or +44 1625 545 745 if calling from outside of the UK.

11. CONTACT 
If you have any questions on this Policy, or would like to exercise your rights, you can contact our Data Protection Officer, Steve Shaw in the following ways:
Email us at admin@3six5digital.co.uk Use our Website contact us form: https://www.3SIX5Digital.co.uk/contact
or Write to us at:
Steve Shaw Data Protection Officer 3SIX5 Digital Dragon Coworking Rochester Kent


TAKE ME HOME