This Privacy Policy sets out how we, Afterlife Intl Limited, collect, store and use information about you when you use or interact with our website, https://ewysh.com/ (website) and where we otherwise obtain or collect information about you. This Privacy Policy is effective from January 1, 2022.

Contents

• Summary
• Our details
• Information we collect when you visit our website
• Information we collect when you contact us
• Information we collect when you interact with our website
• Our use of automated decision-making and profiling
• How we collect or obtain information about you from third parties
• Disclosure and additional uses of your information
• How long we retain your information
• How we secure your information
• Transfers of your information outside the European Economic Area
• Your rights in relation to your information
• Your right to object to the processing of your information for certain purposes
• Sensitive Personal Information
• Changes to our Privacy Policy
• Children’s Privacy
• Copyright, credit and logo

 

Summary

This section summaries how we obtain, store and use information about you. It is intended to provide a very general overview only. It is not complete in and of itself and it must be read in conjunction with the corresponding full sections of this Privacy Policy.

• Data controller: Afterlife Intl Limited

• How we collect or obtain information about you:
  • when you provide it to us (e.g. by contacting us, completing our online contact forms, using our online chat facility, subscribing to website,  and/or by otherwise accessing/submitting any of the online forms or services we offer,
  • from your use of our website, using cookies and similar technologies, and
  • from third parties, details of which are available upon reasonable and legitimate request.

• Information we collect: name, contact details, IP address, information from cookies, information about your computer or device (e.g. device and browser type), information about how you use our website (e.g. which pages you have viewed, the time when you view them and what you clicked on, the geographical location from which you accessed our website (based on your IP address), company name or business name (if applicable), VAT number (if applicable).

• How we use your information: for administrative and business purposes (particularly to improve our service offering, website and business generally and to fulfil our contractual obligations, to advertise our goods and service and to analyse your use of our website and in connection with our legal rights and obligations.

• Disclosure of your information to third parties: only to the extent necessary to operate our business, to our service providers, to fulfil any contracts we enter into with you and where required by law, for the protection of you as our client or to enforce our legal rights.

• Do we sell your information to third parties (other than in the course of a business sale or purchase or similar event):  No

• How long we retain your information: for no longer than necessary, taking into account the data may be saved on our website to be delivered at a later date, any legal obligations we have (e.g. to maintain records for tax and other regulatory purposes), any other legal basis we have for using your information (e.g. your consent, performance of a contract with you or our legitimate interests as a business) and certain additional factors described in the main section below entitled How long we retain your information. For specific retention periods in relation to certain information which we collect from you, please see the main section below entitled How long we retain your information.

• How we secure your information: using appropriate technical and organisational measures such as storing your information on secure servers, encrypting transfers of data to or from our servers using Secure Sockets Layer (SSL) technology, only granting access to your information where considered necessary by us or otherwise agreed with you.

•  Use of cookies and similar technologies: we use cookies and similar information-gathering technologies such as web beacons and Google analytics n our website including essential, functional, analytical and targeting cookies.

• Transfers of your information outside the European Economic Area: in certain circumstances we transfer your information outside of the European Economic Area to our international offices, currently in Canada. Where we do so, we will ensure appropriate safeguards are in place including information being held and transferred wherever possible between our own servers.

•  Use of automated decision making and profiling: we use profiling by use of web analytics, cookies, web beacons, server logs analysis and targeting cookies. For more information, please visit our Cookies Policy.

• Your rights in relation to your information

• to access your information and to receive information about its use
• to have your information corrected and/or completed
• to have your information deleted
• to restrict the use of your information
• to receive your information in a portable format
• to object to the use of your information
• to withdraw your consent to the use of your information
• not to have significant decisions made about you based solely on automated processing of your information, including profiling
• to complain to a supervisory authority

• • • Sensitive personal information: we do not knowingly or intentionally collect what is commonly referred to as ‘sensitive personal information’. Please do not submit sensitive personal information about you to us. For more information, please see the main section below entitled Sensitive Personal Information.

 

Our details

The data controller in respect of our website is Afterlife Intl Limited (company registration number: 12984429) of 10 Carolina Way, Salford, Greater Manchester, United Kingdom, M50 2ZY. You can contact the data controller by writing to Afterlife Intl Limited, 10 Carolina Way, Salford, Greater Manchester, United Kingdom, M50 2ZY or sending an email to info@ewysh.com. If you have any questions about this Privacy Policy, please contact the data controller.

Information we collect when you visit our website

We collect and use information from website visitors in accordance with this section and the section entitled Disclosure and additional uses of your information.

Web server log information

We use a third party server to host our website, details of which may be made available upon reasonable and legitimate request. Our website server automatically logs the IP address you use to access our website as well as other information about your visit such as the pages accessed, information requested, the date and time of the request, the source of your access to our website (e.g. the website or URL (link) which referred you to our website), and your browser version and operating system.

We use our own servers located in the UK, United States and Canada and also make use of third party servers where necessary. Your information may be transferred outside the European Economic Area to our international offices currently in the United States and South Africa  For further information and information on the safeguards used, please see the section of this privacy policy entitled Transfers of your information outside the European Economic Area.

PLEASE ADD ANYTHING ELSE YOU THINK IS REQUIRED

Use of website server log information for IT security purposes

We and/or our third party hosting provider collect(s) and store(s) server logs to ensure network and IT security and so that the server and website remain uncompromised. This includes analysing log files to help identify and prevent unauthorised access to our network, the distribution of malicious code, denial of services attacks and other cyber-attacks, by detecting unusual or suspicious activity.

Unless we are investigating suspicious or potential criminal activity and/or such information is required for evidential purposes, we do not make, nor do we allow our hosting providers to make any attempt to identify you from the information collected via server logs.

Legal basis for processing:
compliance with a legal obligation to which we are subject (Article 6(1)(c) of the General Data Protection Regulation).

Legal obligation: we have a legal obligation to implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk of our processing of information about individuals. Recording access to our website using server log files is such a measure.

Legal basis for processing: our and a third party’s legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interests: we and our third party hosting provider have a legitimate interest in using your information for the purposes of ensuring network and information security and for the pursuit and/or defence of civil and/or criminal proceedings as appropriate.

Use of website server log information to analyse website use and improve our website

We use the information collected by our website server logs to analyse how our website users interact with our website and its features. For example, we analyse the number of visits and unique visitors we receive, the time and date of the visit, the location of the visit and the operating system and browser used.

We use the information gathered from the analysis of this information to improve our website and service offering. For example, we use the information gathered to change the information, content and structure of our website and individual pages according to what users are engaging most with and the duration of time spent on particular pages on our website.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest: improving our website for our website users and getting to know our website users’ preferences so our website can better meet their needs and desires.

 

Cookies and similar technologies

Cookies are data files which are sent from a website to a browser to record information about users for various purposes.

We use cookies and similar technologies on our website, including essential, functional, analytical and targeting cookies and web beacons. For further information on how we use cookies, please see our Cookies Policy.

You can reject some or all of the cookies we use on or via our website by changing your browser settings or non-essential cookies by using our cookie control tool, but doing so can impair your ability to use our website or some or all of its features. For further information about cookies, including how to change your browser settings, please visit www.allaboutcookies.org or see our cookies policy.

Information we collect when you contact us

We collect and use information from individuals who contact us in accordance with this section and the section entitled Disclosure and additional uses of your information.

 

Email

When you send or submit an email to the email address displayed on our website, we may collect your email address and any other information you provide in that email (such as your name, telephone number and the information contained in any signature block in your email).

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, creating an account and storing personal information), we will process your information in order to do so).

Transfer and storage of your information

We use a third party email provider to store emails you send us. Their privacy policy may be made available upon reasonable and legitimate request to the data controller.

Emails you send us will be stored within the European Economic Area or Canada on our third party email provider’s servers. For further information please see the section of this privacy policy entitled Transfers of your information outside the European Economic Area.

Contact form

When you contact us using our contact form, we collect your name, email address, IP address. We also collect any other information you provide to us when you complete the contact form.

If you do not provide the mandatory information required by our contact forms, you will not be able to submit the contact form and we will not receive your enquiry.

If you do not supply the optional information required by our contact form, e.g. phone number, we will not be able to respond to your enquiry by phone.

Legal basis for processing:our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).

Transfer and storage of your information –

Messages you send us via our contact form will be stored within the European Economic Area or Canada, either our third party server in the UK and/or our third party server in Canada. A copy of the relevant privacy policy may be provided upon reasonable and legitimate request.

For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.

We use third party contact form providers to store messages you send us. Our contact form providers are located in the UK or Canada. Messages you send to us via our contact forms may be stored outside the European Economic Area on our contact form providers servers in Canada.

For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.

 

Phone

When you contact us by phone, we collect your phone number and in the UK and we may record any information you provide to us during your conversation with us.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation)

Legitimate interest(s): responding to enquiries and messages we receive and keeping records of communications and correspondence for quality and training purposes.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).

Transfer and storage of your information

Information about your call, such as your phone number and the date and time of your call, is processed by our third party telephone service provider, details of which may be made available upon reasonable and legitimate request.

Information about your phone call within the EEA will be stored by our third party telephone service provider within the European Economic Area or Canada.

 

Post

If you contact us by post, we will collect any information you provide to us in any postal communications you send us.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation)

Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).

Information we collect when you interact with our website

We collect and use information from individuals who interact with particular features of our website in accordance with this section and the section entitled Disclosure and additional uses of your information.

 

Blogs

When you sign up for our blogs, we collect your name, email address, IP address and requested frequency of blog email notifications.

Legal basis for processing: your consent (Article 6(1)(a) of the General Data Protection Regulation).

Consent: you give your consent to us sending you our blogs by signing up to receive it using the steps described above.

 

Transfer and storage of your information

We use third party services to send out our blogs and administer our mailing list. Copies of their privacy policies may be provided upon reasonable and legitimate request.

Information you submit to subscribe to our blogs will be stored within the European Economic Area or Canada on either our or our third party mailing list providers’ servers in the UK or Canada. For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.

Use of web beacons and similar technologies in emails

We use technologies such as web beacons (small graphic files) in the emails we send to allow us to assess the level of engagement our emails receive by measuring information such as the delivery rates, open rates and click through rates which our emails achieve.

For more information on how we use web beacons in our blogs, see our Cookies Policy.

For more information about our third party mailing list provider and their use of web beacons, a copy of the relevant privacy policy may be provided upon reasonable and legitimate request.

 

Marketing communications

You will have the option of receiving marketing communications from us.

Use of web beacons and similar technologies in emails

We use technologies such as web beacons (small graphic files) and other technologies as set out in our Cookies Policy in the emails we send to allow us to assess the level of engagement our emails receive by measuring information such as the delivery rates, open rates and click through rates which our emails achieve. We will only use web beacons in our emails if you have consented to us doing so by subscribing (or continuing to subscribe) to our emails.

For more information on how we use web beacons in our emails, see our Cookies Policy.

For more information about our third party mailing list provider and their use of web beacons, a copy of their privacy policy may be made available upon reasonable and legitimate request.

Our goods and services

You agree to opt in to receiving marketing communications from us in relation to our goods and services by email, text message, phone, and/or submission of one of our online forms.

We will send you marketing communications in relation to our goods and services if you have allowed us to or we have a legitimate business reason.

We will send you marketing communications in relation to our goods and services to those you nominate as a beneficiary of the media you create, as we have a legitimate business reason. The beneficiary

Legal basis for processing: consent (Article 6(1) (a) of the General Data Protection Regulation).

Consent: you give your consent to us sending you information about our goods and services by subscribing to receive such information in accordance with the steps described above. You also give consent for us to send your media to nominated beneficiaries.

We use third party services to administer our mailing list, details of which may be provided upon reasonable and legitimate request.

Information you submit to subscribe for our blogs will be stored within the European Economic Area on our own or our third party mailing list providers’ servers in UK and/or Canada. For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.

Use of web beacons and similar technologies in emails

We use technologies such as web beacons (small graphic files) in the emails we send to allow us to assess the level of engagement our emails receive by measuring information such as the delivery rates, open rates and click through rates which our emails achieve. We will only use web beacons in our emails if you have consented to us doing so by subscribing (or continuing to subscribe) to our emails.

For more information on how we use web beacons in our marketing emails, see our Cookies Policy.

For more information about our third party mailing list provider and they use web beacons, a copy of the relevant privacy policy may be provided upon reasonable and legitimate request.

Information collected or obtained from third parties

This section sets out how we obtain or collect information about you from third parties.

Information received from third parties

We may receive information about you from third parties. The third parties from which we may receive information about you will generally be our international offices, referrals, subscription and data services.

It is also possible that third parties with whom we have had no prior contact may provide us with information about you.

Information we obtain from third parties will generally be your name and contact details, but will include any additional information about you which they provide to us.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: where a third party has passed on information about you to us (such as your name and email address) in order for us to provide services to you, we will process your information in order to take steps at your request to enter into a contract with you and perform a contract with you (as the case may be).

Legal basis for processing: consent (Article 6(1)(a) of the General Data Protection Regulation).

Consent: where you have asked that third party to share information about you with us and the purpose of sharing that information is not related to the performance of a contract or services by us to you, we will process your information on the basis of your consent, which you give by asking the third party in question to pass on your information to us.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interests: where a third party has shared information about you with us and you have not consented to the sharing of that information, we will have a legitimate interest in processing that information in certain circumstances.

For example, we would have a legitimate interest in processing your information to perform our obligations under a sub-contract with the third party, where the third party has the main contract with you. Our legitimate interest is the performance of our obligations under our sub-contract.

Similarly, third parties may pass on information about you to us if you have infringed or potentially infringed any of our legal rights. In this case, we will have a legitimate interest in processing that information to investigate and pursue any such potential infringement.

Where we receive information about you in error

If we receive information about you from a third party in error and/or we do not have a legal basis for processing that information, we will delete your information.

 

Information obtained by us from third parties

In certain circumstances (for example, to verify the information we hold about you or obtain missing information we require to provide you with a service) we will obtain information about you from certain publicly accessible sources, both EU and non-EU, such as Companies House, online customer databases, business directories, media publications, social media, and websites.

In certain circumstances we will also obtain information about you from private sources, both EU and non-EU, such as data brokers and subscription services.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)((b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: where you have entered into a contract or requested that we enter into a contract with you, in certain circumstances, we will obtain information about you from public sources in order to enable us to provide services to you or services to a sufficient standard.

For example, we would obtain and/or verify your email address from a third party or from a directory where you ask us to send you information by email but we do not possess the information or we need to confirm that we have recorded your email address correctly.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interests: in certain circumstances, we will have a legitimate interest in obtaining information about you from public and private sources. For example, if you have infringed or we suspect that you have infringed any of our legal rights, we will have a legitimate interest in obtaining and processing information about you from such sources in order to investigate and pursue any suspected or potential infringement.

Legal basis for processing: consent (Article 6(1)(a) of the General Data Protection Regulation).

Consent: we may obtain information from third parties, such as data brokers, where you have consented to them sharing information with us by e.g. ticking a box that you would like your information to be shared with us.

We may use profiling on our website. We do not consider that this has any legal effect on you or similarly significantly affects you.

You have the right to object to our use of profiling described in this section. You can do that by opting-out of cookies and similar technologies in accordance with the method described in the relevant section below. If you do not want us to process your actual IP address (usually the IP address assigned to you by your Internet Service Provider) when you visit our website, you can use a Virtual Private Network (VPN) or a free service such as Tor.

You can find out more about our use of cookies and similar technologies (including the legal basis on which we use them) and how to opt out from them in our Cookies Policy.

Profiling

Profiling is any form of automated processing of your information to evaluate personal aspects about you, in particular to analyse or predict things like your work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.

Use of profiling for web analytics

Our web analytics services, including Google Analytics, may use and collects information such as your location (based on your IP address) and your behaviour (based on cookies) when you access our website (such as the pages you visit and what you click on. We will only process information from cookies if you have consented to us setting cookies on your computer in accordance with our Cookies Policy.

Logic involved: by automatically analysing and categorising information such as the location (based on IP address) as well as the behaviour and devices of visitors to our website (using cookies), we are able to gain a better understanding of what our website visitors want (in terms of the content of our website and our products), how to improve our website and how to advertise and market our services to them.
Significance and envisaged consequences: cookies will be used to track and store information about your behaviour and device on our website (unless you have opted out from receiving such cookies by blocking all cookies, including essential cookies in your browser settings and your location will be analysed based on your IP address). We may target advertisements based on the level of interest we receive from certain visitors and their behaviour on our website.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest: improving our website user experience and getting to know our website users’ preferences so that we can tailor our website to be of more interest and relevant to your needs and desires.

Use of profiling in marketing emails

We use web beacons and other technologies in our marketing emails to analyse who opens our emails and what actions they take (for example, what they click on). We will only process information from web beacons and other technologies we use if you have consented to their use in accordance with our Cookies Policy.

Logic involved: by analysing how our email recipients respond to our emails, we are able to improve the relevance of content of our emails and gauge the topics of most interest.

Significance and envisaged consequences: your behaviour when you open our emails will be tracked using small gif files (web beacons), including open rates, click through rates, and deliverability.

How to object: if you object to the use of web beacons, please contact us at info@ewysh.com or contact our data controller.

Legal basis for processing: legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest: analysing the level of engagement and effectiveness of our marketing emails and content.

Disclosure and additional uses of your information

This section sets out the circumstances in which we will disclose information about you to third parties and any additional purposes for which we use your information.

Disclosure of your information to service providers

We use a number of third parties to provide us with services which are necessary to run our business or to assist us with running our business and who process your information for us on our behalf. These include telephone providers, e mail providers and IT service providers. Details of these providers’ privacy policies may be made available upon reasonable and legitimate request.

Your information may be shared with our service providers where necessary to provide you with the service you have requested, whether that is accessing our website or ordering goods and services from us.

We do not display the identities of our service providers publicly by name for security and competitive reasons. If you would like further information about the identities of our service providers, however, please contact us directly via our contact form or by email and we will provide you with such information where you have a reasonable and legitimate reason for requesting it (where we have shared your information with such service providers, for example).

Legal basis for processing: legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest relied on: where we share your information with these third parties in a context other than where is necessary to perform a contract (or take steps at your request to do so), we will share your information with such third parties in order to allow us to run and manage our business efficiently.

Legal basis for processing: necessary to perform a contract and/or to take steps at your request prior to entering into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: we may need to share information with our service providers to enable us to perform our obligations under that contract or to take the steps you have requested before we enter into a contract with you.

Disclosure of your information to other third parties

We disclose your information to other third parties in specific circumstances, as set out below.

Providing information to third parties such as Google Inc and our additional third-party sources. A copy our third parties’ privacy policy may be provided upon reasonable and legitimate request. Google collects information through our use of Google Analytics on our website. Google uses this information, including IP addresses and information from cookies, for a number of purposes, such as improving its Google Analytics service. Information is shared with Google on an aggregated and anonymised basis. To find out more about what information Google collects, how it uses this information and how to control the information sent to Google, please see the following page: https://www.google.com/policies/privacy/partners/

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest(s): meeting our contractual obligations to Google under our Google Analytics Terms of Service (https://www.google.com/analytics/terms/us.html)

You can opt out of Google Analytics by installing the browser plugin here: https://tools.google.com/dlpage/gaoptout

Transfer and storage of your information

Information collected by Google Analytics is stored outside the European Economic Area on Google’s servers in the United States of America.

For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.

Sharing your information with third parties, which are either related to or associated with the running of our business, where it is necessary or appropriate for us to do so. These third parties include our international offices, accountants, advisors, affiliates, business partners, independent contractors, third party marketing resources and insurers. Further information on each of these third parties is set out below.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest: running and managing our business efficiently.

Accountants

We share information with our accountants for tax purposes. For example, we share invoices we issue and receive with our accountants for the purpose of completing tax returns and our end of year accounts.

Our accountants are located in England, UK and Canada.

Advisors

Occasionally, we obtain advice from advisors, such as accountants, financial advisors, lawyers and public relations professionals. We will share your information with these third parties only where it is necessary to enable these third parties to be able to provide us with the relevant advice.

Our advisors are located in UK and Canada.

Insurers

We will share your information with our insurers where it is necessary to do so, for example in relation to a claim or potential claim we receive or make or under our general disclosure obligations under our insurance contract with them.

Our insurers are located in UK and Canada.

Sharing your information within our business’ group of companies and companies under mutual ownership in UK, United States and Canada for internal administrative purposes, including customer and employee information.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest: operating and managing our business effectively.

Sharing your information with a nominated beneficiary in the context of delivered media you created, whether actual or potential.

Legal basis for processing: legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest(s):sharing your information with a nominated beneficiary, seller or similar person in order to allow your desired delivery to take place.

We do not display the identities of all of the other third parties we may share information with by name for security and competitive reasons. If you would like further information about the identities of such third parties however, please contact us directly at info@ewysh.com and we shall provide you with such information where you have a reasonable and legitimate reason for requesting it e.g. where we have shared your information with such third parties.

Disclosure and use of your information for legal reasons

Indicating possible criminal acts or threats to public security to a competent authority

If we suspect that criminal or potential criminal conduct has been occurred, we will in certain circumstances need to contact an appropriate authority, such as the police. This could be the case, for instance, if we suspect that we fraud or a crime has been committed or if we receive threats or malicious communications towards us or third parties.

We will generally only need to process your information for this purpose if you were involved or affected by such an incident in some way.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interests: preventing crime or suspected criminal activity (such as fraud).

In connection with the enforcement or potential enforcement of our legal rights

We will use your information in connection with the enforcement or potential enforcement of our legal rights, including, for example, sharing information with law enforcement agencies if we suspect that your media contains references to a criminal act. Our legal rights may be contractual (where we have entered into a contract with you) or non-contractual (such as legal rights that we have under copyright law or tort law).

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest: enforcing our legal rights and taking steps to enforce our legal rights.

In connection with a legal or potential legal dispute or proceedings

We may need to use your information if we are involved in a dispute with you or a third party for example, either to resolve the dispute or as part of any mediation, arbitration or court resolution or similar process.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest(s): resolving disputes and potential disputes.

For ongoing compliance with laws, regulations and other legal requirements

We will use and process your information in order to comply with legal obligations to which we are subject. For example, we may need to disclose your information pursuant to a court order or subpoena if we receive one or to the National Crime Agency in connection with suspected or potential money laundering or other criminal matters.

Legal basis for processing: compliance with a legal obligation (Article 6(1)(c) of the General Data Protection Regulation).

Legal obligation(s): legal obligations to disclose information which are part of the laws of England and Wales or if they have been integrated into the United Kingdom’s legal framework (for example in the form of an international agreement which the United Kingdom has signed).

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation). Legitimate interest: where the legal obligations are part of the laws of another country and have not been integrated into the United Kingdom’s legal framework, we have a legitimate interest in complying with these obligations.

How long we retain your information

This section sets out how long we retain your information. We have set out specific retention periods where possible. Where that has not been possible, we have set out the criteria we use to determine the retention period.

Retention periods

Server log information: we may retain information on our server logs indefinitely.

Contract information: when you enter in to a contract with us for services, we retain that information for a minimum of six years following the end of the financial year in which you place your order, in accordance with our legal obligation to keep records for tax purposes. We may keep this longer if your media deliver data exceeds six years.

Correspondence and enquiries: when you make an enquiry or correspond with us for any reason, whether by email or via our contact form or by phone, we will retain your information for as long as is considered appropriate given the nature and extent of your enquiry, how long it will take to resolve your enquiry and whether you are engaged in a contract with us. Subject to the Criteria outlined below and unless you specifically request us to delete your information, we shall delete your information as soon as considered reasonably necessary and practicably possible.

Blogs: we retain the information you used to sign up for our blogs for as long as you remain subscribed (i.e. you do not unsubscribe) or if we decide to cancel our blogs service, whichever occurs earlier.

Criteria for determining retention periods

In any other circumstances, we will retain your information for no longer than necessary, taking into account the following:

• • • the purpose(s) and use of your information both now and in the future (such as whether it is necessary to continue to store that information in order to continue to perform our obligations under a contract with you or to contact you in the future);
    • whether we have any legal obligation to continue to process your information (such as any record-keeping obligations imposed by relevant law or regulation);
    • whether we have any legal basis to continue to process your information (such as your consent);
    • how valuable your information is (both now and in the future);
    • any relevant agreed industry practices on how long information should be retained;
    • the levels of risk, cost and liability involved with us continuing to hold the information;
    • how hard it is to ensure that the information can be kept up to date and accurate;
    • You request to hold your information based on the media delivery dates you arranged; and
    • any relevant surrounding circumstances (such as the nature and status of our relationship with you).

 

How we secure your information

With the exception of releasing media to your beneficiaries, we take appropriate technical and organisational measures to secure your information and to protect it against unauthorised or unlawful use and accidental loss or destruction, including:

• • • only sharing and providing access to your information to the minimum extent necessary;
    • using secure servers to store your information;
    • verifying the identity of any individual who requests access to information prior to granting them access to information;
    • only transferring your information via closed system.

 

Transmission of information to us by email

Transmission of information over the internet is not entirely secure, and if you submit any information to us over the internet (whether by email, via our website or any other means), you do so entirely at your own risk.

We cannot be responsible for any costs, expenses, loss of profits, harm to reputation, damages, liabilities or any other form of loss or damage suffered by you as a result of your decision to transmit information to us by such means.

Transfers of your information outside the European Economic Area

All of your information is stored in the UK or Canada, as we see fit.

Other than to our partner companies in Canada and to comply with any legal obligations to which we are subject (compliance with a court order, for example), we do not intend to transfer your information outside of our UK or Canadian operation, or to an international organisation.

 

Server log information

Information collected when you visit our website is transferred outside of the EEA and stored on the servers of our third party hosting companies. A copy of their privacy policy may be provided upon reasonable and legitimate request.

Country of storage: Canada. This country is not subject to an adequacy decision by the European Commission.

Safeguard(s) used: our third party hosting provider has self-certified its compliance with the EU-U.S. Privacy Shield.

Contact form

Information you submit to us via our contact forms are transferred outside the EEA and stored within our third party provider’s servers. A copy of their privacy policy may be provided upon reasonable and legitimate request.

Country of storage: UK and Canada.

Safeguard(s) used: our third party email provider and third party marketing platforms have self-certified compliance with the EU-U.S. Privacy Shield.

Email

Information you submit to us by email is transferred outside the EEA and stored on our third party email provider’s servers. A copy of their privacy policy may be provided upon reasonable and legitimate request.

Country of storage: UK and Canada.

Safeguard(s) used: our third party email provider and third party marketing platforms have self-certified compliance with the EU-U.S. Privacy Shield.

Blogs

Information you submit to us when you sign up for our blogs is transferred outside the EEA and stored on our third party mailing list provider’s servers. A copy of their privacy policy may be provided upon reasonable and legitimate request.

Country of storage: UK and Canada.

Safeguard(s) used: our third party email provider and third party marketing platforms have self-certified compliance with the EU-U.S. Privacy Shield

Google Analytics

Information collected by Google Analytics (your IP address and actions you take in relation to our website) is transferred outside the EEA and stored on Google’s servers. You can access Google’s privacy policy here: https://www.google.com/policies/privacy/

Country of storage: United States of America. This country is not subject to an adequacy decision by the European Commission.

Safeguard(s) used: Google has self-certified its compliance with the EU-U.S. Privacy Shield which is available here: https://www.privacyshield.gov/welcome. The EU-U.S. Privacy Shield is an approved certification mechanism under Article 42 of the General Data Protection Regulation, which is permitted under Article 46(2)(f) of the General Data Protection Regulation. You can access the European Commission decision on the adequacy of the EU-U.S. Privacy Shield here: http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm

 

Your rights in relation to your information

Subject to certain limitations on certain rights, you have the following rights in relation to your information, which you can exercise by writing to the data controller at info@ewysh.com.

• • • to request access to your information and information related to our use and processing of your information;
    • to request the correction or deletion of your information;
    • to request that we restrict our use of your information;
    • to receive information which you have provided to us in a structured, commonly used and machine-readable format (e.g. a CSV file) and the right to have that information transferred to another data controller (including a third party data controller);
    • to object to the processing of your information for certain purposes (for further information, see the section below entitled Your right to object to the processing of your information for certain purposes);
    • to withdraw your consent to our use of your information at any time where we rely on your consent to use or process that information. Please note that if you withdraw your consent, this will not affect the lawfulness of our use and processing of your information on the basis of your consent before the point in time when you withdraw your consent; and
    • the right not to be subject to a decision based solely on automated processing, including profiling which produces legal affects concerning you or similarly significantly affects you.

In accordance with Article 77 of the General Data Protection Regulation, you also have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or of an alleged infringement of the General Data Protection Regulation.

For the purposes of the UK, the supervisory authority is the Information Commissioner’s Office (ICO), the contact details of which are available here: https://ico.org.uk/global/contact-us/

Further information on your rights in relation to your personal data as an individual

The above rights are provided in summary form only and certain limitations apply to many of these rights. For further information about your rights in relation to your information, including any limitations which apply, please visit the following pages on the ICO’s website:

• • • https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/; and
    • https://ico.org.uk/for-the-public/is-my-information-being-handled-correctly/

You can also find out further information about your rights, as well as information on any limitations which apply to those rights, by reading the underlying legislation contained in Articles 12 to 22 and 34 of the General Data Protection Regulation, which is available here: http://ec.europa.eu/justice/data-protection/reform/files/regulation_oj_en.pdf

Verifying your identity where you request access to your information

Where you request access to your information, we are required by law to use all reasonable measures to verify your identity before doing so.

These measures are designed to protect your information and to reduce the risk of identity fraud, identity theft or general unauthorised access to your information.

How we verify your identity

Where we possess appropriate information about you on file, we will attempt to verify your identity using that information.
If it is not possible to identity you from such information, or if we have insufficient information about you, we may require original or certified copies of certain documentation in order to be able to verify your identity before we are able to provide you with access to your information.

We will be able to confirm the precise information we require to verify your identity in your specific circumstances if and when you make such a request.

Your right to object to the processing of your information for certain purposes

You have the following rights in relation to your information, which you may exercise in the same way as you may exercise by writing to the data controller a: info@ewysh.com

• • • to object to us using or processing your information where we use or process it in order to carry out a task in the public interest or for our legitimate interests, including ‘profiling’ (i.e. analysing or predicting your behaviour based on your information) based on any of these purposes; and
    • to object to us using or processing your information for direct marketing purposes (including any profiling we engage in that is related to such direct marketing).

You may also exercise your right to object to us using or processing your information for direct marketing purposes by:

• • • clicking the unsubscribe link contained at the bottom of any marketing email we send to you and following the instructions which appear in your browser following your clicking on that link;
    •  sending an SMS message containing only the words “OPT OUT” in reply to any marketing communication we send by text message; or
    • sending an email to info@ewysh.com, asking that we stop sending you marketing communications or by including the words “OPT OUT”.

For more information on how to object to our use of information collected from cookies and similar technologies, please see the section entitled How to accept or reject cookies in our Cookies Policy.

Sensitive Personal Information

‘Sensitive personal information’ is information about an individual that reveals their racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic information, biometric information for the purpose of uniquely identifying an individual, information concerning health or information concerning a natural person’s sex life or sexual orientation.

We do not knowingly or intentionally collect sensitive personal information from individuals, and you must not submit sensitive personal information to us.

If, however, you inadvertently or intentionally transmit sensitive personal information to us, you will be considered to have explicitly consented to us processing that sensitive personal information under Article (2)(a) of the General Data Protection Regulation. We will use and process your sensitive personal information for the purposes of deleting it.

Changes to our Privacy Policy

We update and amend our Privacy Policy from time to time.

Minor changes to our Privacy Policy

Where we make minor changes to our Privacy Policy, we will update our Privacy Policy with a new effective date stated at the beginning of it. Our processing of your information will be governed by the practices set out in that new version of the Privacy Policy from its effective date onwards.

Major changes to our Privacy Policy or the purposes for which we process your information

Where we make major changes to our Privacy Policy or intend to use your information for a new purpose or a different purpose than the purposes for which we originally collected it, we will notify you when you next log into out website or application, by email (where possible) or by posting a notice on our website.

We will provide you with the information about the change in question and the purpose and any other relevant information before we use your information for that new purpose.

Wherever required, we will obtain your prior consent before using your information for a purpose that is different from the purposes for which we originally collected it.

Children’s Privacy

Because we care about the safety and privacy of children online, we comply with the Children’s Online Privacy Protection Act of 1998 (COPPA). COPPA and its accompanying regulations protect the privacy of children using the internet. We do not knowingly contact or collect information from persons under the age of 18. The website is not intended to solicit information of any kind from persons under the age of 18 and it is recommended that any media you create for persons under the age of 18 is placed with a guardian.

It is possible that we could receive information pertaining to persons under the age of 18 by the fraud or deception of a third party. If we are notified of this, as soon as we verify the information, we will, where required by law to do so, immediately obtain the appropriate parental consent to use that information or, if we are unable to obtain such parental consent, we will delete the information from our servers. If you would like to notify us of our receipt of information about persons under the age of 18, please do so by sending an email to info@ewysh.com.

 

Copyright, credit and logo

This Privacy Policy is based on a General Data Protection Regulation (Regulation (EU) 2016/769) (GDPR) compliant template provided by GDPR Privacy Policy. For further information, please visit https://gdprprivacypolicy.org

The copyright in this Privacy Policy is either owned by, or licensed to, us and is protected by copyright laws around the world and copyright protection software. All intellectual property rights in this document are reserved.

Where we display the GDPR Privacy Policy logo on our website, this is used to indicate that we have adopted a privacy policy template provided by GDPR Privacy Policy as the basis for this Privacy Policy.