1. Introduction

1.1    We are committed to safeguarding the privacy of our website visitors.

1.2    This policy applies where we are acting as a data controller with respect to the personal data of our website visitors; in other words, where we determine the purposes and means of the processing of that personal data.

1.3    We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website, we will ask you to consent to our use of cookies when you first visit our website.

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;

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

(d)    the legal bases of the processing.

2.1    We may process data about your use of our website (“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. This usage data may be processed for the purposes of analyzing 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.

2.2    We may process your website user 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.

2.3    We may process information that you provide to us for the purpose of subscribing to our email list (“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.

3. Providing your personal data to others

3.1    We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

3.2    Your personal data held in our website database will be stored on the servers of our hosting services providers.

3.3    We may disclose specify personal data category or categories to our suppliers or subcontractors insofar as reasonably necessary for analytic tracking or marketing.

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

4.1    This Section 4 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.

4.2    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.

4.3    Notwithstanding the other provisions of this Section 4, 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.

5. Your rights

5.1    In this Section 5, we have listed the rights that you have under data protection law.

5.2    Your principal rights under data protection law are:

(a)    the right to access – you can ask for copies of your personal data;

(b)    the right to rectification – you can ask us to rectify inaccurate personal data and to complete incomplete personal data;

(c)    the right to erasure – you can ask us to erase your personal data;

(d)    the right to restrict processing – you can ask use to restrict the processing of your personal data;

(e)    the right to object to processing – you can object to the processing of your personal data;

(f)    the right to data portability – you can ask that we transfer your personal data to another organization or to you;

(g)    the right to complain to a supervisory authority – you can complain about our processing of your personal data; and

(h)    the right to withdraw consent – to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.

5.3    These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by visiting https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.

5.4    You may exercise any of your rights in relation to your personal data by written notice to us, using the contact details set out below.

6. About cookies

6.1    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.

6.2    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.

6.3    Cookies do not typically contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.

7. Cookies that we use

7.1    We use cookies for the following purposes:

(a)    personalization – we use cookies to store information about your preferences and to personalize the website for you;

(b)    security – we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally;

(c)    advertising – we use cookies to help us to display advertisements that will be relevant to you;

(d)    analysis – we use cookies to help us to analyze the use and performance of our website and services; and

(e)    cookie consent – we use cookies to store your preferences in relation to the use of cookies more generally.

8. Cookies used by our service providers

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

8.2  We use Google Analytics. Google Analytics gathers information about the use of our website by means of cookies. The information gathered is used to create reports about the use of our website. You can find out more about Google’s use of information by visiting https://www.google.com/policies/privacy/partners/ and you can review Google’s privacy policy at https://policies.google.com/privacy.

9. Managing cookies

9.1  Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

(a)    https://support.google.com/chrome/answer/95647 (Chrome);

(b)    https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);

(c)    https://help.opera.com/en/latest/security-and-privacy/ (Opera);

(d)   https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);

(e)    https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac (Safari); and

(f)    https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).

9.2  Blocking all cookies will have a negative impact upon the usability of many websites.

9.3  If you block cookies, you will not be able to use all the features on our website.

10. Amendments

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

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

11. Our details

11.1  This website is owned and operated by DeSL.

11.2  Our principal place of business is at 2 Alexandra Gate Ffordd Pengam, Cardiff CF24 2SA.

11.3  You can contact us by using our website contact form found at https://www.desl.net/contact/