Privacy Policy

Version: 30 July 2024

This Privacy Policy sets out how we, Selectabase Limited, collect, store and use information about you when you use or interact with our website, test.selectabase.co.uk (our website) and where we otherwise obtain or collect information about you.

Contents

1. Summary
2. Our details
3. Information we collect when you contact us
4. Information we collect when you visit or interact with our website
5. Information obtained from third parties for use in our direct marketing products and services
6. Our use of automated decision-making and profiling
7. Disclosure and additional uses of your information
8. How long we retain your information
9. How we secure your information
10. Transfers of your information outside the UK and European Economic Area
11. Your rights in relation to your information
12. Your right to object to the processing of your information for certain purposes
13. Sensitive Personal Information
14. Changes to our Privacy Policy
15. Children’s Privacy
16. California Do Not Track Disclosures
17. CCTV
18. Copyright

1. Summary

This section summarises 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: Selectabase Limited
• How we collect or obtain information about you:

• When you provide it to us (e.g. by contacting us, placing an order on our website, by subscribing for our newsletter and through creating an account),
• From your use of our website, using cookies and similar technologies, and from third party suppliers
• Information we collect: name, contact details, email address, telephone number, date of birth, IP address, profile information, 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), your company’s name or business name, your company registration number, ICO registration number and FCA number (if applicable)
• How we use your information: for administrative and business purposes (particularly to contact you and process orders you place on our website), to improve our business and website, to fulfil our contractual obligations, to advertise our goods and services, 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 run our business, to our service providers, to fulfil any contracts we enter into with you, and where required by law or to enforce our legal rights
• Do we sell or pass on your information to third parties (other than in the course of a business sale or purchase or similar event)? Not where you have supplied the information to us directly. We do, however, obtain information from third party suppliers for use in our goods and services and this involves the sale of personal information to third parties. We will only sell your information to third parties if it is included in the data we have acquired from our third party suppliers in accordance with data protection rules and regulations and where it is in our legitimate interests and/or the legitimate interests of third parties to do so for direct marketing and profiling purposes. For further information, please see the section below entitled 5. Information obtained from third parties for use in our direct marketing products and services
• How long we retain your information: for no longer than necessary, taking into account any legal obligations we have (e.g. to maintain records for tax 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 8. 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 8. 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 necessary
• Use of cookies and similar technologies: we use cookies and similar information-gathering technologies including essential, functional and analytical cookies. For more information, please visit our cookies policy here: https://test.selectabase.co.uk/cookies/
• Transfers of your information outside the UK and European Economic Area: In certain circumstances, we will transfer your information outside of the UK and European Economic Area, including to the USA. Where we do so, we will ensure appropriate safeguards are in place, including, for example, that the third parties we use who transfer your information outside the UK and European Economic Area have self-certified themselves as compliant with the EUU.S. Privacy Shield
• Use of automated decision-making and profiling: we use automated profiling on our website through our use of web analytics. We do not use automated decision-making. For further information, please see 6. Our use of automated decision-making and profiling below
• 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, 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 13. Sensitive Personal Information

2. Our details

Data Controller

The data controller is Selectabase Limited, a limited company registered in England and Wales (company registration number 05234487). Our registered address is The Archive Centre, Honeywood.

Road, Dover, Kent, CT16 3EH. You can contact the data controller by writing to Selectabase Limited, The Archive Centre, Honeywood Road, Dover, Kent, CT16 3EH or sending an email to admin@selectabase.co.uk.

If you have any questions about this Privacy Policy, please contact the data controller using the contact details of the Data Protection Officer below:

Data Protection Officer

We have appointed GRCI Law Limited, to act as our DPO.

Postal address

DQM GRC Limited

Cressex Business Park,

Wellington Road,

High Wycombe HP12 3PR

Email: selectabasedpo@dqmgrc.com  Tel: +44 (0) 1494 442900

EU Representative

We have appointed IT Governance Europe Limited to act as our EU Representative.

If you wish to exercise your rights under the EU General Data Protection Regulation (GDPR), or have any queries in relation to your rights or privacy matters generally please contact our Representative using these contact details. Please ensure you include our company name in any correspondence.

EU Representative

IT Governance Europe

The Mill, Newtown Link Rd,
Stagreenan, Drogheda, Co. Louth, A92 CD3D, Ireland

Email: eurep@itgovernance.eu

3. 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 7. Disclosure and additional uses of your information.

Visit the following link to Your Data Rights – https://test.selectabase.co.uk/your-data-rights/

Information collected	Legal basis for processing		Transfer and storage
Email When you send an email to the email address displayed on our website we 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).	Legitimate interests(Article 6(1)(f) of the General Data Protection Regulation“GDPR”). We have a legitimate interest in responding to enquiries and messages we receive and keeping records of correspondence.Necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the GDPR). 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).	We use a third-party email provider to store emails you send us. Our third-party email provider is Intermedia.Emails you send us are stored within the United Kingdom.
Contact form When you contact us using our contact form, we collect your name, first name, email address, phone number and postcode. 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 form, you will not be able to submit the contact form and we will not receive your enquiry.		Messages you send us via our contact form will be stored in our servers in the United Kingdom.
Phone When you contact us by phone, we collect your phone number and any information provide to us during your conversation with us.		Information about your call, such your phone number and the date and time of your call, is processed by our third-party telephone service provider and stored in the United Kingdom.Calls are recorded for training and monitoring purposes. The retention period for recorded calls is 2 years.
Post If you contact us by post, we will collect any information you provide to us in any postal communications you send us.		Information you send us by post is stored in the United Kingdom.

4. Information we collect when you visit or interact with our website

We collect and use information from website visitors in accordance with this section and the section entitled 7. Disclosure and additional uses of your information.

Visit the following link to Your Data Rights – https://test.selectabase.co.uk/your-data-rights/

Information collected	Legal basis for processing	Transfer and storage
Web server log information We use our own web server to host our website. Our web 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 collect and store 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, we do not make, nor do we allow our hosting provider to make, any attempt to identify you from the information collected via server logs.	Compliance with a legal obligation to which we are subject (Article 6(1)(c) of theGDPR). 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.Legitimate interests (Article 6(1)(f) of the GDPR). We have a legitimate interest in using your information for the purposes of ensuring network and information security.	Our web server is located in the United Kingdom.
Cookies Cookies are data files which are sent from a website to a browser to record information about users for various purposes.We use cookies on our website, including essential, functional and analytical cookies. For further information on how we use cookies, please see our cookies policy which is available here: https://test.selectabase.co.uk/cookies/You can reject some or all of the cookies we use on or via our website by changing your browser settings 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 allaboutcookies.org or see our cookies policy.	Consent (Article 6(1)(a) of he GDPR).	Please see our cookie policy for further information: https://test.selectabase.co.uk/cookies/
E-newsletter When you sign up for our e-newsletter, to receive information, news and offers about our products, services and promotions from us, by contacting our sales staff and requesting to be added to our e-newsletter mailing list, we collect your name and email address.	Consent (Article 6(1)(a) of the GDPR).	We use a third-party provider to send out our e-newsletter and administer our mailing list, called Mailgun. You can access their privacy policy here: www.mailgun.com/privacy-policy/Information you submit to subscribe for our e-newsletter will be stored within the European Economic Area on Mailgun’s.
Registering on our website When you register and create an account on our website, we collect your name, title, email address, company, address, telephone number, IP address and any other information you provide to us when you complete the registration form, including any optional information (if applicable), such as your industry, company registration number, ICO registration number and FCA number.If you do not provide the mandatory information required by the registration form, you will not be able to register or create an account on our website.If you do not supply the optional information requested by our registration form, this may affect the time it takes for us to process your order and/or our ability to understand your requirements for our services.	Legitimate interests (Article 6(1)(f) of the GDPR). We have a legitimate interest in registering and administering accounts on our website to provide you the ability to upload feedback and to facilitate the running and operation of our business.	The information you submit will be stored in our servers in the United Kingdom.
When you place an order on our website  Mandatory Information When you place an order for goods or services on our website, we collect your name, title, email address, company name, telephone number, billing/shipping address and IP address.If you do not provide this information, you will not be able to purchase goods or services from us on our website or enter into a contract with us.	Necessary to perform a contract (Article 6(1)(b) of the GDPR). We need the mandatory information collected by our checkout form to establish who the contract is with and to contact you to fulfil our obligations under the contract, including sending you receipts and order confirmations.Compliance with a legal obligation (Article 6(1)(c) of the GDPR). We have a legal obligation to issue you with an invoice for the goods and services you purchase from us where you are VAT registered and we require the mandatory information collected by our checkout form for this purpose. We also have a legal obligation to keep accounting records, including records of transactions.Legitimate interests (Article 6(1)(f)). We collect your phone number for our legitimate interest of more easily and effectively contacting you in relation to your order and your account.	The information you submit will be stored in our servers in the United Kingdom.
Optional information We also collect optional information from you, such as your industry, company registration number and ICO registration number.	Your consent (Article 6(1)(a) GDPR). You consent to us processing any optional information you provide by providing it to us.
Processing your payment After you place an order on our website, or offline via our contact number, you will need to make payment for the goods or services you have ordered. In order to process your payment, we use a third party payment processor. Your payment will be processed by Sage Pay.Sage Pay collects, uses and processes your information, including payment information, in accordance with their privacy policies. You can access their privacy policies via the following link: https://www.sagepay.co.uk/policies/privacy-policy/	Necessary to perform a contract (Article 6(1)(b) of the GDPR). To fulfil your contractual obligations to pay for the goods or services you have ordered from us.	Sage Pay may transfer information relating to your transaction and the processing of your transaction outside the European Economic Area. Where they do so, they will putappropriate safeguards in place.For further information about the safeguards used when your information is transferred outside the EuropeanEconomic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.

5. Information obtained from third parties for use in our direct marketing products and services

This section sets out how we obtain information about you from third party data suppliers (such as Experian – see https://www.experian.co.uk/privacy/consumer-information-portal/) from which we acquire business to business and business to consumer data, for use in our direct marketing products and services.

How we obtain information about you from suppliers

Our suppliers (such as Experian – see https://www.experian.co.uk/privacy/consumer-information-portal/) obtain information via third party forms which set out how your personal information will be used and that it will be transferred to third parties for their direct marketing and profiling purposes. They then transfer this information to us.

Once we have obtained your information from our suppliers, we may either use this information for our own direct marketing and profiling purposes and/or pass this information on to third parties for their direct marketing and profiling purposes.

Information we obtain from third party suppliers

Information we obtain from third party suppliers will include:

• Business to business contact data such as name, business name, address, telephone number, email address (for incorporated companies only), Companies House information, and business profiling information. This data is screened for use in the direct marketing channels postal, telephone and corporate email marketing
• Business to consumer contact data such as name, address, and consumer profiling information. Used for postal marketing only. This data is screened for use in the direct marketing channel postal marketing only

Legal basis for processing: our and third parties’ legitimate interests (Article 6(1)(f) of the GDPR).

Legitimate interests: where a third party supplier has shared information about you with us (and you have not objected to the processing of your information) we will have a legitimate interest in processing that information for our own direct marketing and profiling purposes and the legitimate interests of third parties for their direct marketing and profiling purposes.

Profiling

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

We analyse your information based on various criteria, such as geographical area, business size and type to determine which data is likely to be the most relevant for our and/or our clients’ direct marketing purposes. By analysing and categorising your information based on certain criteria, we are able to ensure that the direct marketing conducted by us and our clients is as relevant and targeted as it can be and to reduce costs.

Who we supply your data to

Your data will be provided to carefully selected reputable organisations (our clients). We and our clients will only use your data for: marketing communications, profiling (including market research and analysis and segmentation).

We and our clients operate in the following areas for use in the manners described above – Retail, Financial Services, Lifestyle, Household & Technology, and Public Sector.

Retail	Financial Services	Lifestyle	Household & Technology	Public Sector
Fashion & Leisure Goods	Comparison Websites	Astrology	Electric, Gas & Water Utilities	Government
Food & Drink	FinancialProviders/Services	Automotive	Multi-Utilities	Legal Services
Producers & Retailers	Insurance Providers	Competition Sites	Home Improvement	Not for Profit
Marketing & Advertising	Shares	Education & Research	Construction
General Retailers	Prospecting	Self Improvement	Household Goods & Services
FMCG		Gambling	IT Services & Software
Mail Order		Health & Welfare	Media, TV & Radio
Prospecting		Parenting	Film online & Print
		Subscription Services	Real Estate
		Entertainment/Gaming/Leisure	Telecommunications
		Charity
		Travel

If you wish to opt out from Selectabase providing your details to third parties please visit the following link – https://test.selectabase.co.uk/data-optout

Visit the following link to Your Data Rights – https://test.selectabase.co.uk/your-data-rights/

For further information and details on how Experian obtains and utilises its personal data for direct marketing purposes please visit the following link – https://www.experian.co.uk/privacy/consumer-information-portal/

6. Our use of automated decision-making and profiling

We use automated profiling on or in relation to our website. We do not consider that this has any legal effect on you or similarly significantly affects you. We do not use automated decision-making.

You have the right to object to our use of automated 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, which is available here:
https://test.selectabase.co.uk/cookies/

Automated Profiling

Automated profiling is profiling carried out by a machine without significant human involvement.

Use of automated profiling for web analytics:  Our web analytics service, Google Analytics uses 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 https://test.selectabase.co.uk/cookies/).

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 rejecting cookie, more information found on our cookies policy here: https://test.selectabase.co.uk/cookies/) and your location will be analysed based on your IP address.

Legal basis for processing: consent (Article 6(1)(a) of the GDPR). Consent: you give your consent to our use of Google Analytics by turning on Google Analytics using our cookie control tool.

7. Disclosure and additional uses of your information

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

Please note, this section describes ordinary disclosures to third party service providers and legal reasons. For information about how we disclose information to our clients which we have obtained about you from third party suppliers, please see the section above entitled 5. Information obtained from third parties for use in our direct marketing products and services.

Disclosure of your information to service providers and other third parties in the ordinary course of business

Third party to whom your information is disclosed	Legal basis for processing	Transfer and storage
Regular 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 the following:• Telephone provider (UK),• Email provider (UK),• Mailing house provider (UK),• Mailing list provider (EEA),• IT service provider (UK),• Web developer (UK), and• Hosting provider (UK)Apart from our mailing list provider, which are located in the EEA, our service providers are located in the United Kingdom.Your information will be shared with these 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 all 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 by email and we will provide you with such information where you have a legitimate reason for requesting it (where we have shared your information with such service providers, for example).	Legitimate interests (Article 6(1)(f) of the GDPR). 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.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 GDPR). 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.	Our  service providers are located in the United Kingdom.

Other third parties
Google Google collects information through our use of Google Analytics (respectively on our website) 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://policies.google.com/technologies/partner-sitesYou can opt out of Google Analytics in general by installing the browser plugin here: https://tools.google.com/dlpage/gaoptout/	Consent (Article 6(1)(a) of the GDPR).	Information collected by Google Analytics is stored outside the European Economic Area on Google’s servers in the USA.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.
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.	Legitimate interests (Article 6(1)(f) of the GDPR). We have a legitimate interest in running and managing our business efficiently.	Our accountants are located in the United Kingdom.
Business partners Business partners are businesses we work with which provide goods and services which are complementary to our own or which allow us to provide goods or services which we could not provide on our own. We share information with our business partners where you have requested services which they provide whether independently from, or in connection with or own services.	Legitimate interests (Article 6(1)(f) of the GDPR). We have a legitimate interest in running and managing our business efficiently.	Our business partners are located in the United Kingdom.
Advisors Occasionally, we obtain advice from advisors, such as accountants, financial advisors, lawyer 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.	Legitimate interests (Article 6(1)(f) of the GDPR). We have a legitimate interest in running and managing our business efficiently.	Our advisors are located in the United Kingdom.
Affiliates  Affiliates are individuals or entities we work with to promote our business or their own business by various means, including by advertising our services on their websites, for example. Affiliates will share information with us and we will share information with them where you have expressed an interest in our products or services.	Legitimate interests (Article 6(1)(f) of the GDPR). We have a legitimate interest in running and managing our business efficiently.	Our affiliates are located in the United Kingdom.
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.	Legitimate interests (Article 6(1)(f) of the GDPR). We have a legitimate interest in running and managing our business efficiently.	Our insurers are location in the United Kingdom.

Disclosure of your information for legal reasons

Legal reason for disclosure	Legal basis for processing
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 a fraud or a cyber 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.	Legitimate interests (Article 6(1)(f) of the GDPR). Preventing crime or suspected criminal activity (such as fraud).
In connection with the enforcement or potential enforcement 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 debt collection agencies if you do not pay amounts owed to us when you are contractually obliged to do so. 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).	Legitimate interests (Article 6(1)(f) of the GDPR). 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.	Legitimate interests (Article 6(1)(f) of the GDPR). 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.	Compliance with a legal obligation (Article 6(1)(c) of the GDPR). 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).Legitimate interests (Article 6(1)(f)). 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.

8. 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 retain information on our server logs for 52 days.

Order information: when you place an order for goods and services, we retain that information for seven years following the date on which you placed your order for tax purposes and to defend against legal claims.

Correspondence and enquiries: when you make an enquiry, or correspond with us for any reason, whether by email, via post or by phone, we will retain your information for as long as it takes to respond to and resolve your enquiry, and then for 3 further years on our back-up servers after which point we will delete your information.

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

Purchased data: we retain this information for a maximum period of 30 months after the date of purchase by one of our clients.

Account information: we retain your account information for as long as you have an active account. We delete account information after 24 months of inactivity.

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 recordkeeping 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; and
• any relevant surrounding circumstances (such as the nature and status of our relationship with you)

9. How we secure your information

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 (amongst others):

• only sharing and providing access to your information to the minimum extent necessary, subject to confidentiality restrictions where appropriate, and on an anonymised basis wherever appropriate;
• using secure servers and facilities to store your information;
• verifying the identity of any individual who requests access to information prior to granting them access to information; and
• using Secure Sockets Layer (SSL) software to encrypt any information you submit to us via any forms on our website

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.

10. Transfers of your information outside the UK and the European Economic Area

Your information will be transferred and stored outside the UK and the European Economic Area (EEA) in the circumstances set out below.

We will also transfer your information outside the UK and the EEA or to an international organisation in order to comply with legal obligations to which we are subject (compliance with a court order, for example). Where we are required to do so, we will ensure appropriate safeguards and protections are in place.

When data is transferred	Country of storage	Safeguard(s) used
Payment processing When you pay for goods and services in relation to our website, if you use Sage Pay, Sage Pay may transfer information about your order and the processing of your order outside the European Economic Area.	Various countries outside the UK and EEA.	Appropriate safeguards will be put in place. You can access Sage Pay’s privacy policy here.
Google Analytics Information collected by Google Analytics (your IP address and actions you take in relation to our website) is transferred outside theEEA and stored on Google’s servers. You can access Google’s privacy policy here.	USA. This country is not subject to an adequacy decision by the European Commission.	Google has self-certified its compliance with the EU-U.S. Privacy Shield which is available here. The EU-U.S. Privacy Shield is an approved certification mechanism under Article 42 of the GDPR, which is permitted under Article 46(2)(f) of the GDPR. You can access the European Commission decision on the adequacy of the EU-U.S. Privacy Shield here.

11. 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 Selectabase Limited, The Archive Centre, Honeywood Road, Dover, Kent, CT16 3EH, sending an email to admin@selectabase.co.uk, or visiting the following link to Your Data Rights – https://test.selectabase.co.uk/your-data-rights/:

• 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); and
• 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

In accordance with Article 77 of the GDPR, 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 GDPR.

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-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/ and
• https://ico.org.uk/your-data-matters/

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 GDPR, which is available here:
https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32016R0679

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.

12. 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 Selectabase Limited, The Archive Centre, Honeywood Road, Dover, Kent, CT16 3EH , sending an email to admin@selectabase.co.uk, or visiting the following link to Your Data Rights – https://test.selectabase.co.uk/your-data-rights/:

• 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 email to admin@selectabase.co.uk:, asking that we stop sending you marketing communications or by including the words “OPT OUT”; or
• using our opt-out request form which is available here: selectabase.co.uk/data-protection/data-optout/

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, which is available here: https://test.selectabase.co.uk/cookies/

13. 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 9(2)(a) of the GDPR. We will use and process your sensitive personal information for the purposes of deleting it.

14. 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 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.

15. 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.

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 admin@selectabase.co.uk.

16. California Do Not Track Disclosures

“Do Not Track” is a privacy preference that users can set in their web browsers. When a user turns on a Do Not Track signal in their browser, the browser sends a message to websites requesting that they do not track the user. For information about Do Not Track, please visit https://allaboutdnt.com/.

At this time, we do not respond to Do Not Track browser settings or signals. In addition, we use other technology that is standard to the internet, such as cookies to track visitors to the website. Those tools may be used by us and by third parties to collect information about you and your internet activity, even if you have turned on the Do Not Track signal. For information on how to opt out from tracking technologies used on our website, see our cookies policy which is available here: https://test.selectabase.co.uk/cookies/

17. CCTV

We use CCTV on and around our premises for the prevention and detection of crime and to safeguard our staff and visitors.

Legal basis for processing: Legitimate interests (Article 6(1)(f)) of the GDPR. We have a legitimate interest in carrying out these activities.

CCTV footage is stored for 14 days on our secure servers in the UK.

18. Copyright

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