1. Introduction
1.1 We are committed to safeguarding the privacy of our website visitors and customers.
1.2 This policy applies where we are acting as a data controller with respect to the personal data of such persons; 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 and services, we will ask you to consent to our use of cookies when you first visit our website.
1.4 This policy sets out the basis on which any personal data we collect from you, or that you provide to us, when you visit our website will be processed by us. It is important that you read this privacy policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements the other policies and notices and is not intended to override them. For the purposes of the Data Protection Act 1998 and, when it comes into force, the General Data Protection Regulation ((EU) 2016/679) (“GDPR”) and all successor legislation to the Data Protection Act 1998 and the GDPR (the “Data Protection Legislation”), the data controller is BL ACTON Ltd (company no. 11484986 ), Acre House, 11/15 William Road, London, United Kingdom, NW1 3ER.

2. Credit
2.1 This document was created using a template from Docular (https://seqlegal.com/free-legal-documents/privacy-policy).

3. Collecting personal information
3.1 We may collect, store and use the following kinds of personal information: (a) information about your computer and about your visits to and use of this website; (b) information that you provide to us when contacting us via our website; (c) information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters; (d) information that you provide to us when using the services on our website, or that is generated in the course of the use of those services.
3.2 Before you disclose to us the personal information of another person, you must obtain that person’s consent to both the disclosure and the processing of that personal information in accordance with this policy.
3.3 We collect information through Google Analytics. For information that Google may collect please see the Google Privacy & Terms at www.google.com/policies/privacy/partners/. If you do not want your data to be used by Google Analytics, please install the Google Analytics Opt-out Browser Add-on available from tools.google.com/dlpage/gaoptout
3.4 Some data will be collected automatically by Our Site, through Google Analytics. Other data will only be collected if you voluntarily submit it by emailing us. Depending upon your use of Our Site, we may collect some or all of the following data: (a) IP address (automatically collected); (b) Domain details (automatically collected); (c) Web browser type and version (automatically collected); (d) Operating system (automatically collected); (e) A list of URLs starting with a referring site, your activity on Our Site, and the site you exit to (automatically collected); (f) Geographic location.
3.5 We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

4. Using personal information
4.1 Personal information submitted to us through our website will be used for the purposes specified in this policy or on the relevant pages of the website.
4.2 We may use your personal information to: (a) administer our website and business; (b) personalise our website for you; (c) send you email notifications that you have specifically requested; (d) send you our email newsletter, if you have requested it.
4.4 Your privacy settings can be used to limit the publication of your information on our website, and can be adjusted using privacy controls on the website.
4.5 We will not, without your express consent, supply your personal information to any third party for the purpose of their or any other third party’s direct marketing.

5. Disclosing personal information
5.1 We may disclose your personal information to any of our employees, insofar as reasonably necessary for the purposes set out in this policy.
5.2 We may disclose your personal information to any member of our group of companies insofar as reasonably necessary for the purposes set out in this policy.
5.3 We may disclose your personal information: (a) to the extent that we are required to do so by law; (b) in connection with any ongoing or prospective legal proceedings; (c) in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).
5.4 Except as provided in this policy, we will not provide your personal information to third parties.
5.5 We only use the data collected by Google Analytics to understand how our website is used.
5.6 Some of our external third parties are based outside the European Economic Area (“EEA”) so their processing of your personal data may involve a transfer of data outside the EEA.
5.7 Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented: We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
5.8 Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

6. Retaining personal information
6.1 Our data retention policies and procedures are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal information.
6.2 Personal information that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
6.3 Notwithstanding the other provisions of this Section 6, we will retain documents (including electronic documents) containing personal data:
(a) to the extent that we are required to do so by law;
(b) if we believe that the documents may be relevant to any ongoing or prospective legal proceedings; and
(c) in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).
6.4 To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

7. Security of personal information
7.1 We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
7.2 However, the transmission of information via the internet is never completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk.
7.3 We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Amendments
8.1 We may update this policy from time to time by publishing a new version on our website.
8.2 You should check this page occasionally to ensure you are happy with any changes to this policy.

9. Your rights
9.1 Under the Data Protection Legislation you may be entitled to the following rights:
(a) Where you have provided your consent to the processing of your personal data for any purpose, you have the right to withdraw such consent at any time by contacting us at Acre House, 11/15 William Road, London, United Kingdom, NW1 3ER or by using our website contact form.
(b) You can ask us to rectify any inaccuracies in the personal information that we hold about you.
(c) To request the erasure of personal information that we hold about you where there is no good reason for us to continue processing it, where you have successfully exercised your right to object to processing, where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law.
(d) To object to our processing of your personal data where we are relying on a legitimate interest (or that of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
(e) To restrict our processing of your personal data (i) if you want us to establish the data’s accuracy; (ii) where our use of the data is unlawful but you do not want us to erase it; (iii) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (iv) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
(f) To request a copy of your personal data from us in a commonly used and machine-readable format or that we transmit your personal data to another data controller.
(g) Not to be subject to automated decision-making, including profiling, which has legal or other significant effects on you.
(h) To access information held about you. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
9.2 You can exercise any of the above rights at any time by contacting us at us at Acre House, 11/15 William Road, London, United Kingdom, NW1 3ER or by using our website contact form.

10. Third party websites
10.1 Our website includes hyperlinks to, and details of, third party websites.
10.2 We have no control over, and are not responsible for, the privacy policies and practices of third parties.
10.3 If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

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

12. Cookies
12.1 Our website uses cookies.
12.2 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.
12.3 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.
12.4 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
12.5 We use both session and persistent cookies on our website.
12.6 The names of the cookies that we use on our website, and the purposes for which they are used, are set out below:
(a) we use session cookies on our website to enable the use of your account on the website, administer the website, prevent fraud and improve the security of the website and to personalise the website for each user;
(b) we use persistent cookies on our website to recognise a computer when a user visits the website and to analyse the use of the website.
12.7 In most cases we will need your consent in order to use cookies on this website. The exception is where the cookies are essential in order for us to provide you with a service you have requested or to enable you to access and use our website. The use of such cookies is necessary for our legitimate interests in that we will be unable to provide you with the relevant service or to grant you access to our website without the use of such cookies.
12.8 When you first access our website, a cookie message will pop up in your browser asking you to confirm whether you consent to our use of non-essential cookies. By ticking the box, you are agreeing to our use of such cookies as set out in this policy
12.9 If you do not wish us to use cookies, please do not tick the box in the pop up when you first access our website.
12.10 You can withdraw your consent to the use of non-essential cookies on our website at any time. Generally you can also restrict, block or delete the cookies which are set by any websites by changing your internet browser settings. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website. If you delete cookies relating to this website we will not remember things about you, including your cookie preferences, and you will be treated as a first-time visitor next time you visit the site.
12.11 Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.
12.12 Cookie Audit:

13. Our details
13.1 This website is owned and operated by BL ACTON Ltd.
13.2 We are registered in England and Wales under registration number 11484986, and our registered office is at Acre House, 11/15 William Road, London, United Kingdom, NW1 3ER.
13.3 You can contact us by writing to the business address given above, or by using our website contact form.