For the purposes of the Data Protection Act 1998 (the Act), Sunfloret is a data controller of your personal data, when it provides you with services or information related to those services. A data controller is the person who determines the purposes for which, and the manner in which, any personal data is processed. Data controllers have a responsibility to establish practices and policies in line with the Act.
Personal data means data that we store electronically, on a computer, or in certain paper filing systems, relating to a living individual who can be identified from that data (or from that data and other non-public personal data in our possession). Personal data can be factual or an opinion.
We process personal information about our:
- customers and clients;
- suppliers and services providers;
- advisers, consultants and other professional experts;
- complainants and enquirers.
We may collect and process the following personal data about you:
- personal details (such as name, date of birth, tax ID number, social security number);
- employment and education details;
- contact information including address, telephone number, email address;
- demographic information such as postcode, preferences and interests other information relevant to client surveys and/or offers;
- financial details;
- goods or services provided;
- your correspondence with us;
- personal data we receive from third parties in order to verify information that you have provided to us (such as your identity), or to protect our clients, suppliers and correspondents against fraud, such as payment processors, banks, credit reference agencies (but for identification and fraud-prevention purposes, not credit checking purposes), fraud checking agencies, providers of operational services, and regulators; and
- certain information which we automatically collect when your visit our website: technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, and information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our service number.
We also process sensitive classes of information that may include:
- physical or mental health details;
- racial or ethnic origin;
- religious or other beliefs of a similar nature;
- trade union membership.
We may also collect information about how users use our website and you may read about that below.
TELEPHONE CALLS: To make sure we follow your telephone instructions correctly, and to improve our service to you through training our staff or suppliers, we may also monitor and record telephone calls.
You retain the right to withhold any information from us but please be aware that some of our products and services may not be available to you if this information is not provided by you to us.
The personal information we collect and maintain about you is gathered both indirectly (for example, through the website’s technology) and directly (for example, when you request a quote). It is made up of information you give us through your use of our website and through our other communications with you such as by telephone, email, through our customer service agents and specialist sales of services consultants or in person. This includes information obtained when you send us a request to receive a quote, our newsletter or one of our free guides.
We will use your personal data in order to understand your needs and to provide you with Sunfloret language related services, including:
- providing you with the website and our services;
- carrying out our obligations arising from any contracts entered into between you and us and providing you with the services that you request from us;
- personalising aspects of our overall services for you;
- communicating with you;
- resolving disputes with you;
- administering our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- internal analysis and research (including, improving our site to ensure that content is presented in the most effective manner for you and for your computer);
- in our efforts to keep our site safe and secure;
- allowing you to participate in interactive features of our service, when you choose to do so;
- measuring or understanding the effectiveness of advertising we serve to you and others, and delivering relevant advertising to you;
- keeping internal record;
- improving our services;
- sending periodically promotional emails about new products, special offers or other information which we think you may find interesting using the email address which you have provided. You may opt out of this and if you do not wish to receive this information, please contact Sunfloret by one of the methods referred to on its website or email Sunfloret at email@example.com or use the un-subscribe mechanism in the email or text message;
- for contacting you for market research purposes from time to time. We may contact you by email, phone or mail. We may use the information to customise the website according to your interests;
- assisting in processing your requests for services offered by us;
- contacting you regarding your enquiries;
- providing you with clients support;
- complying with any applicable laws and regulations, including the transfer of personal information to regulatory and government authorities.
We may also use your personal data to send you information about our services, or services of third parties, where you have consented to this. You may opt out of this and if you do not wish to receive this information, please contact us by one of the methods referred to on our website.
We may retain and store some of your personal information, including your client profile information (such as your name and contact details) and transactional information (such as your teleconferencing history) to improve client satisfaction and to tailor our services to meet your individual needs.
We may also use and disclose information in aggregate (so that no individuals are identified) for marketing and strategic development purposes.
We will not disclose your personal data to any third parties except where necessary or required we share information with:
- family, associates and representatives of the person whose person data we are processing;
- employment and recruitment agencies;
- current, past and prospective employers;
- educators and examining bodies;
- central government;
- credit reference agencies;
- suppliers and service providers;
- debt collection and tracing agencies;
- persons who perform services on our behalf, including subcontractors;
- as required by law or regulation;
- to such persons as you have given your consent for us to do so;
- third parties in connection with criminal or civil proceedings.
We may provide your contact details included in your personal data to third parties for the purpose of their informing you about their services. You may opt out of this and if you do not wish us to disclose your personal information to such third parties, please contact us by one of the methods referred to on our website.
Under United Kingdom laws, anyone acting as a data controller must comply with the eight enforceable principles of good practice. These principles provide that personal data must be:
- Processed fairly and lawfully.
- Processed for limited purposes (consistent with those notified to you when we collected your personal data and other purposes permitted under the Act) and in an appropriate way.
- Adequate, relevant and not excessive for the purpose.
- Accurate and up-to-date.
- Not kept longer than necessary for the purpose.
- Processed in line with the rights of the person to whom they relate.
- Secure, that is that we must take appropriate security measures against unlawful or unauthorised processing of your personal data, and against the accidental loss of, or damage to, your personal data. Please see further below.
- Not transferred to people or organisations situated in countries without adequate protection.
We are committed to ensuring that your information is secure. We maintain physical, electronic, managerial and procedural safeguards designed to safeguard the personal data that we collect. We oblige our suppliers who might obtain your data to deliver required services on our behalf to do the same. We have implemented appropriate steps to help maintain the security of our information systems, processes and website and prevent the accidental destruction, loss or unauthorised disclosure of the information we collect.
All information you provide to us is stored on our secure servers.
Unfortunately, the transmission of information via the Internet is not 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. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
You may exercise your access rights to the personal data in accordance with the Data Protection Act 1998. You may request details of personal information which we hold about you by contacting us by one of the methods provided on our website.
You can correct incomplete or incorrect information in your personal data by contacting us by one of the methods provided on our website. We will promptly correct any information found to be incorrect.
The cookie is a software application that we store on your browser or the hard drive of your computer if you agree. It contains information that is transferred to your computer's hard drive, and which we have scripted so as to send information to our server.
We may use the following types of cookie:
- Cookie: Functional. Supplementary part of application. Stores additional information about the user's browsing needed to improve usability of our website.
- Google Analytics cookie: Analyse behaviour of users of users of our website on an aggregated basis.
- i18next: Functional. Adjusts language displayed on site according to user's selected locale.
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some such items. However, if you use your browser settings to block all such items (including where essential) you may not be able to access all or parts of our site.
If you have any questions regarding this Privacy Disclosure, you can contact us at firstname.lastname@example.org.
Last modified: 6 July 2015