THE ADVISERS TOOLBOX LIMITED

PRIVACY AND COOKIES POLICY

 

The Advisers Toolbox Limited ("we", “us”) is committed to protecting and respecting your privacy. This Privacy and Cookies Policy (“Policy”) (together with and any other documents referred to therein) sets out the basis on which the personal data collected from you, or that you or a third party provide to us will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

 

For the purpose of the General Data Protection Regulation (GDPR), the UK General Data Protection Regulation (UK GDPR) and the UK Data Protection Act 2018 the Data Controller is The Advisers Toolbox Limited, registered in England and Wales with registered office at 52 Millpond Estate West Lane, London, England, SE16 4LZ(Company Number 12843203).

 

 

YOUR PERSONAL INFORMATION

 

Information we collect from you

 

We collect and process some or all of the following types of information from you in the course of your use of the-advisers-toolbox.co.uk (the “Website”) or providing our services:

 

• Information that you provide by filling in forms on the Website or filing in forms as part of the registration process. This includes information provided at the time of registering to use the Website, subscribing to our service, or requesting further information or services. We may also ask you for information when you report a problem with the Website.

 

• Specifically, we will collect personal details such as your name, email address, organisation name, job title or any information input by you when using the Website, or using our Services.

 

• payment information, such as bank card number, expiration date and security code.

 

• If you contact us, we may keep a record of that correspondence.

 

• Technical information such as details of your visits to the Website including, but not limited to, traffic data, location data, weblogs and other communication data, and the resources that you access.

 

• This Website is not intended for children and we do not knowingly collect data relating to children.

 

• We do not collect any special categories of data about you (ie information 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.

 

The provision of your name, and email address is required from you to enable us to provide log- in access to the Website. We will inform you at the point of collecting information from you, whether you are required to provide the information to us.

 

Information we collect from other sources

 

Where your employer sets up an organisation account, we will also obtain personal data from your employer, such as your name and email address.

If you are not our client or a member of a client’s staff, we have obtained your contact details from apollo.io as part of a marketing list we have purchased from them. For further information, please consult apollo.io’s privacy policy https://www.apollo.io/privacy-policy . You may unsubscribe from our marketing emails at any time.

USES MADE OF YOUR INFORMATION

 

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

 

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new customer	contact details	Performance of a contract with you
To process and deliver your order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us	payment information, and contact details	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include: Notifying you about changes to our EULA or privacy policy Notifying you about any maintenance to the Website to keep our records updated	contact details	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) In our legitimate interest
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	contact details, technical information	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
To use data analytics to improve our website, products/services, and experiences	technical information	Necessary for our legitimate interests (to keep our website updated and relevant, to develop our business and monitor visitors to our site and analyse their behaviour)
To make suggestions and recommendations to you about goods or services that may be of interest to you	(eg contact details and marketing preferences)	Necessary for our legitimate interests (to develop our products/services and grow our business)
If you are not yet our customer, to send you direct marketing emails	Name, work contact email address	Necessary for our legitimate interests (to develop our products/services and grow our business)

Change of purpose

 

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

 

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

 

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

 

Marketing

 

In addition to the above uses we may use your information (and, where you have consented, permit selected third parties to use your information), to notify you about goods or services which may be of interest to you. Where we do this, we will contact you by electronic means (e-mail) only if you have consented to such communication. If you do not want us to use your data in this way please either (i) tick the relevant box situated on the form on which we collect your data (for example, the registration form); (ii) unsubscribe from our electronic communications using the method indicated in the relevant communication; or (iii) inform us at any time by contacting us at the contact details set out below.

 

DISCLOSURE OF YOUR INFORMATION

 

We may disclose your personal data to third parties:

 

• in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets; or

 

• if we or substantially all of our assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets; or

 

• if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our End User Licence Agreement; or

 

• to protect our rights, property, or safety or that of our affiliated entities and our users and any third party we interact with the to provide the Website; or

 

• to our professional advisers, where needed.

 

Other than as set out above, and save insofar as is necessary in order for us to carry out our obligations arising from any contracts entered into between you and us, we will not share your data with third parties unless we have procured your express consent to do so.

 

STORING YOUR PERSONAL DATA

 

Security

 

We take appropriate measures to ensure that any personal data are kept secure, including security measures to prevent personal data from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal data to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality. Where we process payment transactions, these will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of the Website, you are responsible for keeping this password confidential.

 

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

 

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 the Website; 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.

 

Keeping your personal data up to date

 

If your personal details change you may update them by accessing the relevant page of the Website, or by contacting us using the contact details below. If you have any questions about how we use data collected which relates to you, please contact us by sending a request by email to the contact details below.

 

We will endeavour to update your personal data within seven (7) working days of any new or updated personal data being provided to us, in order to ensure that the personal data we hold about you is as accurate and up to date as possible.

 

How long we keep your personal data

 

• We will hold your personal data for no longer than necessary, but no longer than the period we are required to retain this information by applicable UK tax law (currently 6 years)

 

Where we store your personal data

 

The data that we collect from you may be transferred to, and stored at, a destination outside the United Kingdom and/or the European Economic Area ("EEA"). It may also be processed by staff operating outside the United Kingdom and/or EEA who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfilment of your orders, the processing of your payment details and the provision of support services.

 

In the event we transfer your personal data to a country without an adequacy decision from the United Kingdom, any such transfer will be subject to standard contractual clauses approved by the United Kingdom’s Information Commissioner’s Office and any other appropriate safeguards which may be applicable to such transfers.

 

If you would like further information please contact us (see ‘Contact’ link above or ‘Contact’ section below).

 

YOUR RIGHTS

 

Under the General Data Protection Regulation you have a number of important rights free of charge. In summary, those include rights to:

• access to your personal data and to certain other supplementary information that this Policy is already designed to address

• require us to correct any mistakes in your information which we hold

• require the erasure of personal data concerning you in certain situations

• receive the personal data concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations

• object at any time to processing of personal data concerning you for direct marketing

• object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you

• object in certain other situations to our continued processing of your personal data

• otherwise restrict our processing of your personal data in certain circumstances

• claim compensation for damages caused by our breach of any data protection laws.

For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation.

 

If you would like to exercise any of those rights, please:

• email, call or write to us

• let us have enough information to identify you (e.g. registration number (if any), organisation name, user name, registration details),

• let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill), and

• let us know the information to which your request relates, including any registration or reference numbers, if you have them

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 could refuse to comply with your request in these circumstances.

 

HOW TO COMPLAIN

 

We hope that we can resolve any query or concern you raise about our use of your information.

 

The General Data Protection Regulation and the UK GDPR also give you the right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state or the UK where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone: 0303 123 1113.

CHANGES TO OUR PRIVACY POLICY

 

We reserve the right to modify this Policy at any time. Any changes we may make to our Policy in the future will be notified and made available to you using the Website. Your continued use of the services and the Website shall be deemed your acceptance of the varied privacy policy.

INFORMATION ABOUT OUR USE OF COOKIES

 

We may collect information about you including where available your IP address, operating system and browser type, for systems administration. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual. We may, however, use such information in conjunction with the data we have about you in order to track your usage of our services.

 

Our Website uses cookies to distinguish you from other users of our Website. This helps us to provide you with a good experience when you browse our Website and also allows us to improve the Website. By using our Website you agree to our use of cookies as more specifically set out below.

 

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.

 

 

 

 

 

 

The cookies we use include:

 

• “Strictly necessary” cookies. These are cookies that are required for the operation of our Website. They include, for example, cookies that enable you to log into secure areas of our Website, use a shopping cart or make use of e-billing services.

• “Analytical” cookies. They allow us to recognise and count the number of visitors and to see how visitors move around the Website when they are using it. This helps us to improve the way our Website works, for example, by ensuring that users are finding what they are looking for easily.

• “Functionality” cookies. These are used to recognise you when you return to our Website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

 

Cookie Title   Cookie Name	Purpose	More information	Duration
joomla_remember_me_*	To allow a user to remain logged in between sessions. Essential for our site to function.	https://docs.joomla.org/Cookie_notification	3 months
* (session cookie)	To allow the site to distinguish between different users. Essential for our site to function.	https://docs.joomla.org/Cookie_notification	Session
joomla_user_state	To store the state of a user for ACL purposes. ie are they logged in? Essential for our site to function.	https://docs.joomla.org/Cookie_notification	Session
cookieconsent_status	To store your consent to accept or refuse optional cookies.	https://storejextensions.org/extensions/gdpr.html	Permanent (over 1 year)
_ga   _ga_*   Google Analytics	To use data analytics to improve our website, products/services, and experiences	https://support.google.com/analytics/answer/12159447?hl=en#:~:text=Google%20Analytics%20is%20a%20platform,provide%20insights%20into%20your%20business.	Permanent (over 1 year)

 

Cookies which are strictly necessary for the core functionality of the website are enabled by default, and set automatically at the point you access the website. Any cookies which are not strictly necessary for the functioning of the website will not be set unless you expressly consent to them through the cookie banner by clicking “accept”.

 

You may block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. 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 the Website.

 

Except for essential cookies, all cookies will expire at the end of the Subscription (as defined in the EULA).

CONTACT

 

All questions, comments and requests regarding this Privacy and Cookies Policy should be addressed to This email address is being protected from spambots. You need JavaScript enabled to view it. or write to us at our registered address.