Privacy and cookies policy
1. Introduction
1.1. We are committed to safeguarding the privacy of our website visitors.
1.2. This policy applies where we are acting as a data controller with respect to the personal data of such persons; in other words, where we determine the purposes and means of the processing of that personal data.
1.3. Our website incorporates privacy controls which affect how we and our partners will process your personal data. By using the privacy controls, you can choose how your personal data is used for the purposes of personalised ads and content, ad and content measurement, audience insights and product development. You can access the privacy controls by clicking on 'Privacy and cookie settings' at the bottom of any page. You can also click this button to revoke your consent and access the controls:
1.4. 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.
1.5. In this policy, "we", "us" and "our" refer to Recoreo Ltd. For more information about us, see Section 16.
2. The personal data that we collect
2.1. In this Section 2 we have set out the general categories of personal data that we process.
2.2. We may process data enabling us to get in touch with you ("contact data"). The contact data may include your name, email address, telephone number, postal address and/or social media account identifiers. The source of the contact data is you. If you log into our website using a social media account, we will obtain elements of the contact data from the relevant social media account provider.
2.3. We may process data about your use of our website and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is Google Analytics, FullStory and Mouseflow.
2.4. Please do not supply any other person's personal data to us, unless we prompt you to do so.
3. Purposes of processing and legal bases
3.1. In this Section 3, we have set out the purposes for which we may process personal data and the legal bases of the processing.
3.2. Operations - We may process your personal data for the purposes of operating our website and providing our services. The legal basis for this processing is our legitimate interests, namely the proper administration of our website, services and business.
3.3. Relationships and communications - We may process contact data, customer relationship data and/or communication data for the purposes of managing our relationships, communicating with you (excluding communicating for the purposes of direct marketing) by email and/or telephone, providing support services and complaint handling. The legal basis for this processing is our legitimate interests, namely communications with our website visitors and service users, enabling the use of our services, and the proper administration of our website, services and business.
3.4. Personalisation - We and our advertising partners may process service data and/or usage data for the purposes of personalising the content and advertisements that you see on our website and through our services to ensure that you only see material that is relevant to you. The legal basis for this processing is consent.
3.5. Direct marketing - We may process contact data and/or customer relationship data for the purposes of creating, targeting and sending direct marketing communications by email. The legal basis for this processing is consent.
3.6. Research and analysis - We may process usage data and/or service data for the purposes of researching and analysing the use of our website and services, as well as researching and analysing other interactions with our business. The legal basis for this processing is our legitimate interests, namely monitoring, supporting, improving and securing our website, services and business generally.
3.7. Record keeping - We may process your personal data for the purposes of creating and maintaining our databases, back-up copies of our databases and our business records generally. The legal basis for this processing is our legitimate interests, namely ensuring that we have access to all the information we need to properly and efficiently run our business in accordance with this policy.
3.8. Security - We may process your personal data for the purposes of security and the prevention of fraud and other criminal activity. The legal basis of this processing is our legitimate interests, namely the protection of our website, services and business, and the protection of others.
3.9. Insurance and risk management - We may process your personal data where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks and/or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
3.10. Legal claims - We may process your personal data where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
3.11. Legal compliance and vital interests - We may also process your personal data where such processing is necessary for compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person.
4. Providing your personal data to others
4.1. We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.
4.2. We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice.
4.3. Your personal data held in our website database will be stored on the servers of our hosting services providers Akamai Technologies International AG and its Non-North American Affiliates (“Akamai Switzerland”).
4.4. In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
5. International transfers of your personal data
5.1. In this Section 5, we provide information about the circumstances in which your personal data may be transferred to a third country under UK and/or EU data protection law.
5.2. We may transfer your personal data from the European Economic Area (EEA) to the UK and process that personal data in the UK for the purposes set out in this policy, and may permit our suppliers and subcontractors to do so, during any period with respect to which the UK is not treated as a third country under EU data protection law or benefits from an adequacy decision under EU data protection law; and we may transfer your personal data from the UK to the EEA and process that personal data in the EEA for the purposes set out in this policy, and may permit our suppliers and subcontractors to do so, during any period with respect to which EEA states are not treated as third countries under UK data protection law or benefit from adequacy regulations under UK data protection law.
6. Retaining and deleting personal data
6.1. This Section 6 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
6.2. Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
6.3. We will retain your personal data as follows:
- contact data will be retained for a minimum period of 1 year following the date of the most recent contact between you and us, and for a maximum period of 3 years following that date;
- customer relationship data will be retained for a minimum period of 6 months following the date of termination of the relevant customer relationship and for a maximum period of 1 year following that date;
- usage data will be retained for 3 years following the date of collection; and
6.4. Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
7. Security of personal data
7.1. We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.
7.2. We will store your personal data on secure servers, personal computers and mobile devices.
7.3. The following personal data will be stored by us in encrypted form: your name and contact information.
7.4. You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
8. Your rights
8.1. In this Section 8, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
8.2. Your principal rights under data protection law are:
- the right to access - you can ask for copies of your personal data;
- the right to rectification - you can ask us to rectify inaccurate personal data and to complete incomplete personal data;
- the right to erasure - you can ask us to erase your personal data;
- the right to restrict processing - you can ask us to restrict the processing of your personal data;
- the right to object to processing - you can object to the processing of your personal data;
- the right to data portability - you can ask that we transfer your personal data to another organisation or to you;
- the right to complain to a supervisory authority - you can complain about our processing of your personal data; and
- the right to withdraw consent - to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.
8.3. You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. You can request your personal data by emailing [email protected].
8.4. You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
8.5. In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
8.6. In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
8.7. You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
8.8. You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
8.9. To the extent that the legal basis for our processing of your personal data is consent and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
8.10. If you consider that our processing of your personal data infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. In relation to complaints under EU data protection law, you may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement; in relation to complaints under UK data protection law, you should do so in the UK.
8.11. To the extent that the legal basis for our processing of your personal data is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
8.12. You may exercise any of your rights in relation to your personal data by emailing [email protected].
9. Third party websites
9.1. Our website includes hyperlinks to, and details of, third party websites.
9.2. In general we have no control over, and are not responsible for, the privacy policies and practices of third parties.
10. About cookies
10.1. A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
10.2. Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
10.3. Cookies may not contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.
11. Cookies that we use
11.1. We use cookies for the following purposes:
-
personalisation - we use cookies to store information about
your preferences and to personalise our website for you. Cookies used for
this purpose are:
Cookie name Purpose gglpg Stores your landing page to tailor the site experience gg_random_id Random number between 0 and 1 used to test new site experiences
12. Cookies used and personal data processing by our service providers
12.1. Our service providers use cookies and those cookies may be stored on your computer when you visit our website.
12.2 We use Google Analytics, which gathers information about the use of our website and uses cookies for this purpose. We use the information gathered by Google Analytics to create reports about the use of our website. You can find out more about Google's use of information by visiting https://policies.google.com/technologies/partner-sites and you can review Google's privacy policy at https://policies.google.com/privacy. The cookies used by Google Analytics are named _ga, _gid and _ga_GFNPSLFB8Y.
12.3. We publish Google AdSense advertisements on our website, together with advertisements from the following advertisers and advertising networks that are distributed by Google:
12.4 The advertisements we display on our website may be personalised to reflect your interests. To help determine your interests Google and its partners use cookies. The cookies are used to track your visits to our website and your visits to other websites. You can opt out of Google's personalised advertising or customise the advertising that you see by visiting https://adssettings.google.com/ and https://myadcenter.google.com/. You can opt out of third party cookie use for personalised advertising by visiting https://youradchoices.com. To find out more about Google's use of personal data, you can review Google's privacy policy at https://policies.google.com/privacy.
12.5. We partner with Microsoft Clarity and Microsoft Advertising to capture how you use and interact with our website through behavioral metrics, heatmaps, and session replay to improve and market our products/services. Website usage data is captured using first and third-party cookies and other tracking technologies to determine the popularity of products/services and online activity. Additionally, we use this information for site optimization, fraud/security purposes, and advertising. For more information about how Microsoft collects and uses your data, visit the Microsoft Privacy Statement.
13. Managing cookies
13.1. Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser and from version to version. You can obtain up-to-date information about managing cookies via these links:
- https://support.google.com/chrome/answer/95647 (Chrome);
- https://support.mozilla.org/en-US/products/firefox/privacy-and-security (Firefox);
- https://help.opera.com/en/latest/security-and-privacy/ (Opera);
- https://support.apple.com/en-gb/guide/safari/welcome/mac (Safari); and
- https://support.microsoft.com/en-gb/windows/microsoft-edge-browsing-data-and-privacy-bb8174ba-9d73-dcf2-9b4a-c582b4e640dd (Edge)
13.2. Blocking all cookies will have a negative impact upon the usability of many websites.
13.3. If you block cookies, you will not be able to use all the features on our website.
14. Cookie preferences
14.1. You can manage your preferences relating to the use of cookies on our website by using our privacy controls. By using the privacy controls, you can choose how your personal data is used for the purposes of personalised ads and content, ad and content measurement, audience insights and product development. You can access the privacy controls by clicking on 'Privacy and cookie settings' at the bottom of any page. You can also click this button to revoke your consent and access the controls:
15. Amendments
15.1. We may update this policy from time to time by publishing a new version on our website.
15.2. You should check this page occasionally to ensure you are happy with any changes to this policy.
16. Our details
16.1. This website is owned and operated by Recoreo Ltd.
16.2. We are registered in England and Wales under registration number 10005255, and our registered office is at Recoreo Ltd, 20-22 Wenlock Road, London, England, N1 7GU.
16.3. You can contact us by email, using [email protected].
17. Data protection registration
17.1. We are registered as a data controller with the UK Information Commissioner's Office.
17.2. Our data protection registration number is ZA170042