2COMMS may change this policy from time to time by updating this policy, we advise you to regularly check to ensure we respect and comply with any applicable law and regulation regarding how we collect and process your personal information we may collect . This policy was last updated on 10 September 2021.
2. How we use your personal data
- This section provides you with information about:
- what personal data we hold and process;
- in respect of personal data that we did not collect from you directly, where we obtained that data from, and what types of data we have collected;
- the purposes for which we may process your personal data; and
- the legal grounds on which we process your data.
- Contact data. We may process information that you provide to us ("contact data"). This contact data may include your name, address, telephone number, email address, and employment details, and may be provided through our website. We may use this data to provide you with a quote, and for providing our services to you. The contact data may be processed in this way for the purposes of performing our contract with you, or in taking steps at your request prior to entering into a contract.Where you have provided your consent for us to do so, we may contact you regarding the latest promotions and offers regarding our products and services, and send you newsletters.
- Your Client During the course of providing services to you, you may provide us with the personal data of your clients ("client data"). You must always do so in accordance with our terms and conditions. We may process the client data in providing our services to you. The client data may be processed in this way for the purposes of performing our contract with you.
- Website We may process data about your use of our website and services ("website data"). The website 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 website data is our analytics tracking system. This website data may be processed for the purposes of analysing the use of the website and services.The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.
- Enquiry data. We may process information contained in any enquiry you submit to us regarding our products or services ("enquiry data"). The enquiry data may be processed for the purposes of offering, marketing and selling relevant products and/or services toThe legal basis for this processing is consent.
- Notification We may process information that you provide to us for the purpose of subscribing to our newsletters ("notification data"). The notification data may be processed for the purposes of sending you newsletters.The legal basis for this processing is consent.
- Correspondence We may process information contained in or relating to any communication that you send to us ("correspondence data"). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping.The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
- Payment We may process payment information relating to goods and services that you purchase from us ("payment data"). The payment data may include your contact details, your card details and the transaction details. The payment data may be processed for the purposes of administering the payment, for the supply of the purchased goods and services, and keeping proper records of those payments. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract, and our legitimate interests, namely our interest in the proper administration
- Other processing activities. In addition to the specific purposes for which we may process your personal data set out above, we may also process any of 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.
Please do not supply any other person’s personal data to us, unless we prompt you to do so or have entered into a written data processing agreement with you.
3. Providing your personal data to others
- To our partner service We may also disclose your personal data to Lead Forensics Limited, provider of the Lead Forensics Tool, our IP address tracking system, whose functions include identifying visitors to our site to help us monitor and improve our website and services for you.
- Our insurers/professional advisers. We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining and maintaining insurance coverage, managing risks, obtaining professional advice and managing legal
- Where we provide your personal data to any third party. Where we share your personal data with any third party, we will ensure this processing is protected by appropriate safeguards including a suitable data processing agreement with that third
- To comply with legal obligations. In addition to the specific disclosures of personal data detailed above, we may also disclose your personal data where such disclosure is necessary for compliance with a legal obligation we have to comply with, or in order to protect your vital interests or the vital interests of another individual.
4. Transfers of your personal data outside of the European Economic Area
Where your personal data is transferred outside of the EEA, we will ensure that either (a) The European Commission has made an "adequacy decision" with respect to the data protection laws of the country to which it is transferred, or (b) we have entered into a suitable data processing agreement with the third party situated in that country to ensure the adequate protection of your data. In all cases, transfers outside of the EEA will be protected by appropriate safeguards.
5. Retaining and deleting personal data
- Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those
- Unless we contact you and obtain your consent for us to retain your personal data for a longer period, we will retain and delete your personal data as follows:
- Contact data will be retained for 7 years following the date of our last contact or dealing with you, at the end of which period it will be deleted from our
- Client data will be retained for 5 years following the date of our last contact or dealing with you in the case of static PDFs and 90 days in the case of mailing or transactional data, at the end of which period it will be deleted from our systems. We hold on to this data for this period of time so that you may easily re-engage our services. Many of our clients rely on us to hold this data for them. Please let us know if you would prefer us to delete this data within 30 days of our contract with you coming to an end.
- Website data will be retained for 3 years following the date of our last contact or dealing with you, at the end of which period it will be deleted from our
- Enquiry data will be retained for 7 years following the date of our last contact or dealing with you, at the end of which period it will be deleted from our
- Notification data will be retained for 7 years following the date of our last contact or dealing with you, at the end of which period it will be deleted from our
- Correspondence data will be retained for 7 years following the date of our last contact or dealing with you, at the end of which period it will be deleted from our
- Payment data will be retained for 7 years following the date of our last contact or dealing with you, at the end of which period it will be deleted from our
- We my 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
- We may update this policy from time to time by publishing a new version on our
- You should check this page occasionally to ensure you are happy with any changes to this
- We may notify you of changes to this policy by
7. Your rights
- You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to:
- your request not being found to be unfounded or excessive, in which case a charge may apply; and
- the supply of appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address).
- We may withhold personal information that you request to the extent permitted by
- You may instruct us at any time not to process your personal information for marketing
- In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing
- The rights you have under data protection law are:
- the right to access;
- the right to rectification;
- the right to erasure;
- the right to restrict processing;
- the right to object to processing;
- the right to data portability;
- the right to complain to a supervisory authority; and
- the right to withdraw
- Your right to access your data. You have the right to ask us to confirm whether or not we process your personal data and, to have access to the personal data, and any additional information. That additional information includes the purposes for which we process your data, the categories of personal data we hold and the recipients of that personal data. You may request a copy of your personal data. The first copy will be provided free of charge, but we may charge a reasonable fee for additional
- Your right to rectification. If we hold any inaccurate personal data about you, you have the right to have these inaccuracies rectified. Where necessary for the purposes of the processing, you also have the right to have any incomplete personal data about you
- Your right to erasure. In certain circumstances you have the right to have personal data that we hold about you erased. This will be done without undue delay. These circumstances include the following: it is no longer necessary for us to hold those personal data in relation to the purposes for which they were originally collected or otherwise processed; you withdraw your consent to any processing which requires consent; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are certain general exclusions of the right to erasure, including where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for establishing, exercising or defending legal
- Your right to restrict processing. In certain circumstances you have the right for the processing of your personal data to be restricted. This is the case where: you do not think that the personal data we hold about you is accurate; your data is being processed unlawfully, but you do not want your data to be erased; it is no longer necessary for us to hold your personal data for the purposes of our processing, but you still require that personal data in relation to a legal claim; and you have objected to processing, and are waiting for that objection to be verified. Where processing has been restricted for one of these reasons, we may continue to store your personal data. However, we will only process it for other reasons: with your consent; in relation to a legal claim; for the protection of the rights of another natural or legal person; or for reasons of important public
- Your right to object to processing. You can object to us processing your personal data on grounds relating to your particular situation, but only as far as our legal basis for the processing is that it 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 our legitimate interests or those of a third party. If you make an objection, we will stop processing your personal information unless we are able to: demonstrate compelling legitimate grounds for the processing, and that these legitimate grounds override your interests, rights and freedoms; or the processing is in relation to a legal claim.
- Your right to object to direct You can object to us processing your personal data for direct marketing purposes. If you make an objection, we will stop processing your personal data for this purpose.
- Your right to object for statistical purposes. You can object to us processing your personal data for statistical purposes on grounds relating to your particular situation, unless the processing is necessary for performing a task carried out for reasons of public interest.
- Automated data processing. To the extent that the legal basis we are relying on for processing your personal data is consent, and where the processing is automated, you are entitled to receive your personal data from us in a structured, commonly used and machine-readable format. However, you may not have this right if it would adversely affect the rights and freedoms of
- Complaining to a supervisory authority. If you think that our processing of your personal data infringes data protection laws, you can lodge a complaint with a supervisory authority responsible for data You may do this in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
- Right to withdraw consent. To the extent that the legal basis we are relying on for processing your personal data is consent, you are entitled to withdraw that consent at any Withdrawal will not affect the lawfulness of processing before the withdrawal.
- Exercising your You may exercise any of your rights in relation to your personal data by written notice to us in addition to the other methods specified above.
9. Our details
- This website is owned and operated by 2COMMS LTD
- We are registered in England and Wales under registration number 10191537, and our registered office is at 137 Gloucester Road, Cheltenham, GL51 8NG
- You can contact us:
- by post, using the postal address given above;
- using our website contact form;
- by telephone, on the contact number published on our website from time to time; or
- by email, using the email address published on our website from time to firstname.lastname@example.org