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Privacy Policy

Welcome to the privacy policy for www.regulation84.co.uk.

This privacy policy informs you about how we look after your personal data when you visit our website (regardless of where you visit it from) and tells you about your privacy rights and how the law protects you.

1Important information and who we are

The website is a collaboration between Lifecycle Management Group Ltd of Unipart House, Garsington Road, Cowley, Oxford, OX4 2PG and Mills & Reeve LLP of 24 Monument Street, London, EC3R 8AJ.

This privacy policy is issued on behalf of both parties, who will be separate controllers of the personal data we collect from you through this website. Lifecycle is the controller responsible for hosting and managing the website.

Contact

If you have any questions about this privacy policy or our privacy practices, please contact Lifecycle at DataProtection@Lifecycle.co.uk.

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

2The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity and Contact Data includes name, job title, organisation you work for, your username and password, email address and telephone number.
  • Content Data includes any personal data that you enter as part of the wizard to create your Regulation 84 report.
  • Technical Data includes your IP address and data on the time and duration of your visit.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature.

We do not collect any Special Categories of Personal Data about you. Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

3How is your personal data collected?

We use different methods to collect data from and about you including through:

  • Direct interactions. You will give us Identity and Contact Data by filing in a form to register for the website and Content Data by completing the report wizard. You may also give us Identity and Contact Data when you contact us.
  • Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy for further details.

4How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal obligation.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of the ways each of us 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.

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest

To manage our relationship with you which will include:

(a) creating and managing your user account

(b) notifying you about changes to our terms or privacy policy

Lifecycle and Mills & Reeve will have access to and use data for this purpose

Identity and Contact Data

(a) Performance of a contract with you

(b) Necessary for compliance with our legal and professional obligations to third parties. This includes for example, our professional and contractual duties to the courts and our obligations to regulators (for example reporting data breaches to the Information Commissioner)

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To provide you with your report

Only Lifecycle will have access to and use data for this purpose

Content Data

Processing this data is necessary to perform our contractual obligation with you and provide you with the tools to create your report.

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

Only Lifecycle will have access to and use data for this purpose

(a) Identity and Contact Data

(b) Content Data

(c) Technical Data

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security and to prevent fraud)

(b) Necessary to comply with a legal obligation

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

Lifecycle and Mills & Reeve will have access to and use data for this purpose

Technical Data

Processing this data is necessary to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy.

To make suggestions and recommendations to you about goods or services that may be of interest to you

Lifecycle and Mills & Reeve will have access to and use data for this purpose

Identity and Contact Data

Processing your data is necessary for our legitimate interests to develop our products/services and grow our business.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

Third-party marketing

Neither Lifecycle nor Mills & Reeve will share your data with third parties for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.

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.

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.

5Disclosures of your personal data

We may from time to time use external service providers to assist us with the provision of this website and/or the marketing activities described in the table at paragraph 4 above. These service providers are appointed as processors, who will only process your personal data for specified purposes and in accordance with our instructions on our behalf. They are not permitted to use your personal data for their own purposes. We require all third parties

We require all third parties to respect the security of your personal data and to treat it in accordance with the law.

6International transfers

Some of our external service providers are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA. In the course of carrying out the activities referred to above we may transfer your data to other countries, which may not have the same legal protections for your data as the UK.

Where data is being transferred outside of the European Economic Area, we will take steps to ensure that your data is adequately protected in accordance with UK legal requirements.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7Data security

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.

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.

8Data retention

Your Identity and Contact Details will be retained for 4 years after your last activity on the website or contact with us unless you express a wish to be contacted further by us (this may be registering for updates or to attend an event, or responding by email to request further information), except in the following circumstances:

  • if you unsubscribe from our marketing communications, your data may be kept longer (up to 15 years) on a suppression list to ensure that you do not receive any further communications in line with your wishes;
  • if necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements; and
  • we may retain your data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

Content Data will be retained until you delete the created report and/or your account for the website.

Technical Data may be retained while the account is active. No Technical data will be retained once a user account has been deleted.

In some circumstances you can ask us to delete your data: see paragraph 9 below for further information.

In some circumstances we will 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.

9Your legal rights

You have the right to:

  • Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing of your personal data where we are relying on a legitimate interest (or those 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.
  • Request restriction of processing processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
    • If you want us to establish the data's accuracy.
    • Where our use of the data is unlawful but you do not want us to erase it.
    • 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.
    • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact Lifecycle by email at DataProtection@Lifecycle.co.uk. Lifecycle will manage all initial requests on behalf of both Lifecycle and Mills & Reeve LLP.

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.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.