Effective starting: August 4, 2022
Last Updated: September 23, 2021
Who we are
When we refer to “we”, or “our”, or “us”, in this policy, we are referring to FW-IT Limited and all its products and services. FW-IT Limited is a company incorporated in England and Wales, with the registration number 09826725 and ICO registration ZA153122. Our registered address is 86 – 90 Paul Street, London, EC2A 4NE.
Our principles of data protection
We follow closely all the legislation regarding to data protection, thus our approach is based on seven principles:
- Lawfulness and fairness – We will follow legal procedures in regard to collect and process your data.
- Empowerment – We will inform you about your rights regarding to your data.
- Transparency – We have a simple and clear approach about your data.
- Purpose limitation – We will only use your data for the business purposes that you agreed upon.
- Integrity and confidentiality – Security is at forefront of our business, therefore we have measures in place to assure you that your data is in good hands.
- Accountability – We accept responsibility that comes with processing or in some cases controlling your data.
- Data quality – We have procedures in place to guard the quality of your data.
How we collect your data
The protection of your rights is important to us, thus we will collect your personal data only with the purpose to fulfil a contract with you, or whether there is legitimate interest to process your data and your rights are not overridden, in accordance with a legal obligation and where your consent is given. The ways we collect your data can be broadly categorised into the following:
Direct interactions – You may give us your Identity, contact and financial data by filling in forms or by corresponding with us by post, phone, email or otherwise, including face-to-face contact. This includes personal data you provide when you:
- subscribe to our products or services, or those of our clients.
- create an account on our website.
- subscribe to our service or publications.
- make a complaint.
- request marketing to be sent to you.
- enter a competition, promotion or survey.
Automated interactions – In this case we collect personal data by using cookies, server logs and other technologies, as you may interact with our service and products, we may automatically collect technical data, such as browsing actions and patterns, location and equipment details.
- Cookies are small text files that are placed on your computer’s hard drive by your web browser when you visit any website. They allow information gathered on one web page to be stored until it is needed for use on another, allowing a website to provide you with a personalised experience and the website owner with statistics about how you use the website so that it can be improved. Some cookies may last for a defined period of time, such as one day or until you close your browser. Others last indefinitely.
Your web browser should allow you to delete any you choose. It also should allow you to prevent or limit their use.
- Personal identifiers from your browsing activity requests by your web browser to our servers for web pages and other content on our website are recorded.
We record information such as your geographical location, your Internet service provider and your IP address. We also record information about the software you are using to browse our website, such as the type of computer or device and the screen resolution.
We use this information in aggregate to assess the popularity of the webpages on our website and how we perform in providing content to you.
If combined with other information we know about you from previous visits, the data possibly could be used to identify you personally, even if you are not signed in to our website.
- Our use of re-marketing involves placing a cookie on your computer when you browse our website in order to be able to serve to you an advert for our products or services when you visit some other website.
Please refer to our Cookies Policy for further information.
Third Parties – The majority of the personal data that collect comes from a direct contact with you, however we might collect personal from other sources such as online available information or trusted third parties like marketing and research partners, this information is used to supplement the data given to us, in order to personalise and improve our product / services and to validate personal data that you provide. If you object, the collection of such data please contact us prior subscribing the services as we might not be able to provide you with all the functions and features available in our services. Thus, we might receive personal data from various third parties and public sources:
- technical data from analytics providers, advertising networks and search information, for instance Google and other based outside EEA.
- identity and contact data from publicly available sources, for instance Companies House, electoral register, brokers or aggregators some of them sometimes are based outside EEA.
How we use your data
First of all, we process personal data lawfully collected by the subscriber of our services. Also we may collect and use your personal data for other purposes, which will be the following instances:
Communication – providing information that you have requested or information we are required to send to you (changes and updates to our websites, services, policies, security notifications, or guidance to our services). If you have opted-in to our marketing communications you will receive information about our products and services. We might get in touch to collect your feedback for research purposes in order to improve services.
. Support – assisting you on technical issues related to our product and services.
. remember information so that you will not have to re-enter it during your visit or the next time you visit or use the Service.
. provide custom, personalised content and information, including targeted content and advertising.
. provide and monitor the effectiveness of our Service.
. monitor aggregate metrics such as total number of visitors, traffic, usage, and demographic patterns on our website and our Service.
. diagnose or fix technology problems.
. otherwise, to plan for and enhance our Service.
. marketing – When agreed by you, we may use your personal data to display targeted advertising to you online, through our platforms and third-party services.
. protection – we will monitor suspicious activities that do not comply with our terms of service and to reinforce personal data protection compliance.
How we may share your data
We may have to share your personal data with other third parties, however we will you’re your consent prior your subscription of our services and only disclose your personal data with the following parties:
- other companies related to FW-IT.
- third party service providers and partners and enable us to fulfil our contractual obligations and perform our services.
- government agencies, legal and regulatory bodies, and other third parties that have the purpose to protect our legal rights. Wherever possible and appropriated we will inform you of this type of disclosure;
- agents and advisers in connection with an actual or proposed purchase, merger or acquisition of any part of our business.
- other parties that you have consent.
Currently our data hosting provider’ servers are located in the United Kingdom. However, sometimes in order to fulfil our business purpose we will need to transfer personal data to third parties based outside the European Economic Area (EEA). These countries may follow different laws than we abide in EEA, rest assured where we have to disclose your information to third parties outside EEA we will request your consent and implement safeguards to ensure your personal data remains safe.
Where personal data from individuals in the European Economic Area is transferred outside EEA, it will only be transferred to countries and providers that have been identified to provide the adequate level of protection as recommended by the European Commission, and by entering into European Commission’ Standard Contractual Clauses. In case we use providers based in the US, we will ensure they are Privacy Shield certified.
Please contact us using the details stated in this policy if you would like further information on our procedures of transferring personal data out of the EEA.
We have put in place appropriate technical and organisational measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Moreover, we limit access to your personal data thus only personnel subject to a duty of confidentiality and with a clear business reason deals with your data and on written instructions. FW-IT follows security procedures in order to deal with any suspected personal data breach and will notify you and the applicable regulator of such a breach.
Encryption of data
We use Secure Sockets Layer (SSL) certificates to verify our identity to your browser and to encrypt any data you give us. Whenever information is transferred between us, you can check that it is done so using SSL by looking for a closed padlock symbol or other trust mark in your browser’s URL bar or toolbar.
Except as otherwise mentioned in this privacy notice, we keep your personal information only for as long as required by us:
. In order to provide you with the services you have subscribed or requested.
. To comply with applicable legal requirements and in accordance with our data retention policies and practices.
However, following the required period we will delete or anonymise your personal data. When data is anonymised can no longer identify or be associated with you.
Your Legal Rights
. Access to your personal information
At any time you may review or update your personal data that we hold about you, by signing in to your account on our online services or contacting us. However if you would like to obtain a copy of any information that is not provided on our online services you should contact us to make that request.
You will need to provide proof of identity in order to make any enquiry or request regarding your personal data.
We do not commonly charge a fee for you to access your personal data. However, we may charge a reasonable fee if a request is found repetitive and excessive. In some circumstances where we identify the request to be malicious we may refuse to comply.
. Removal of your information
If you wish us to remove your personal information personally from our services, you should contact us in writing to make your request. This may limit or stop, the service we can provide to you.
. Verification of your information
When we receive any request to access, edit or delete personal data we shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.
. Time limit for our response
We aim to respond to all legitimate requests within one month. Occasionally it may 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.
. How you can complain
If a dispute is not settled then we hope you will agree to attempt to resolve it by engaging in good faith with us in a process of mediation or arbitration.
If you are in any way dissatisfied about how we process your personal information, you have a right to lodge a complaint with the ICO – Information Commissioner’s Office (www.ico.org.uk). We would, however, appreciate the opportunity to talk to you about your concern before you approach the ICO.
Use of our product and services by children
We do not knowingly provide products or services to anyone under18 years of age, nor do we market to them.
Review of this policy
We reserve the right to modify and update this policy from time to time as necessary. When any changes occur the version date of this policy will change and you will still be able to access previous versions by requesting here. If you object to any changes, please contact us immediately or cancel your subscription, otherwise by continuing to use the service after we publish changes to this policy constitute your consent to the changes.
We are available for any enquiries regarding to your data, also we appreciate any feedback on this policy and its impact on service subscribers.
You can contact us via email or in writing and we will aim to assist you within the regulatory time frames.
Our full details:
Full name of legal entity: FW-IT Limited
Email – firstname.lastname@example.org
Postal Address – 86 – 90 Paul Street, London, EC2A 4NE