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Privacy PolicyThe information we collect, why we collect it, and how we safeguard it

Privacy Policy

This privacy policy (“Policy”) was last updated on 30 July 2018.
Our pledge to you:
  • is to hold your data securely;
  • share only where you agree;
  • use your data to tailor the information we provide you and improve our services;
  • put you in control by allowing you to update, delete and access your data.

INTRODUCTION

VisitScotland is an executive non-departmental public body established under the Development of Tourism Act 1969, with offices at Ocean Point 1, 94 Ocean Drive, Edinburgh EH6 6JH (“VisitScotland”, “we”, “us” or “our”).
Our website, http://www.visitscotlandexpo.com/ is the Expo website for VisitScotland. VisitScotland is the national tourism organisation for Scotland. Our main aim is to contribute significantly to the advancement of Scottish tourism by giving it a real presence in the global marketplace and benefiting the whole of Scotland including making Scotland the perfect stage for events.
This Policy will inform you as to how we collect, use, disclose, transfer and store data. It tells you about your privacy rights and how the law protects you. It also sets out who to contact if you have any queries or concerns about this information.

PURPOSE OF THIS POLICY
This Policy covers how we handle business customer data within VisitScotland and on this website. It gives you information on how we collect and process any personal data through your use of this website, including any data you may provide through this website when you sign up to be an exhibitor or buyer at Expo.
It is important that you read this Policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Policy supplements other notices and privacy policies and is not intended to override them.

CONTROLLER
VisitScotland is the controller and responsible for your personal data.
We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this Policy. If you have any questions about this Policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

CONTACT DETAILS
If you have any questions about this Policy or our privacy practices, please contact our DPO in the following ways:
Full name of legal entity: VisitScotland
Email address: dpo@visitscotland.com
Postal address: VisitScotland, Records Management and Data Protection Officer, Ocean Point One, 94 Ocean Drive, Edinburgh, EH6 6JH
Telephone number: 0131 472 2222
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 POLICY AND YOUR DUTY TO INFORM US OF CHANGES
We keep this Policy under regular review. This version was last updated on 30 July 2018. We reserve the right to make changes to this Policy at any time and we may notify you of changes to this Policy by email.
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
Our 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.

Contents

1. [THE DATA WE COLLECT ABOUT YOU]
3. [HOW IS YOUR PERSONAL DATA COLLECTED?]
4. [HOW WE USE YOUR PERSONAL DATA]
5. [DISCLOSURES OF YOUR PERSONAL DATA]
6. [INTERNATIONAL TRANSFERS]
7. [DATA SECURITY]
8. [DATA RETENTION]
9. [YOUR LEGAL RIGHTS]
10. [GLOSSARY]

1.THE 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 in certain categories. Please take care when submitting information to us, particularly when completing free text fields or uploading content, documents and other materials. Some of our services may be automated and we may not recognise that you have accidentally provided us with incorrect or sensitive information.
Whenever you interact with us, you may be asked to provide us with information relating to you. The following types of data may be collected from you:
  • Identity Data includes first name, maiden name, last name, username or similar identifier, title, date of birth and gender.
  • Contact Data includes address, email address and telephone numbers.
  • Financial Data includes bank account and payment card details.
  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
  • Enquiry Data includes data you provide us with when you contact us to provide details of when you are attending Expo, and which you are seeking support for (by any means of communication including written communications or via our website(s), support forums, telephone, or email) or when you visit us at a public event, such as a trade show or exhibition or participate in one of our surveys, competitions or prize draws, we may record all business customer service communications and keep information about the particular communication, including your name, the event you have proposed, the reason why you contacted us, and the advice we gave you so we can track the resolution of any business customer service issues and for business customer service training purposes.
  • Usage Data includes information about how you use our website, products and services, as well as the frequency and pattern of your service use.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
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. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Policy.
We do not collect any Special Categories of Personal Data about you (this includes details 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.

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.

3.HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:
  • 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. This includes personal data you provide when you:
    • apply for our products or services;
    • create an account on our website;
    • subscribe to our service or publications;
    • request marketing to be sent to you;
    • enter a competition, promotion or survey; or
    • give us feedback or contact us
  • Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.
a) Details of your usage patterns, the content (including any advertisements) that you view and interact with including information on the services and applications you are using in-device to personalise services to your specific needs. For example, when you use our websites, we may collect information about your visit, such as your browser software, which pages you view and which items you ‘clicked’ on.
b) Service, product or server logs, which hold technical information about your use of our service, product or websites, such as your IP address, device ID(s), domain, device and application settings, errors and hardware activity. We may use your IP address to determine your location/country of origin.
c) Device Information such as your device ID(s), including information about where your device is physically located. For example, when you are using a geo-location service or application and you have given consent to your location being shared.
d) Interests and preferences that you specify during set up or registration of any product or service.
  • Third parties or publicly available sources. We may receive personal data about you from various third parties [and public sources] as set out below
    • Financial and Technical Data from parties such as:
    • Identity and Contact Data from publicly available sources [such as Companies House and the Electoral Register based inside the EU].
    • Identity and Contact Data from social media if you (i) interact with any of our social network pages or applications; or (ii) you use one of our products or services that allow interaction with social networks, we may receive information relating to your social network accounts. For instance:
(a)Logging in: If you log-in to one of our websites, applications or services using your social network account, we may receive basic details from your social network profile. The basic details we receive may depend on your social network account privacy settings; however, they might include your social network ID, name, profile picture, gender and location.
(b) Interactions: If you click on a ‘like’, ‘+1’ or ‘tweet’ or similar button in one of our websites or services, we may record the fact that you have done so. In addition, the content that you are viewing may be posted to your social network profile or feed. We may receive information about further interactions with this posted content (for example, if your contacts click on a link in the posted content), which we may associate with the details that we store about you.

4.HOW 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.
See Section 10. Glossary to find out more about the types of lawful basis that we will rely on to process your personal data.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
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.
We retain all business customer data for 1 year, commencing when business data is collected for the next year’s Expo.
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 business business customer

(a) Identity
(b) Contact
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
(c) Provide you with a product or service you have requested (including any back-up and restore service), delivering your purchase to you or ensuring that you benefit from any relevant special offer or promotion (and to fulfil our obligations under any other agreement we may have with you)
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications

(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:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey

(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications

(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how business customers use our products/services)

To enable you to partake in a prize draw, competition or complete a survey

(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how business customers use our products/services, to develop them and grow our business)

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

(a) Identity
(b) Contact
(c) Technical

(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 deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical

Necessary for our legitimate interests (to study how business customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

To use data analytics to improve and enhance our existing website, products/services/applications, marketing, business customer relationships and experiences [and to develop new offerings, recommendations, advertisements]

(a) Technical
(b) Usage

Necessary for our legitimate interests (to define types of business 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, including carrying out surveys to better understand your preferences.

(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
(f) Marketing and Communications

Necessary for our legitimate interests (to develop our products/services and grow our business)

To prevent fraud and for investigation purposes, for example, using device information such as device ID(s) to ensure that any vouchers or discounts relating to any promotions or campaigns are not being redeemed fraudulently, checking that a payment is not made fraudulently.(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
(f) Financial
Necessary to comply with a legal obligation
To create and manage business customer database(s). As part of our ongoing business customer relationship management activities, we may consolidate several databases into one or otherwise link separate databases to more effectively manage your accounts. Information may be linked via a unique identifier, such as a cookie or account number.
Alternatively, we may decide to combine two or more databases into a single database of business customer information.
We may do this for your and/or our convenience (for example, to allow you to more easily register for a new service), to allow us to provide more seamless business customer support whenever you contact us and to provide you with better, personalised services, content, marketing and adverts.
  1. (a) Identity
  2. (b) Contact
(c) Financial
(d) Transaction
(e) Technical
(f) Enquiry
(g) Profile
(h) Usage
(i) Marketing and Communications
Necessary for our legitimate interests (to ensure that we have optimal data management practices in place)

To enable you to provide feedback both when we ask you and unprompted(a) Contact (only your email address if you want us to reply to your feedback.Performance of a contract with you

To allow us to deliver newsletters to you(a) Identity Data
(b) Contact Data
Performance of a contract with you



MARKETING
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
You will only receive marketing communications from us if you have requested information from us by opting in to receive such marketing.

PROMOTIONAL OFFERS FROM US
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased [goods or services] from us and you have not opted out of receiving that marketing.

THIRD-PARTY MARKETING
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

OPTING OUT
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of [a product/service purchase, warranty registration, product/service experience or other transactions].
Please note that we may occasionally send you important information (including via email) about our products and services that you are using or have used including essential software updates, changes to applicable terms and conditions and/or other communications or notifications as may be required to fulfil our legal and contractual obligations to provide warranty or after sales repair services. These important product and/or service communications are not affected by your opt-out of any marketing communications.

PUBLISH YOUR REVIEWS, COMMENTS AND CONTENT
Where you have uploaded product reviews, comments or content to our websites or services and made them publicly visible, we may link to, publish or publicise these materials elsewhere including in our own advertisements.


COOKIES
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.
Our website uses industry-wide technologies, such as “cookies”, to collect information about the use of our website and email communications. For instance, these technologies may tell us which visitors clicked on key elements (such as links or graphics) on a website or email and recognise your browser the next time you visit our websites.
Cookies allow us to customise your experience to better match your interests and preferences, or to simply facilitate your signing in to use the services. Most browsers will allow you to erase cookies from your computer hard drive, block acceptance of cookies or receive a warning before a cookie is stored. However, if you block or erase cookies, we may not be able to restore any preferences or customisation settings you have previously specified, and our ability to personalise your online experience would be limited. Please refer to your browser instructions to learn more about these functions.
More information about our use of cookies can be found in our cookie policy.


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 if for another reason and that reason is compatible with the original purpose. Please contact us using the details set out at the beginning of this Policy for an explanation as to how the processing for the new purpose is compatible with the original purpose.
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.


5.DISCLOSURES OF YOUR PERSONAL DATA

We may share your personal data with the parties set out below for the purposes set out in the table [Purposes for which we will use your personal data] above.

We may have to share your personal data with the third parties set out below for the purposes set out in the table in paragraph 3 above.
(a) our payment services providers for services relating to our website and services to which you have subscribed to which may be handled by our payment services providers, such as, without limitation, Worldpay. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers' privacy policies and practices at https://www.worldpay.com/uk/privacy-policy.
(b) one or more of the selected third party suppliers of goods and services identified on our website to which you have specifically consented to share your personal data with for the purposes set out in such consent or to fulfill our contractual obligations. Each such third party will act as a data controller in relation to the data that we supply to it; and upon contacting you, each such third party will supply to you a copy of its own privacy policy, which will govern that third party's use of your personal data.
(c) our authorised data processors and service providers for the purposes of providing certain data processing services for us (acting as our authorised data processors). Examples of authorised data processors could include evaluation and research agencies, [billing and fulfilment partners,] data analytics providers who process information on our behalf for the purposes outlined above. For example, we may use the services of third parties to personalise content, fulfil orders, deliver packages, send postal mail and emails, send text messages (SMS), provide marketing assistance, process credit card payments, provide fraud checking services and provide business customer services. When acting as our authorised data processors, our service providers are required to only process data in accordance with our instructions, in line with this Policy, and are subject to appropriate confidentiality and security obligations.
(d) our professional advisers in so far as reasonably necessary for the purposes of managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
(e) to government bodies such as the [Cabinet Secretary for Culture, Tourism and External Affairs] and law enforcement agencies to prevent fraud, to comply with applicable laws, regulations and court orders and to comply with valid legal information requests from such bodies.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

ANONYMOUS STATISTICS
We prepare anonymous, aggregate or generic data (including “generic” statistics) for a number of purposes as outlined above. As we consider that you cannot reasonably be identified from this information, we may share it with any third party (such as our partners, advertisers, industry bodies, the media and/or the general public).

6.INTERNATIONAL TRANSFERS

In this paragraph, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).
VisitScotland is a statutory body incorporated under the Development of Tourism Act 1969 with its headquarters based in Edinburgh, Scotland. We have a national network of offices to assist in delivering our core function of promoting the development of tourism to and within Scotland and encouraging people to visit Scotland.
The hosting facilities for our website(s) are situated in the United Kingdom.
Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7.DATA 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.
Some of the steps we use to protect your information from unauthorised access, use or alteration and unlawful destruction, include where appropriate:
  • Using Secure Sockets Layer (SSL) encryption when collecting or transferring sensitive information, such as credit card details (SSL encryption is designed to make the data unreadable by anyone but us).
  • Limiting access to the information we collect about you (for instance, only those of our personnel who need your information to carry out our business activities are allowed access).
  • Putting in place physical, electronic, and procedural safeguards in line with industry standards.
As general best practice on the Internet, it is recommended that individuals take great care with user accounts, and follow some basic rules:
  • Do not use trivial passwords (such as single dictionary words).
  • Do not use the same password for multiple accounts.
  • Do use very long passwords (at least 10 characters, but preferably much longer)
  • Do use passwords which contain a combination of upper and lower case letters, numbers and special characters e.g. $%^& etc.
  • Do keep passwords securely (never written down, or shared with anyone) and changed periodically.

8.DATA RETENTION

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
This paragraphsets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
We retain all business customer data for 1 year, commencing when business data is collected for the next year’s Expo. When your data is no longer required, we will delete it securely. Please contact us if you require more details regarding our retention periods.
In some circumstances you can ask us to delete your data: see [your legal rights] 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.

9.YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. We have provided a summary of the rights that you have under current data protection law. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
Your principal rights under data protection law are:
(a) the right to be informed;
(b) the right to access;
(c) the right to rectification;
(d) the right to erasure;
(e) the right to restrict processing;
(f) the right to object to processing;
(g) the right to data portability;
(h) the right to complain to a supervisory authority; and
(i) the right to withdraw consent.


YOUR 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 ofyour 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.
Read more about your individual rights on the Information Commissioner's Office website.
If you wish to exercise any of the rights set out above, please contact us by emailing dpo@visitscotland.com
or by post at VisitScotland, Records Management and Data Protection Officer, Ocean Point One, 94 Ocean Drive, Edinburgh, EH6 6JH.


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.

10.GLOSSARY

LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.


EXTERNAL THIRD PARTIES
  • Service providers [acting as processors] based in the EU who provide IT and system administration services.




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