OUR PRIVACY POLICY
This document explains how we use your personal data.
Nine Circles Limited is a company registered in England and Wales with company registration number 03413817 and having its registered office at Unit 6 Bamel Way, Gloucester Business Park, Brockworth, Gloucester GL3 4BH, United Kingdom. This website is run and administered by Nine Circles Limited, and Nine Circles Limited is the data controller for all personal data collected through this website.
We are committed to ensuring the privacy of our clients and other website visitors. In this policy we explain how we hold, process and retain your personal data.
How we use your personal data
This section provides you with information about:
a. what personal data we hold and process;
b. 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;
c. the purposes for which we may process your personal data; and
d. the legal grounds on which we process your data.
Contact data. We may process contact details that you provide to us ("contact data"). This contact data may include your name, telephone number, and email address, and may be provided through our website when you express an interest in purchasing one of our products. The legal basis for this processing is our legitimate interest in introducing you to our goods and services.
We may process your contact data if you decide to purchase one of the products available from our website. Your 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.
We may use this contact data to contact you to discuss your use of our website, and how our website performed and functioned for you. This may include requesting you to complete surveys about our website and service. The legal basis for this processing is our legitimate interest in ensuring the efficient administration and continued function of our website by users.
We may use this contact data if you enter a competition, in order to contact you as necessary. The legal basis for this processing is our legitimate interest in ensuring the efficient administration of any such competition.
Where you have provided your consent for us to do so, we may send you marketing communications, including communications regarding the latest promotions and offers regarding our products and services,
Where we pass your information to third parties, this information will be anonymized and aggregated with other user information (for example, we may inform them that 500 men aged 30 have clicked on their advertisement on any given day). These third parties may use such aggregated data to target particular demographics (for example, everyone under the age of 30 in the Midlands).
The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
Payment Data. If you decide to purchase one of the products available from our website, we will ask you for further information in order to complete a purchase (“purchase data”). This purchase data may include your address, financial and credit card information, a personal description of yourself, a photograph, details of your personal identification such as your passport, drivers licence, or identity card, utility bills, bank statements, and tax statements.
We may use this data to process your purchase. This may include contacting you with a summary of your order, requesting and processing payment, and administering the necessary identification checks.
The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
Website data. 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, time zone setting, browser plug-in types, 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, which we may use a third-party service provider to monitor and analyze the usage of our service. This website data may be processed for the purposes of analysing on an anonymous, statistical basis the use of the website and services.
Our third-party service provider is Google Analytics.
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity.
For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy “
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 other 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 to you.
The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
Notification data. 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 data. We may process information contained in or relating to any other 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.
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.
Providing your personal data to others
Our partner service providers. We may disclose your data to Sage Pay Europe Limited (Company Registration Number 07492608, registered office North Park, Newcastle on Tyne, NE13 9AA) and Worldpay Group Limited (Company Registration Number 08762327, registered office The Walbrook Building, 25 Walbrook, London EC4N 8AF) (our payment service providers) and banks, organisations that we work with in order to provide services to you. This may include other companies within our group of companies.
Our professional advisers. We may disclose your personal data to our professional advisers insofar as reasonably necessary for the purposes of managing risks, obtaining professional advice and managing legal disputes.
Our third party contractors. We may disclose your personal data to third parties who provide services to us:
that are necessary to enable us to supply goods and services to you such as courier services, or
that are necessary for the conduct or administration of our business such as IT support engineers, or
that enable the sending to you of emails that you have opted to receive from us.
In each of the foregoing cases we shall only supply to such service providers the minimum amount of personal data required to enable them to provide their services.
Selected third parties for marketing. Where you have provided your consent for us to do so, we may pass your personal data on to third parties for marketing purposes. Subject to 2.3.3 above, this information will be anonymized and aggregated with other user information (for example, we may inform them that 500 men aged 30 have clicked on their advertisement on any given day). These third parties may use such aggregated data to target particular demographics (for example, everyone under the age of 30 in the Midlands).
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 party.
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.
Transfers of your personal data outside of the European Economic Area
Your personal data may be transferred and stored outside of the EEA. It will also be processed by staff of our suppliers operating outside of the EEA.
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.
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 purposes.
Unless we contact you and obtain your consent for us to retain your personal data for a longer period, based on our experience of operating the business of Nine Circles Limited we will retain and delete your personal data as follows:
a. 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 systems.
b. Purchase data will be retained for 7 years following the date on which that purchase is completed, at the end of which period it will be deleted from our systems.
c. Website 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 systems.
d. 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 systems.
e. 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 systems.
f. 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 systems.
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.
Amendments
We may update this policy from time to time by publishing a new version on our website.
You should check this page occasionally to ensure you are happy with any changes to this policy.
We may notify you of changes to this policy by email.
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:
a. your request not being found to be unfounded or excessive, in which case a charge may apply; and
b. 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 law.
You may instruct us at any time not to process your personal information for marketing purposes.
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 purposes.
The rights you have under data protection law are:
a. the right to access;
b. the right to rectification;
c. the right to erasure;
d. the right to restrict processing;
e. the right to object to processing;
f. the right to data portability;
g. the right to complain to a supervisory authority; and
h. the right to withdraw consent.
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 copies.
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 completed.
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 claims.
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 interest.
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 marketing. 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.
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 protection. 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 time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
Exercising your rights. You may exercise any of your rights in relation to your personal data by written notice to us at our registered office at Unit 6 Bamel Way, Gloucester Business Park, Brockworth, Gloucester GL3 4BH, United Kingdom or by email to us at [email protected].