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Privacy Policy

Ventil8 Logo FINAL REV

PRIVACY POLICY 


1.    Who we are

We are World Ventil8 Day and our website is operated by BESA Ltd, a company with registered office at Old Mansion House, Eamont Bridge, Penrith, Cumbria, CA10 2BX ("BESA", "we", "our" and "us"). BESA operate this website - www.worldventil8day.com – and the products and services made available through it (our "Website"). 

2.    Our values and what this Privacy Policy for 

We respect your privacy and want you to be familiar with how we collect, use and disclose information directly or indirectly relating to you as an individual ("Personal Data"), and the rights that you have in this regard.
This privacy policy (the "Privacy Policy") describes how we, as a data controller, process your Personal Data when you use this Website, and when you interact with us in relation to our business and services. We use "you" to mean users of this Website and the individuals with whom we interact.
If you have any queries or feedback on this Privacy Policy, you can contact us by using the contact information in Section 16 of this Privacy Policy. 

3.    Your key rights

You have various rights in respect of our use of your Personal Data as set out in more detail in Section 7.  

Your confirmation to us

Please read this Privacy Policy carefully to understand how we handle your Personal Data. By engaging with us in the ways set out in this Privacy Policy, you confirm that you have read and understood it, as it applies to you.

4.    What Personal Data do we process about you? 

a.    How we collect your Personal Data
•    When you use our Website. We collect some Personal Data about you automatically as you use our Website.

b.    What Personal Data we process

We process the following Personal Data about you:

  • "Data and Usage Information" means information about how you use our Website, what content you have interacted with, which website you came from, the number of visits to the Website and traffic data about how long you visit our Website for. We use cookies to track user sessions on the Website. Please see the "Cookies" section below for more information. 
  • "Preferences Information" means information about your preferences set for notifications, marketing communications, acceptance of legal terms and information about how you prefer to interact with our Website.
  • "Technical Information" means information about the type of internet browser and operating system you use, your internet protocol (IP) address, your 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 are using.

c.    Why we process your Personal Data 

The purposes for which we process your Personal Data and the relevant legal bases for that processing are set out in the table below. 

Please note that we need certain types of Personal Data so that we can provide services to you and perform contractual and other legal obligations that we have to you. If you do not provide us with such personal information, or if you ask us to delete it, you may no longer be able to access certain services. 

 

Purpose for Processing

Categories of Personal Data Processed

Legal Basis for Processing

Processing Operations

To improve our services and provide you with more relevant information.

·        Technical Information

·        Data and Usage Information

Our processing of your Personal Data is on the basis of:

·        your consent

 

For this purpose, we will collect, record, organise and use your Personal Data.

For our own research to understand our users and how they use our services and our Website to help us adapt and improve them appropriately.

·        Technical Information

·        Data and Usage Information

 

Our processing of your Personal Data for this purpose is on the basis of your consent.

For this purpose, we will collect, analyse, record, store, organise and use your Personal Data.

To ensure that the content on the Website is presented in the most effective manner for you and your device.

·        Technical Information

·        Data and Usage Information

Our processing of your Personal Data for this purpose is on the basis of your consent.

For this purpose, we will collect and use your Personal Data.

To provide you with a safe, smooth, efficient and customised user experience.

·        Technical Information

·        Data and Usage Information

 

Depending on the circumstances, our processing of your Personal Data is on the bases of:

·        your consent;

·        as is necessary for compliance with a legal obligation to which we are subject

 

For this purpose, we will collect, record, store, organize and use your Personal Data.

To comply with our legal obligations, court orders or government authority requests, when we reasonably believe that we are legally required to disclose your Personal Data.

·        All categories of Personal Data in Section 5

Our processing of your Personal Data for this purpose is for compliance with a legal obligation to which we are subject.

For this purpose, we will collect, record, store, organise, retrieve, disseminate, restrict and use your Personal Data.

To lawfully enforce our legal rights and perform our obligations and allow us to pursue any available legal remedies or limit the damages we may sustain.

·        All categories of Personal Data in Section 5

Our processing of your Personal Data for this purpose is for compliance with a legal obligation to which we are subject.

For this purpose, we will collect, record, store, organise, retrieve, disseminate, restrict and use your Personal Data.

To conduct internal audit and reporting processes, ensuring adequate insurance coverage for our business, ensuring the security of facilities, research and development, and to identify and implement business efficiencies.

 

·        All categories of Personal Data in Section 5

Depending on the circumstances, our processing of your Personal Data is on the bases of:

·        as is necessary for compliance with a legal obligation to which we are subject; or

·        as is necessary for the purposes of legitimate interests pursued by us, which are to verify the accuracy and processes of our business operations.

For this purpose, we will collect, record, analyse, store, organise and disseminate, use your Personal Data.

 

Before using your Personal Data for any purposes which fall outside those set out in this Section 5, we will undertake an analysis to establish if our new use of your Personal Data is compatible with the purposes set out in this Section 5. Please contact us using the details in Section 16 if you want further information on the analysis we will undertake or have taken.

d.    The Personal Data we don't collect
We will not intentionally process the following sensitive Personal Data, referred to as "Special Category" data: racial or ethnic origin; political opinions; religion or philosophical beliefs; health or medical condition; criminal background; trade union membership; genetic or biometric data; or sexual life or orientation. 
Please do not send, nor disclose, any Special Category data to us. 

5.    Cookies

As described in the table above, when you use our Website and online products and services, read our emails, or otherwise engage with us through a computer or mobile device, we may automatically collect information about how you access and use the relevant content and information about the device you use to access the content.

Our automated data collection is typically carried out using cookies. Cookies are small data files sent by a web server to a web browser in order to enable the server to collect information back from the browser. We use cookies in accordance with the details set out in the table in Section 5c above.

You can delete cookies from your hard drive at any time. You may also set your browser to disable cookies. However, you should be aware that, if you disable cookies, this may limit your ability to enjoy the full functionality of the Website, product or service. There is full information on how you can do this at http://www.aboutcookies.org/.

Please refer to our cookies policy for more information. 

6.    Your rights in relation to your Personal Data

You have the following specific rights in respect of your Personal Data that we hold:

a.    The right to be informed about how your Personal Data is being used. 
b.    The right to access the Personal Data we hold about you.
c.    The right to request that we correct inaccurate Personal Data or request that we delete your Personal Data, if you consider that it is incorrect or we do not have the right to hold it. 
d.    A right to object to or restrict certain processing activities. 
e.    The right to withdraw consent to any consent-based processing at any time. You can do this by contacting us using the details in Section 16. Where you do withdraw your consent, we will stop processing your Personal Data for that purpose immediately, except where we are required by law to continue the processing. We cannot reverse any processing that we may have carried out before you withdrew your consent. 
f.    To ask us to stop or start sending you direct marketing messages at any time.
g.    The right to data portability (moving some of your personal data elsewhere) in certain circumstances.
h.    The right not to be subject to a decision based on automated processing and to ask us to explain any computer-system decision about you.
i.    The right to complain to your data protection regulator — in the UK, the Information Commissioner’s Office, contact details for which can be found under Contacting Us in Section 16.
If you have questions, you wish to contact us to exercise your rights, or you wish to make a complaint, you can contact us using the contact information listed in Section 16 of this Privacy Policy.
We will consider all such requests and provide our response within a reasonable period (and in any event within such period required under applicable law). Please note, however, that certain Personal Data may be exempt from such requests in certain circumstances, for example if we need to keep using the information to comply with our own legal obligations or to establish, exercise or defend legal claims. If an exception applies, we will tell you this when responding to your request.  We may request you provide us with information necessary to confirm your identity before responding to any request you make.  

7.    Who do we share your Personal Data with and why? 

We may share your Personal Data to the following categories of recipients as an essential part of being able to provide our services to you. 

Who do we share your Personal Data with?

What Personal Data do we share?

Why do we share your Personal Data?

Where does your Personal Data go?

Other members of the BESA group or our affiliated companies. We may also share information with third parties in which we have an ownership interest or commercial relationship.

·        All categories of Personal Data in Section 5

·        To manage our Website to ensure everything is working as it should be.

 

United Kingdom, Isle of Man, Republic of Ireland

Third party service providers appointed by us including (but not limited to): (a) companies who help operate our Website; (b) marketing and promotional partners; (c) IT service providers; (d) third party payment providers; (e) software solutions providers; and (e) companies who provide communication, auditing, archiving, data analysis and administration services including banks, accountants and legal services.

·        All categories of Personal Data in Section 5

·        To develop and improve our Website.

·        To provide technical support for our systems and digital platforms when things go wrong.

·        To host our systems and Website.

·        To provide reporting solutions and data analytics.

·        To provide necessary support to our business in relation to communications, auditing and consulting.

The location of our third party service providers is global although the majority are based in the UK and EEA.

 

 

Authorities, public agencies, regulators and law enforcement

·        All categories of Personal Data in Section 5

We may share your Personal Data as we believe to be necessary or appropriate with relevant authorities, affiliates and third parties:

·        to comply with our legal obligations;

·        to respond to requests from public and government authorities (including courts and law enforcement) which may include public and government authorities outside your country of residence;

·        to enforce our legal rights;

·        to protect our operations or those of any of our affiliates;

·        to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and

·        to allow us to pursue available remedies or limit the damages that we may sustain.

The location of the competent authorities shall depend on the particular purpose.

Third parties in the event of any sale, merger, reorganization, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).

·        All categories of Personal Data in Section 5

We may share your Personal Data with a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).

The location of the third party shall depend on the specific details of the reorganization, merger, sale, joint venture, assignment, transfer or other disposition.

 

We may also disclose and use anonymised, aggregated reporting and statistics about users of our Website or our products and services for the purpose of internal reporting or reporting to our group companies or other third parties, and for our marketing and promotion purposes. None of these anonymised, aggregated reports or statistics will enable individuals to be personally identified.
If you would like to know more about the third parties we may share personal data with, or how to find out more about how they will use your Personal Data, please contact us using the contact details listed in Section 16 of this Privacy Policy.

8.    Children

You must be aged 18 or over to purchase products or services from us. Our website and services are not directed at children and we do not knowingly collect any personal information from children.

If you are a child and we learn that we have inadvertently obtained personal information from you from our websites, or from any other source, then we will delete that information as soon as possible. Please contact us using the details in Section 16 if you are aware that we may have inadvertently collected personal information from a child.

9.    Marketing

We will not use data collected on this site to send marketing communications to you.

10.    What overseas transfers of Personal Data do we carry out?

To achieve the purposes described in this Privacy Policy, we may transfer your Personal Data to countries which do not offer the same level of protection for your personal data as the UK or the European Economic Area.   
Where such locations do not offer an adequate level of protection for your Personal Data, we will ensure that your Personal Data will continue to be protected by implementing appropriate safeguards when it is transferred to one of these countries.
The table at Section 8 above provides details of the countries to which we transfer Personal Data, but if you want any information about any transfers of your Personal Data to third countries (including the relevant transfer mechanisms or safeguards), please contact us using the contact details listed Section 16 of this Privacy Policy.

11.    How long do we keep your Personal Data?

It is important to us that we keep your Personal Data accurate and up-to-date. We will delete the Personal Data that we hold about you when we no longer need it for the purposes for which it was obtained (as described in this Privacy Policy) or as required to comply with any legal obligations to which we are subject. 

12.    Risks to your information 

The main risk of our processing of your Personal Data is if it is lost, stolen or misused.  This could lead to your Personal Data being in the hands of someone else who may use it fraudulently or make public, information that you would prefer to keep private.
In the course of provision of your Personal Data to us, your Personal Data may be transferred over the internet.  Although we make every effort to protect the Personal Data which you provide to us, the transmission of information over the internet is not completely secure not within our control. As such, you acknowledge and accept that we cannot guarantee the security of your Personal Data transmitted over the internet and that any such transmission is at your own risk. 

13.    How we protect your information 

We are committed to protecting your Personal Data from loss, theft and misuse.  We take all reasonable precautions to safeguard the confidentiality of your personal information, including through use of appropriate organisational and technical measures. These include secure offsite hosting of your personal data and ensuring that all passwords are stored in a way that prevents subsequent decryption.
We also keep your information confidential. Our internal procedures cover the storage, access and disclosure of your information. However, no security system is impenetrable, and we cannot guarantee the security of our systems 100%. 

14.    Links to other websites

Our website may contain hyperlinks to websites that are not operated by us. These hyperlinks are provided for your reference and convenience only and do not imply any endorsement of the activities of such third-party websites or any association with their operators. Third party websites have their own terms and conditions and privacy policies, and you should read these carefully before you submit any personal information to these websites. We do not endorse or otherwise accept any responsibility or liability for the content of such third party websites or third party terms and conditions or policies.

15.    Contacting us 

If you have questions about our Privacy Policy, please feel free to email us at DPO@thebesa.com

If you wish to raise a concern or exercise any of your rights about our processing of your Personal Data, you can contact us using one of the options below.

•    You can send us an email to the following address: DPO@thebesa.com
•    You can call us on: +44 (0)1768 860459

You can write to the following postal address: Old Mansion House, Eamont Bridge, Penrith, Cumbria, CA10 2BX, United Kingdom. 
You also have a right to lodge a complaint with the relevant supervisory authority (in particular in the Member State of your habitual residence, place of work or place of the alleged infringement), if you are of the opinion that any of your Personal Data is processed in a manner constituting an infringement of applicable data protection law. In the UK this is the Information Commissioner's Office, which can be contacted on 0303 123 1113 or www.ico.org.uk/make-a-complaint.

16.    Updates to this Privacy Policy 

You can find out when this Privacy Policy was last amended by checking "LAST REVISED" date at the bottom of this page.

All changes to this Privacy Policy will be posted on this page. Please check back frequently to see any updates or changes to this Privacy Policy. 

If you object to any changes, you may cease using our Website, products or services or close your account. By continuing to use our Website, products or services after we publish changes to this Privacy Policy, you are confirming that you have read and understood the changes.

You may wish to print, download or otherwise retain a copy of this Privacy Policy (and of any revised version) for your records.

LAST REVISED: [[14] October 2022]