Privacy

PRIVACY POLICY – WCF LTD (T/A HAT TRICK MEDIA)

WCF Ltd, Crawhall, Brampton, Cumbria, CA8 1TN (trading as Hat Trick Media) ("we", "the Company", "WCF”) are committed to protecting and respecting the confidentiality, integrity and security of the personal information we hold about each past or present client, customer or enquirer of Hat Trick Media ("Client”, "you", "your").

This policy sets out the basis on which Client Data (see definition below) will be processed by us, and how we comply with our responsibilities under applicable data protection laws ("Data Protection Laws"). Please read this policy carefully and if you have any questions or concerns please contact us using the information below.

"Client Data” in this Policy covers personal data provided to, or collected by, us and held, electronically or on paper, relating to Clients of Hat Trick Media and, where the Client is an organisation, relating to its employees, staff and agents.

For the purposes of the Data Protection Laws, WCF Ltd is a data controller of Client Data.

We wish to make it clear however that Client Data does not include personal data relating to our Client’s own clients, customers and enquirers ("End User Data”) which is provided to us by our Clients only for the purposes of allowing us to provide them with the contracted services. We are acting as a data processor in relation to the End User Data, with the Client being the data controller. This Privacy Policy does not cover End User Data held by WCF as a data processor.

Personal data collection

We hold Client Data which has been provided to us or collected by us directly or through one of our authorised data processors in one of the following ways:

· By our Clients as part of our agreement to provide them with web design, development, hosting or email services;

· Through an online or telephone enquiry;

· Via online research;

· Via social media metadata; or

· Purchased as part of a business acquisition

We do not collect Customer Data directly.

Categories of personal data we may collect and hold

We may collect the following personal information about our Clients:

· name;

· company;

· contact details including telephone number and email address;

· user name; and

· job title

Purposes for which Client Data is used

We will use Client Data for the following purposes:-

· providing graphic or web design, web development, hosting or email newsletter services ordered by our Clients under our Terms of Use;

· maximising the usage and efficiency of our website and diagnosing any problems;

· sending out email newsletters and promotional literature and determining its effectiveness;

· providing personal access to our domain portals and email marketing products; and

· fulfilling our legal and fiduciary responsibilities.

Legal basis for Processing

WCF processes Client Data only as follows:

· Where it is necessary for the performance of our agreement with Clients;

· Where it is necessary for compliance with our legal obligations;

· Where it is necessary for the purposes of our legitimate business interests, which include maintaining direct, relevant and appropriate contact with our Clients to enable us to give them the best and relevant service and products; or

· Where you have given your consent for the processing of your personal data.

We may process Client Data on more than one legal basis. Please contact us if you need details as to which legal ground we are relying on to process any specific item of personal data.

Disclosure of Client Data

We will not disclose Client Data to any third party except as set out below.

We may disclose personal data to third parties who are providing services to us, in particular to the IT company that hosts our websites, to the payment gateways who process card payments, to the company that manages email campaigns and to our project management software provider.

We may also disclose personal data we hold to third parties:

(a) in the event that we sell any business or assets, in which case we may disclose personal data we hold to the prospective buyer of such business or assets; and/or

(b) if we are permitted by law to disclose your personal data to that third party or are under a legal obligation to disclose your personal data to that third party.

Access and other rights

Clients may request to see the personal information we hold either digitally or on file at any point by making a request in writing to us via The Company Secretary, WCF Ltd, Crawhall, Brampton, Cumbria, CA8 1TN or via email to pam.murray@wcf.co.uk. This request will be responded to within 30 working days. You will be provided with a copy of the personal information we hold about you. If we require more time to respond fully to any request, we will notify you in writing within the 30-day period referred to. Any additional copies of any information we provide to you may be subject to a reasonable fee.

You also have other rights under Data Protection Laws in relation to your personal data. In particular, you may have (i) the right to request that we rectify or erase information we hold about you in certain circumstances, (ii) the right to ask us to limit our processing of your information, (iii) the right (if we are processing information based on your consent, such as for marketing purposes) to withdraw your consent, (iv) the right to object to certain processing of your information (including the right to object to processing of your personal data for direct marketing purposes at any time), (v) the right to ask us to move, copy or transfer your personal information to another organisation.

If you wish to exercise any of these rights, please contact us via the Company Secretary at Crawhall, Brampton, Cumbria, CA8 1TN or via email on pam.murray@wcf.co.uk.

Accuracy of personal data

We try to ensure that the information we hold about our Clients is accurate and kept up-to-date. However, if at any time you believe that any information we are holding about you is inaccurate, out-of-date or incomplete, please notify us via Hat Trick Media, 32, Autumn Park, Business Centre, Dysart Rd, Grantham NG31 7EU as soon as possible or via email at thrive@hattrickmedia.co.uk. We will promptly correct or delete any information found to be incorrect.

Security

We have put in place what we consider to be appropriate technical and organisational security measures appropriate to the level of risk against unlawful or unauthorised processing of the personal data we hold about you, and against the accidental loss of, or damage to, such personal data. We regularly monitor our systems for possible vulnerabilities and suspicious activity.

Transferring personal data outside the EEA

Except if appropriate safeguards are in place, we will not transfer any data to a country outside of the European Economic Area ("EEA") or to a person based outside the EEA (unless required to do so by applicable EU or member state law to which we are subject) and, in such circumstances, we shall inform you of such requirement (unless prohibited by applicable EU or member state law on important grounds of public interest). If we or one of our data processors enters into EU Standard Contractual Clauses (or their equivalent in the UK) with a third party outside the EEA to whom personal information is being transferred, this will be deemed "appropriate safeguards" for the purposes of this Policy.

Retention of data

We are committed to ensuring that we do not retain Client Data for any longer than is necessary for the purposes for which it was obtained. We will hold Client Data so long as we continue to provide services under the terms of our agreement.

Marketing

Marketing communications via email are sent only to those Clients who have elected to receive such information. This operates on a strict permission based policy. All emails requested also include an option to unsubscribe; these requests are fulfilled within minutes and no further communications will be sent to those Clients who have stated that they do not wish to receive communications.

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 notice of every website you visit.

Changes to this policy

We may make changes to this Privacy Policy at any time. Any changes we make will be posted on this page and, where appropriate, notified to you in writing. Please refer to this page regularly to see any changes or updates to this policy.

Contact

If you have any queries about this policy or your personal data, or you wish to submit an access request or raise a complaint about the way your personal data has been handled, please do so in writing and address this to the Company Secretary, WCF Ltd, Crawhall, Brampton, Cumbria, CA8 1TN or via email on pam.murray@wcf.co.uk.

Complaints

If you are not satisfied with our response to any queries or complaints you raise with us or believe we are not processing your personal data in accordance with the Data Protection Laws you have the right to lodge a complaint at the Information Commissioner’s Office (https://ico.org.uk/).


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