You are not required to give us any personal data in order to use our website. However, when you interact with us through our website (or otherwise) you may provide, or we may collect, certain information from which you are personally identifiable (which is referred to as personal data).
For the purposes of the General Data Protection Regulation or “GDPR” (and all other laws relating to the use of your personal data), we are the “data controller”, meaning that we are responsible for deciding how your personal data is used and more importantly, for keeping your data safe and only using it for legitimate reasons.
We are committed to protecting your privacy and will take all steps necessary to comply with our legal obligations when using your personal data. This privacy/cookies notice explains how we fulfil this commitment, so please read this carefully.
2. Information we collect and how we use it
You may provide us with certain personal information when you interact with our website. This includes:
- Identity – first name, surname, country of residence.
- Contact – email address, telephone numbers and address.
- Profile – your preferences for marketing, other website preferences and feedback.
We may collect the following types of information from you when you use our website (using Cookies or other tracking technologies):
- Usage – information about how you use our website, including time spent on page, click-throughs, download errors
- Technical – IP address, browser type, hardware type, network and software identifiers, device information, operating system and system configuration.
Aggregated data may be derived from your personal data but is not considered personal data in law as this data does 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 privacy/cookies notice.
The information below sets out how and why we use your personal data and our lawful basis for doing so.
We may process your personal data for more than one lawful basis depending on the specific purpose for which we are using it. Importantly, we will only use your personal data when the law allows us to.
Reasons why we use your data:
a. To provide you with news about Ben Ainslie and products or services we offer.
What data we use: Identity, Contact, Profile
Legal ground for using the data: Performance of a contract with you. Necessary for our legitimate interests (to develop our business, including our products and services and to increase the profile of INEOS).
b. For internal administration and record keeping purposes
What data we use: All
Legal ground for using the data: Performance of a contract with you.
c. Because it is necessary to comply with a legal obligation
Necessary for our legitimate interests (for effective business administration and service provision), so as to notify you of changes to our privacy/cookies notice, our Terms and Conditions or other changes to our services or products.
What data we use: Identity, Contact.
Legal ground for using the data: Performance of a contract with you.
d. To answer your enquiries which may involve contacting you by post, e-mail or phone
What data we use: Identity, Contact.
Legal ground for using the data: Performance of a contract with you. Necessary for our legitimate interests (to ensure our customers are informed and satisfied with our services)
e. To administer our website, including website trouble shooting, testing and analysis and to enable you to participate in interactive features of our website
What data we use: All.
Legal ground for using the data: Performance of a contract with you. Necessary for our legitimate interests (to ensure that our website is fully functional and operating in the most effective way for you)
3. Who we share your data with
You agree that we have the right to share your personal information with:
a. Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries.
b. Selected third parties including:
- Other business partners, suppliers and sub-contractors for the performance of any contract we enter into with you;
- Select companies outside our group for marketing purposes (where we have your express opt-in consent); and
- Analytics and search engine providers that assist us in the improvement and optimisation of our website.
We will disclose your personal information to third parties:
- if we are required to do so by law or pursuant to a binding regulatory request (in such circumstances, such disclosure will at all times be solely to the extent required by law or the applicable regulatory request);
- in the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets;
- in order to enforce or apply our Terms and Conditions and other agreements; or
- to protect the rights, property or safety of our users or others which may include exchanging information with third party companies for the purpose of fraud prevention or credit risk reduction.
We may use the information you provide to us to better understand your interests so we can try to predict what other products, services and information you might be most interested in. We call this profiling. This enables us to tailor our communications to make them more relevant and interesting for you.
Cookies and other similar technologies distinguish you from other users of our website and may:
- be fundamental to the running of our website;
- help the website to perform effectively;
- allow us to deliver a more personalised browsing experience; enable us to understand our customers’ browsing behaviour; and/or
- allow us to improve our website.
We use the following categories of cookies on our website:
Category 2: Performance Cookies – These cookies collect anonymous information on how people use our website.
For example, we use Google Analytics cookies to help us to understand how users arrive at our site, browse or use our site and highlight areas where we can improve areas such as navigation. The data stored by these cookies never shows personal details from which your individual identity can be established.
We may also use various third-party cookies to report usage statistics of the service, deliver advertisements on and through the service, and so on.
Importantly, we will not use any cookies or similar technologies (or permit any third parties to place these on our website) which are not strictly necessary for the operation of the website, without first getting your consent.
If you want to delete any cookies that are already on your computer, please refer to the help and support area on your internet browser for instructions on how to locate the file or directory that stores cookies.
Please note that by deleting our cookies or disabling future cookies you may not be able to access certain areas or features of our website.
To find out more about cookies please visit: www.allaboutcookies.org or see www.youronlinechoices.eu which contains further information about behavioural advertising and online privacy.
Further, some of our web pages may contain electronic images known as web beacons (sometimes known as clear gifs) that allow us to count users who have visited these pages. Web beacons collect only limited information which includes a cookie number, time and date of a page view, and a description of the page on which the web beacon resides. We may also carry web beacons placed by third party advertisers. These web beacons do not carry any personally identifiable information and are only used to track the effectiveness of a particular campaign.
6. Do we send any of your data outside the EEA?
The European Economic Area or “EEA” is deemed to have good standards when it comes to data privacy. As such, we consciously limit the occasions when we may need to transfer or handle your data outside of the EEA. Where we do, for example where our service providers are based outside of the EEA, we make sure that your data is still treated fairly and lawfully in all respects (including making sure we have a legal ground for sending your data outside the EEA and putting in place all necessary safeguards for such arrangement)
Where relevant, you will have the right to see a copy of any safeguards we put in place for international transfers of your data. Just get in touch with us if you would like to find out more.
7. How Long Do We Keep Your Data For?
We will retain your personal data only for as long as is strictly necessary for the purposes for which such data was originally collected (or for such longer period as may be required by law). In some circumstances we may 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.
Our website may contain links to other websites over which we have no control. We are not responsible for privacy policies or practices of other websites to which you choose to link from this site. Once you leave our website or are redirected to a third-party website or application, you are no longer governed by this privacy/cookies notice or our website’s Terms and Conditions. We encourage users to review the privacy policies of those other websites so you can understand how they collect, use and share your information.
We have implemented reasonable technical and organisational measures designed to secure your personal information from accidental loss and from unauthorised access, use, alteration or disclosure. We also make sure that third parties who need to handle your data when helping us to deliver our services are subject to suitable confidentiality and security standards.
10. Your rights
In certain situations, you are entitled to:
- access a copy of your personal data;
- correct or update your personal data, which you can do [yourself in relation to the Online Store by logging into your account or] by contacting us at the address in this privacy/cookies notice;
- erase your personal data;
- object to the processing of your personal data where we are relying on a legitimate interest (as set out in the above table);
- restrict the processing of your personal data;
- request the transfer of your personal data to a third party; or
- where you have provided your consent to certain of our processing activities you may withdraw your consent at any time (but please note that we may continue to process such personal data if we have legitimate legal grounds for doing so).
If you want to exercise any of these rights, please contact us at email@example.com
Where your request is legitimate, we will always respond within one month (unless there is a legal reason to take longer, such as where your request is particularly complex). We may also need you to confirm your identity before we proceed with your request if it is not clear to us who is making the request.
In addition to the above, you may get in touch with the ICO (Information Commissioner’s Office) if you are concerned about the way in which we are handling your personal data. However, where possible, we would really appreciate you speaking with us first if you have any concerns.
11. Changes to our privacy/cookies notice
12. How to contact us
If you have any questions about this privacy/cookies notice, please contact us at firstname.lastname@example.org