1. Introduction

This Policy sets out the obligations of Torry Harris Business Solutions (Europe) Limited (THBS, the Company, We or Us) a company registered in England and Wales under number 04307378, whose registered office is at 12 The Courtyard, Woodlands, Bradley Stoke, Bristol, BS32 4NQ (“the Company”) regarding data protection and the rights of customers (“data subjects”) in respect of their personal data under EU Regulation 2016/679 General Data Protection Regulation (“GDPR”).

The GDPR defines “personal data” as any information relating to an identified or identifiable natural person (a “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification telephone number, email address, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person. Any reference herein to “personal information” herein means “personal data”.

This Policy sets the Company’s obligations regarding the collection, processing, transfer, storage, and disposal of personal data. The procedures and principles set out herein must be followed at all times by the Company, its employees, agents, contractors, or other parties working on behalf of the Company.

We are the data controller of any personal information you provide to us. This means we are responsible for complying with data protection laws.

The Company is committed not only to the letter of the law, but also to the spirit of the law and places high importance on the correct, lawful, and fair handling of all personal data, respecting the legal rights, privacy, and trust of all individuals with whom it deals.

This Policy applies to the main website https://www.thbs.com as well as to the other product microsites owned by Torry Harris Business Solutions such as https://apiconnect.io/ and https://digitmarket.com/

This Policy shall be deemed effective as of 25th May 2018. No part of this Policy shall have retroactive effect and shall thus apply only to matters occurring on or after this date.

2. The Data Protection Principles

This Policy aims to ensure compliance with the GDPR. The GDPR sets out the following principles with which any party handling personal data must comply. All personal data must be:

2.1 Processed lawfully, fairly, and in a transparent manner in relation to the data subject.

2.2 Collected for specified, explicit, and legitimate purposes and not further processed in a manner that is incompatible with those purposes. Further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes.

2.3 Adequate, relevant, and limited to what is necessary in relation to the purposes for which it is processed.

2.4 Accurate and, where necessary, kept up to date. Every reasonable step must be taken to ensure that personal data that is inaccurate, having regard to the purposes for which it is processed, is erased, or rectified without delay.

2.5 Kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data is processed. Personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes, subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of the data subject.

2.6 Processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction, or damage, using appropriate technical or organisational measures.

We are sensitive to the privacy concerns of our users.

We are committed to processing all personal information responsibly and in compliance with applicable data protection principles as indicated above and in compliance with laws in all countries in which THBS operates.

We have specific security measures to safeguard individually identifiable information obtained through our website. These measures are applicable to all Personal Data that our website accesses or stores, in order to provide you with relevant services or product information.

This Online Privacy Statement describes our general privacy practices that detail how we collect, use, share, transfer and protect Personal Data we receive about consumers and other individuals within our clients, business partners, supplier and other organisations with which THBS has or contemplates a business relationship.

3. Who do we collect information about?

We collect information about you.

4. When do we collect personal information

We collect personal information when you use our website or otherwise when you correspond with or contact us.

5. What personal information do we collect and use?

The nature and extent of any personal information we may collect would depend upon the purpose for which you use our website.

If you contact us by telephone or if you correspond with us, we will normally collect some personal data, to include your name and contact information, from you.

If you visit our website, in general you can do so without providing any personal data about yourself.

However, to access some parts of our websites, such as to download specific information or for one or more of the following reasons: user ID creation, registering on to our website or commenting on website content, reporting a problem, etc. we may need to collect personal data from you.

Please be aware that providing personal data to us in these events is voluntary.

However, if you do not provide Personal Data to us, then you would not be able to benefit from the respective functionality offered by our websites, such as communication, downloading of documents or recruitment.

The purposes for which Personal Data is normally collected include but are not necessarily restricted to the examples as mentioned below:

  • All forms of communications with you. We may receive on line requests of a varying nature from you which may require us to access and use your personal data to enable us to telephone you or contact you via email.
  • Direct Marketing and promotion of the Company’s services. We will require some personal data from you for these purposes. We will normally provide you with options for the use of your personal data when used for this purpose.
  • Recruitment. It is normally necessary to use some of your personal information for the purpose of all types of recruitment. Except where you specifically request otherwise, we may retain your Personal Data to facilitate considering you in relation to other employment opportunities with the Company in the future.
  • Discussion forums. The sharing of some personal data is normally a requirement to enable you to participate in our discussion forums or chat rooms. As is often the case, any comments you choose to make via this media may be accessible to and available to third parties, inside and outside of the Company, depending upon the nature of the forum or chat room you are visiting.
  • Website maintenance. Your personal data can be used as part of a process to maintain and also improve our website.
  • Surveys and Statistical Analysis. Your personal data can be used to assist is the Company in conducting customer satisfaction surveys and undertaking statistical analysis.

When providing Personal Data on this website, you acknowledge that you have the necessary authorization and consent to disclose Personal Data to be used by THBS as described in this Privacy Statement.

6. Sharing of Personal Data/Disclosure to Third parties

We will not divulge your Personal Data to third parties or any non-affiliated bodies, for marketing or other purposes.

Save as provided below, we would seek your approval prior to using or sharing your Personal Data for any purpose beyond the requirement for which it was originally collected.

We would however disclose your information to the third parties for the purposes as listed below:

  • fraud detection agencies and other third parties who operate and maintain fraud detection registers
  • the police and other third parties or law enforcement or regulatory agencies where required by law or where reasonably necessary for the prevention, investigation of or detection of crime
  • our third party services providers such as auditors, lawyers, marketing agencies, and tax advisers
  • selected third parties in connection with the sale, transfer or disposal of our business

7. Unsolicited Information

Our policy does not apply to any unsolicited information provided by you for which we have no liability or responsibility.

8. Use of Cookies

Cookies are used on this website. By using our website, you agree that cookies are to be placed on your device as explained and summarised below.

Cookies may be described as small pieces of data that a website sends to your computer’s web browser while you are navigating through the website.

Cookies can have many purposes. The main functions of a Cookie are to facilitate a smooth navigation between website pages and to remember the user’s preferences.

Cookies may be stored on your machine/ terminal device and this enables the Cookie to identify your computer.

Cookies used on our website can be facilitated by either our own website or by a third-party website.

Cookies are either “session” or “persistent” cookies:

- a session cookie is a cookie that is automatically deleted when the you close the browser

- a persistent cookie is a cookie that remains stored in the your user’s machine/ terminal device until it reaches a predetermined expiration date.

Cookies used on the THBS website have a maximum lifetime of 24 months. The types of cookies normally used on our website are as tabulated below:

Cookie Name

Description

Google Analytics (_ga)

Used to distinguish users.

Google Analytics (_gat)

Used to throttle request rate.

Google Analytics (_gid)

Used to distinguish users.

addthis.com cookies (__atuvc, bku, loc, mus, na_id, na_tc, ouid, ssc, ssh, sshs, uid, uvc, xtc, ups)

These 3rd party cookies are created by the AddThis social sharing site. If you use the AddThis tool to share content they aggregate data about what pages are shared, when, and how.

YouTube Cookies

We use YouTube service to host video content and embed YouTube's player in our web pages to allow you to watch the video without leaving our website. In accordance with YouTube’s embedding videos information page, YouTube will not set cookies on your computer until you click on the YouTube video player

disqus.com cookies

These cookies are used by the Disqus system which we use to power the comments system of our blog.

Twitter cookies

Multiple cookies used by Twitter services, to monitor referral links, and login status. These are used where the Twitter widgets are present on the website.

Double Click

Used to anonymously collect demographic information.

 

9. Links to other Websites

Our website may contain links to other third party websites and services.

While using any third-party content, you may leave our website and be directed to an external website, or to a website maintained by an entity other than by Us.

We hold no control over those third party websites or their privacy practices.

If you visit any such site, you do so entirely at your own risk and it is your responsibility to take all protective measures to guard against viruses or other destructive elements.

We make no warranty or representation regarding privacy, data protection or any other aspect of a linked or third party website. We do not endorse any linked third party websites or the information appearing thereon or any of the products or services described or offered thereon.

We strongly recommend and encourage you to diligently review the privacy policies of all other sites which you wish to visit or use before submitting any Personal Data.

10. How long do we keep personal information for?

We retain personal information for as long as necessary to provide the access to and use of the website, or for other essential purposes such as complying with our legal and regulatory obligations, handling disputes and enforcing our agreements.

11. Children

Unless otherwise indicated, our website and any products and services are intended for use by adults only and not by minors/ children.

12. Your Rights

Under data protection law you have certain rights in relation to the personal information that we hold about you. You may exercise these rights at any time by contacting us using the details set out in section 14.

Please note:

  • in some cases, we may not be able to comply with your request (e.g. we might not be able to delete your personal information) for reasons such as our own obligations to comply with other legal or regulatory requirements. However, we will always respond to any request you make and if we can’t comply with your request, we would tell you why.
  • in some circumstances exercising some of these rights (including the right to erasure, the right to restriction of processing and the right to withdraw consent) would mean we would be unable to continue providing you the service or function you had required when visiting our website.

Your rights include:

• The right to access your personal information

You are entitled to a copy of the personal information we hold about you and certain details of how we use it. The company reserves the right to levy a small charge for dealing with these requests.

This information will usually be provided in writing, unless otherwise requested, or where you or have made the request by electronic means, in which case the information will be provided by electronic means where possible.

• The right to rectification

We take reasonable steps to ensure that the information we hold about you is accurate and complete. However, if you do not believe this is the case, you can ask us to update or amend it.

• The right to erasure

In certain circumstances, you have the right to ask us to erase your personal information.

• The right to a restriction of processing

In certain circumstances, you are entitled to ask us to stop using your personal information.

• The right to data portability

In certain circumstances, you have the right to ask that we transfer any personal information that you have provided to us to another third party of your choice.

• The right to object to marketing

You can ask us to stop sending you marketing messages at any time.

• The right not to be subject to automated decision-making (including profiling)

You have a right not to be subject to a decision based solely on automated means. However, please note that we do not currently undertake any automated decision making.

• The right to withdraw consent

For certain uses of your personal information, we will ask for your consent. Where we do this, you have the right to withdraw your consent to further use of your personal information.

• The right to lodge a complaint with the ICO

You have a right to complain to the Information Commissioner’s Office (ICO) if you believe that any use of your personal information by us is in breach of applicable data protection laws and regulations.

More information can be found on the Information Commissioner’s Office website: www.ico.org.uk

Making a complaint will not affect any other legal rights or remedies that you have.

13. How we protect your information

We are ISO 27001 complaint and we use a range of organisational and technical security measures to protect your information from unauthorized access, loss, alteration, disclosure or improper use.

These include passwords and secure logins which are changed at regular intervals, limiting access to files to necessary personal use, anti-virus software and firewalls and cloud back up of our information.

14. Contacting us

If you have any questions about how we collect, store or use your personal information, you may contact us at:

The Data Protection Officer
Torry Harris Business Solutions (Europe) Limited
12 The Courtyard,
Woodlands,
Bradley Stoke,
Bristol,
BS32 4NQ
Or by email: This email address is being protected from spambots. You need JavaScript enabled to view it.

15. Updates to this Privacy Policy

From time to time we may need to make changes to this Privacy Policy, for example, as the result of government regulation, new technologies, or other developments in data protection laws or privacy generally. Any changes will be released by and accessible via our website.

This Privacy Policy was last updated on: 25 May 2018.

Please send any requests relating to your personal information and our Privacy Policy to:

The Data Protection Officer
Torry Harris Business Solutions (Europe) Limited
12 The Courtyard,
Woodlands,
Bradley Stoke,
Bristol,
BS32 4NQ
Or by email: This email address is being protected from spambots. You need JavaScript enabled to view it.

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