Background

51Degrees.mobi Limited understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits this website, 51degrees.com ("Our Site") and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.

Please read this Privacy Policy carefully and ensure that you understand it. If you are not comfortable with the contents of this Privacy Policy, please stop using Our Site immediately.

Definitions and Interpretation

In this Policy the following terms shall have the following meanings:

Information About Us

Our Site is owned and operated by 51Degrees.mobi Limited, a limited company registered in England under company number 07397529.

Registered address: 51Degrees, Davidson House, Forbury Square, Reading, Berkshire, RG1 3EU, United Kingdom.

VAT number: 105 0599 36.

For the purposes of data protection laws, we are the ‘controller’ of the processing of personal data described in this Privacy Policy. As a controller we decide why and how your personal data is processed and are responsible to you for that processing.

What Does This Policy Cover?

This Privacy Policy applies only to your use of Our Site. Our Site may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.

What is Personal Data?

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the "GDPR") as any information relating to an identified or identifiable person who can be directly or indirectly identified in particular by reference to an identifier'.

Personal data is, in simpler terms, any information we can link to you where we have already identified you or could do so with reasonable effort. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

What Are My Rights?

Under the GDPR, you have the following rights, which we will always work to uphold:

a) The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 15.

b) The right to access the personal data we hold about you. Part 13 will tell you how to do this.

c) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 15 to find out more.

d) The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Part 15 to find out more.

e) The right to restrict (i.e. prevent) the processing of your personal data.

f) The right to object to us using your personal data for a particular purpose or purposes.

g) The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a structured copy of that personal data that can be read by a computer to re-use with another service or business in many cases.

h) Rights relating to automated decision-making and profiling. These rights apply where we make decisions about you, without any manual checks, where these have a legal or other significant impact on your life. We do not use your personal data in this way.

For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 15.

Further information about your rights can also be obtained from the Information Commissioner's Office or your local Citizens Advice Bureau.

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner's Office. However, we are confident we can resolve your complaints promptly so encourage you to contact us in the first instance.

What Data Do We Collect?

Depending upon your use of Our Site, we may collect some or all of the following personal and non-personal data (please also see Part 14 on our use of Cookies and similar technologies):

• Name

• Address

• Email address

• Telephone number

• Business name

• Job title

• Profession

• Payment information and order transaction history

• Information about your preferences and interests

• IP address

• Web browser type and version

• Operating system

• A list of URLs starting with a referring site and including your activity on Our Site

• The frequency of your visits to Our Site

• Your 51Degrees website username and password

• Marketing preferences

• Cookie IDs and related data

• Your location

If you directly disclose personal data including personally sensitive data through Our Site's public messaging boards, this information may be collected and used by others.

How Do You Use My Personal Data?

Under the GDPR, we must always have a legal reason (known as a ‘lawful basis’) for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data will be used for the following purposes and legitimate interests (where relevant):

• Providing and managing your Account;

• Providing and managing your access to Our Site and the services we provide through it;

• Personalising and tailoring your experience on Our Site;

• Supplying our products or services to you. Your personal details are required in order for us to enter into a contract with you.

• Personalising and tailoring our products or services for you.

• Communicating with you. This may include responding to emails or calls from you.

• Supplying you with information by email or post that you have opted-in to (you may unsubscribe or opt-out at any time by email us or where provided using the unsubscribe link towards the bottom of an email).

• Analysing your use of Our Site and gathering feedback to enable us to continually improve Our Site and your user experience.

• To conduct research about your opinion of current services or of potential new services that may be offered.

With your permission or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email or telephone or text message or post with information, news, and offers on our products or services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.

How Long Will You Keep My Personal Data?

If we collect your personal data, the length of time for which we retain it is determined by a number of factors including the purpose(s) for which we use that information and our obligations under applicable laws. We do not retain personal data in an identifiable form for longer than is necessary.

We may need your personal information to establish, bring or defend legal claims. For this purpose, we may retain your personal information for up to 7 years after the date it is no longer needed by us for any of the purposes listed in Part 7. The only exceptions to this are where:

• the law requires us to hold your personal information for a longer period, or delete it sooner. For example, we may retain your contact details indefinitely in a suppression list to ensure we do not send direct marketing to you if you have asked us not to contact you for marketing purposes;

• we collect personal data from you when placing a session cookie on your device, in which case we will delete that data at the end of your browsing session (see below for further details regarding the cookies we use);

• you exercise your right to have the information erased (where it applies) and we do not need to hold it in connection with any of the reasons permitted or required under the law; or

• you exercise your right to require us to retain your personal information for a period longer than our stated retention period.

How and Where Do You Store or Transfer My Personal Data?

We will only store or transfer your personal data within the United Kingdom (“UK”) and the European Economic Area (the "EEA"). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the GDPR or to equivalent standards by law.

The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including use of computer servers in a controlled, secure environment which is protected from unauthorised access, use or disclosure and when personal information (such as a credit card number) is transmitted to other Web sites, it is protected through the use of the Secure Socket Layer (SSL) protocol.

Do You Share My Personal Data?

We may share your personal data with other companies in our group. This includes subsidiaries and our holding company and its subsidiaries. We do so for audit and administration purposes or where necessary to provide services to you or our clients.

We may sometimes contract with the following third parties to supply certain products and services. These may include payment processing, delivery, and marketing. In some cases, those third parties may require access to some or all of your personal data that we hold.

• Authorise.net - payment processing - UK

• Worldpay - payment processing - US

• Vale & West – accountancy services – UK

• Chargify – subscription billing services - US

• Vimeo - video host and player services - US

If any of your personal data is required by a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party's obligations under the law, as described above in Part 9.

If any personal data is transferred outside of the EEA and UK, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR, as explained above in Part 9.

In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

How Can I Control My Personal Data?

In addition to your rights under the GDPR, set out in Part 5, when you submit personal data via Our Site, you may be given options to restrict our use of your personal data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails and at the point of providing your details).

Can I Withhold Information?

You may access certain areas of Our Site without providing any personal data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.

How Can I Access My Personal Data?

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a "subject access request".

All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 15.

There is not normally any charge for a subject access request. If your request is 'manifestly unfounded or excessive' (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We will respond to your subject access request within one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

How Do You Use Cookies?

Our Site may place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by us and are used only by us. We use Cookies to provide the functionality necessary to provide the website services. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.

All Cookies used by and on Our Site are used in accordance with current Cookie Law.

The features of Our Site depend on Cookies to function. Cookie Law deems these Cookies to be "strictly necessary". These Cookies are shown in the table below. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser's settings as detailed below, but please be aware that Our Site may not work properly if you do so. We have taken care to ensure that your privacy is not at risk by allowing them.

The following first-party Cookies may be placed on your computer or device:

Our supplier, Chargify, may also place and read cookies from your device when you are directed to its website to place an order. Chargify is responsible for these cookies and you can find further information reqarding its cookies at www.chargify.com/privacy-policy.

Our supplier, Vimeo, may also place and read cookies from your device when you watch videos embedded in our website. Vimeo are responsible for these cookies and you can find further information reqarding its cookies at vimeo.com/privacy.

In addition to the controls that we provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.

It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.

How Do I Contact You?

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details:

Email address: contactus@51degrees.com.

Postal Address: 51Degrees, Davidson House, Forbury Square, Reading, Berkshire, RG1 3EU, United Kingdom.

Changes to this Privacy Policy

We may change this Privacy Policy from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

Any changes will be posted on Our Site and/or where appropriate, emailed to you. We recommend that you check this page regularly to keep up-to-date.