Privacy & Cookie Policy

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Background:

simply-communicate ltd understands that your privacy is important to you and that you care about how your information is used and shared online. We respect and value the privacy of everyone who visits our Site and will only collect and use information in ways that are useful to you and in a manner consistent with your rights and our obligations under the law.

This Policy applies to our use of any and all data collected by us in relation to your use of our Site.Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of our Privacy Policy is deemed to occur upon your first use of our Site. If you do not accept and agree with this Privacy Policy, you must stop using our Site immediately.

1. Definitions and Interpretation

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

“Account”

means an account required to access and/or use certain areas and features of our Site;

“Cookie”

means a small text file placed on your computer or device by our Site when you visit certain parts of our Site and/or when you use certain features of our Site. Details of the
Cookies used by our Site are set out in section 12, below;

“Our Site”

means this website, https://simply-communicate.com/

“UK and EU Cookie Law”

means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended in 2004, 2011 and 2015; and

“We/Us/Our”

means simply-communicate ltd, a limited company registered in England under 5137978, whose registered address is 2 Eastbourne Terrace, London, W2 6LG.

2. Information About Us

2.1 Our Site, https://simply-communicate.com/, is owned and operated by simply-
communicate, a limited company registered in England under 5137978, whose
registered address is 2 Eastbourne Terrace, London, W2 6LG.

Our VAT number is GB 280 6741 92.

2.2 Our data protection officer is Ella Magal who can be contacted at info@simply-
communicate.com

3. Scope – What Does This Policy Cover?

This Privacy Policy applies only to your use of our Site. It does not extend to any websites
that are linked to from our Site (whether we provide those links or whether they are shared
by other users). 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.

4. What Data Do We Collect?

Some data will be collected automatically by our Site (for further details, please see section
12 on our use of Cookies and our Cookie Policy), other data will only be collected if you
voluntarily submit it and consent to us using it for the purposes set out in section 5, for
example, when signing up for a newsletter. Depending upon your use of our Site, we may
collect some or all of the following data:

4.1     Name;
4.2     business/company name;
4.3     contact information such as email addresses and telephone numbers;
4.4     demographic information such as post code, preferences and interests;
4.5     IP address (automatically collected);
4.6     web browser type and version (automatically collected);
4.7     operating system (automatically collected);
4.8     a list of URLs starting with a referring site, your activity on Our Site, and the site you
exit to (automatically collected);
4.9     and further information as required.

5. How Do We Use Your Data?

5.1     All personal data is stored securely in accordance with the EU General Data
Protection Regulation (Regulation (EU) 2016/679) (GDPR). For more details on
security see section 6, below.
5.2     We use your data to provide the best possible services to you. This includes:
5.2.1   Providing and managing your access to our Site;
5.2.2   Personalising and tailoring your experience on our Site;
5.2.3   Supplying our services to you;
5.2.4   Personalising and tailoring our services for you;
5.2.5   Responding to communications from you;
5.2.6   Supplying you with email e.g. newsletters, alerts etc. that you have
subscribed to (you may unsubscribe or opt-out at any time by clicking on
Unsubscribe at foot of emails);
5.2.7   Market research;
5.2.8   Analysing your use of our Site [and gathering feedback] to enable us to
continually improve our Site and your user experience;

5.3      In some cases, the collection of data may be a statutory or contractual requirement,
and we will be limited in the services we can provide you without your consent for us
to be able to use such data.

5.4     With your permission and/or where permitted by law, We may also use your data for
marketing purposes which may include contacting you by email and/or telephone
and/or text message and/or post with information, news and offers on our services.
We will not, however, send you any unsolicited marketing or spam and will take all
reasonable steps to ensure that we fully protect your rights and comply with our
obligations under the GDPR and the Privacy and Electronic Communications (EC
Directive) Regulations 2003, as amended in 2004, 2011 and 2015.

5.5     Under GDPR we will ensure that your personal data is processed lawfully, fairly, and
transparently, without adversely affecting your rights. We will only process your
personal data if at least one of the following basis applies:

a) you have given consent to the processing of your personal data for one or
more specific purposes;

b) processing is necessary for the performance of a contract to which you are a
party or in order to take steps at the request of you prior to entering into a
contract;

c) processing is necessary for compliance with a legal obligation to which we are
subject;

d) processing is necessary to protect the vital interests of you or of another
natural person;

e) processing is necessary for the performance of a task carried out in the public
interest or in the exercise of official authority vested in the controller; and/or

f) processing is necessary for the purposes of the legitimate interests pursued by
us or by a third party, except where such interests are overridden by the
fundamental rights and freedoms of the data subject which require protection
of personal data, in particular where the data subject is a child.

6. How and Where Do We Store Your Data?

6.1 We only keep your data for as long as we need to in order to use it as described
above in section 5, and/or for as long as we have your permission to keep it. In any
event, we will conduct an annual review to ascertain whether we need to keep your
data. Your data will be deleted if we no longer need it, and if you choose to
unsubscribe from our newsletter then your data will also be removed.

6.2 Your data will only be stored within the European Economic Area (“the EEA”) (The
EEA consists of all EU member states, plus Norway, Iceland and Liechtenstein).
Data security is of great importance to us, and to protect your data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through our Site.

6.2 Steps we take to secure and protect your data include:

6.2.1 Data is stored on a highly available storage system with strong security
replicated between data centres.

6.2.2 Analytics data is retained for 38 months.

6.3 Notwithstanding the security measures that we take, it is important to remember
that the transmission of data via the internet may not be completely secure and that
you are advised to take suitable precautions when transmitting to us data via the
internet.

7. Do We Share Your Data?

7.1 We may contract with third parties to supply services to you on our behalf. These
may include search engine facilities, advertising and marketing. In some cases, the
third parties may require access to some or all of your data. Where any of your data
is required for such a purpose, we will take all reasonable steps to ensure that your
data will be handled safely, securely, and in accordance with your rights, our
obligations, and the obligations of the third party under the law.

7.2 We may compile statistics about the use of our Site including data on traffic, usage
patterns, user numbers, sales and other information. All such data will be
anonymised and will not include any personally identifying information. We may
from time to time share such data with third parties such as prospective investors,
affiliates, partners and advertisers. Data will only be shared and used within the
bounds of the law.

7.3 In certain circumstances we may be legally required to share certain data held by us,
which may include your personal information, for example, where we are involved in
legal proceedings, where we are complying with the requirements of legislation, a
court order, or a governmental authority. We do not require any further consent
from you in order to share your data in such circumstances and will comply as
required with any legally binding request that is made of us.

8. What Happens If Our Business Changes Hands?

8.1 We may, from time to time, expand or reduce our business and this may involve the
sale and/or the transfer of control of all or part of our business. Data provided by
users will, where it is relevant to any part of our business so transferred, be
transferred along with that part and the new owner or newly controlling party will,
under the terms of this Privacy Policy, be permitted to use the data for the purposes
for which it was originally collected by Us.

8.2 In the event that any of your data is to be transferred in such a manner, you will not
be contacted in advance and informed of the changes, unless you have contracted
services with us.

9. How Can You Control Your Data?

9.1 When you submit information via our Site or sign up to our newsletters, we will give you the ability to opt-out of receiving emails from us, which you may do by
unsubscribing using the links provided in our emails.

9.2 You may also wish to sign up to one or more of the preference services operating in
the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone
Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”).
These may help to prevent you receiving unsolicited marketing. Please note,
however, that these services will not prevent you from receiving marketing
communications that you have consented to receiving.

10. Your Right to Withhold Information and Your Right to Withdraw Information After
You Have Given it

10.1 You may access all areas of our Site without providing any data at all.

10.2 You may restrict your internet browser’s use of Cookies. For more information, see
section 12 and Our Cookie Policy.

10.3 You may withdraw your consent for us to use your personal data as set out in section
in 5 at any time by contacting us using the details set out in section 14, and we will
delete your data from our systems. However, you acknowledge this may limit our
ability to provide the best possible services to you.

11. How Can You Access Your Data?

You have the legal right to ask for a copy of any of your personal data held by us (where such data is held). Please contact us for more details at info@simply-communicate.com or using the contact details below in section 14.

12. What Cookies Do We Use and What For?

12.1 simply-communicate.com uses cookies – these are small text files that are placed on
your machine to help the site provide a better user experience, determine whether
you are logged in and provide security, personalise your browsing experience and
help us analyse the performance of our website.

12.2 In general, cookies are used to retain user preferences, store information for things
like shopping carts, and provide anonymised tracking data to third party applications
like Google Analytics. Google’s privacy policy is available at:
https://www.google.com/policies/privacy/

12.3 Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

12.4 Cookies do not typically contain any information that personally identifies a user, but
personal information that we store about you may be linked to the information
stored in and obtained from cookies.

12.5 Blocking all cookies will have a negative impact upon the usability of many websites.
If you block cookies, you may not be able to use all the features on our website.

12.6 Consent of our use of cookies will be requested on first visit to simply-
communicate.com or you will consent by using this this website and agreeing to this policy.
12.7 All Cookies used by and on our Site are used in accordance with current English and
EU Cookie Law.

12.8 Before any Cookies are placed on your computer or device, you will be shown a pop-
up or message bar requesting your consent to set those Cookies. By giving your
consent to the placing of Cookies you are enabling us to provide the best possible
experience and service to you. You may, if you wish, deny consent to the placing of
Cookies; however certain features of our Site may not function fully or as intended.

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

Name of Cookie: Google Analytics and remarketing

Purpose: To monitor performance of the site and improve
end-user experience

Strictly Necessary: No

12.10 Our Site uses analytics services provided by Google. Website analytics refers to a set
of tools used to collect and analyse usage statistics, enabling us to better understand
how people use our Site. This, in turn, enables us to improve our Site and the services
offered through it. You do not have to allow us to use these Cookies, as detailed
below, however whilst our use of them does not pose any risk to your privacy or your
safe use of our Site, it does enable us to continually improve our Site, making it a
better and more useful experience for you.

12.11 The analytics service(s) used by our Site use(s) Cookies to gather the required
information. Certain of these Cookies may be placed immediately when you first visit
our Site and it may not be possible for us to obtain your prior consent. You may
remove these Cookies and prevent future use of them by following the steps set out
below in section 12.12.

12.12 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.

12.13 You can choose to delete Cookies at any time however you may lose any information
that enables you to access Our Site more quickly and efficiently including, but not
limited to, login and personalisation settings.

12.14 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.

13. Summary of Your Rights under GDPR
Under the GDPR, you have:

13.1 the right to request access to, deletion of or correction of, your personal data held by us;

13.2 the right to complain to a supervisory authority;

13.3 be informed of what data processing is taking place;

13.4 the right to restrict processing;

13.5 the right to data portability;

13.6 object to processing of your personal data;

13.7 rights with respect to automated decision-making and profiling (see section 13 below).

To enforce any of the foregoing rights or if you have any other questions about our Site or this Privacy Policy, please contact us using the details set out in section 14 below.

14. Automated Decision-Making and Profiling

We do not use personal data for the purpose of automated decision making and profiling.

15. Contacting Us

If you have any questions about our Site or this Privacy Policy, please contact us by email at “info@simply-communicate.com” Please ensure that your query is clear, particularly if it is a request for information about the data we hold about you (as under section 10, above).

16. Changes to Our Privacy Policy

We may change this Privacy Policy as we may deem necessary from time to time, or as may be required by law. Any changes will be immediately posted on our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of our Site following the alterations. We recommend that you check this page regularly to keep up-to-date.