Last updated: September, 2019
Introduction to this Policy
This website www.modpodsinternational.com (“our Site”) is brought to you by ModPods International Ltd (“we”, “us” or “our”), a company registered in England and Wales under company number 10966361. We have our registered office and main trading address at 5 The Quadrant, Coventry, CV1 2EL
We ask that you read this Policy carefully as it governs our use of your information and binds both you and us. If you do not agree with or accept this Policy, you should stop using our Site immediately.
We may update this Policy from time to time and post any changes to it to our site in accordance with the “Changes to this Policy” section below.
References in this Policy to:
For the purposes of applicable Data Protection Law, we, ModPods International Ltd, are the Data Controller and therefore we are responsible for, and control the processing of, your Personal Data in accordance with applicable Data Protection Law. “Personal Data” has a legal definition but, in brief, it refers to information from which a living person can be identified. Such information must be protected in accordance with Data Protection Law.
Information we may collect about you
We will collect information about you when you visit our Site or do business with us (including requesting quotations and ordering services from us). This information may include your name, your contact details (including postal address, email address and telephone number), your payment details (i.e. relating to any payment you make to us in connection with our services), any other information we request from time to time to enable us to provide our Site to you and to continue to do business with you and any other information you provide to us.
We may occasionally receive information about you from other sources, including:
We will add this data to any information we already hold about you.
Any of the information or data referred to in this paragraph (together, the “Information”) may or may not constitute or include Personal Data.
Safety of Children
Our services are not intended for and may not permissibly be used by individuals under the age of 16. We do not knowingly collect Personal Data from persons under 16. If it comes to our attention that we have collected Personal Data from such a person, we may delete this Information without notice. If you have reason to believe that this has occurred, please contact firstname.lastname@example.org
How long we keep your Information
We will keep your Information only for as long as we need to hold it for the purposes set out in this Policy.
However, if required we will be entitled to hold your Information for longer periods in order to comply with our legal or regulatory obligations.
Legal basis for processing your Information
From 25 May 2018, under applicable Data Protection Law we may only process your Information if we have a “legal basis” (i.e. a legally permitted reason) for doing so. We will have a legal basis for processing your Information under this Policy if:
Your consent to processing
If you have previously given your consent to the processing of your Information, you may freely withdraw such consent at any time. You can do this by notifying us in writing using our contact details below.
If you withdraw your consent, and if we do not have another legal basis for processing your Information (see above), then we will stop processing your Information. If we do have another legal basis for processing your Information then we may continue to do so subject to your legal rights (for which see “Your Rights” below).
Where we are unable to rely on consent, we will rely on the performance of a contract with you or compliance with our legal obligations as the basis for processing your Information, unless we consider that processing is necessary for our legitimate interests (e.g. delivery and/or improvement of our services). Marketing is considered separately below.
How we use your Information
We will use your Information for the following purposes:
If you have not purchased services from us or enquired about purchasing any of our services and if you have given us prior permission, then we will use the Information we hold about you to contact you by email for the purpose of letting you know about our services. If you prefer not to receive these communications from us, or if you no longer wish to receive them, then you can opt out at any time.
If you are an existing customer of ours, or if you have previously purchased services from us or enquired about purchasing any of our services, we may use the Information we hold about you to contact you by email to provide you with details of similar services to those purchased or enquired about by you. If you prefer not to receive these communications from us, or if you no longer wish to receive them, then you can opt out at any time. We have undertaken a legitimate interests assessment of our marketing practices and we have concluded that legitimate interests is an appropriate basis for those practices, as we consider that it is reasonable to assume that you would expect us to promote our services to you in this manner and that doing so involves relatively little intrusion into your privacy or any disproportionate impact on your fundamental rights; furthermore, because we utilise an email marketing system which allows us to exercise a sophisticated degree of control over your marketing preferences, we do not consider that a less invasive form of processing is available to achieve the same ends.
You have the right at any time to ask us to stop processing your Information for marketing purposes. If you wish to exercise this right, you should contact us by sending an email to email@example.com giving us enough information to identify you and deal with your request. Alternatively you can follow the unsubscribe instructions in emails you receive from us.
We may share your Information with:
Keeping your Information secure
We will use technical and organisational measures in accordance with good industry practice to safeguard your Information. However, while we will use all reasonable efforts to safeguard your Information, you acknowledge that the use of the internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any Information that is transferred from you or to you via the internet.
We may monitor and record communications with you (such as telephone conversations and emails) for the purpose of quality assurance, training, fraud prevention and compliance. Any information that we receive through such monitoring and communication will be added to the information we already hold about you and may also be used for any of the purposes listed in this Policy.
Information about other individuals
If you give us information on behalf of a third party, you confirm that the third party has appointed you to act on his/her/their behalf and has agreed that you can:
From time to time we may need to transfer your Information to countries outside the European Economic Area, which comprises the EU member states plus Norway, Iceland and Liechtenstein (‘EEA’). Such countries may not have similar protections in place regarding protection and use of your Information as those set out in this Policy. Therefore, if we do transfer your Information to countries outside the EEA we will take reasonable steps in accordance with applicable Data Protection Law to ensure adequate protections are in place to protect the security of your Information.
By submitting your Information to us in accordance with this Policy you consent to these transfers for the purposes specified in this Policy.
This section sets out your legal rights in respect of any of your Personal Data that we are holding and/or processing. If you wish to exercise any of your legal rights you should put your request in writing to us (using our contact details below) giving us enough information to identify you and respond to your request.
If you have any concerns about how we collect or process your Information then you have the right to lodge a complaint with a supervisory authority, which for the UK is the UK Information Commissioner’s Office (‘ICO’). Complaints can be submitted to the ICO through the ICO helpline by calling 0303 123 1113. Further information about reporting concerns to the ICO is available at https://ico.org.uk/concerns/.
When you access our Site, cookies will be used to distinguish you from other visitors to our Site. Cookies are text files placed on your computer to collect standard Internet log information and visitor behaviour information. The information is used to track visitor use of our Site and allows us to:
Our software will issue cookies to your system when you access and use our Site and you will be asked to consent to this at the time (e.g. when you first visit our Site). Cookies do not affect your privacy and security since a cookie cannot read data off your system or read cookie files created by other sites. You can set your system not to accept cookies if you wish (for example by changing your browser settings so cookies are not accepted), however please note that some of the features of our Site may not function if you remove cookies from your system.
Changes to this Policy
We keep this Policy under regular review and may change it from time to time. If we change this Policy we will post the changes on our Site and place notices on our Site as applicable, so that you may be aware of the Information we collect and how we use it at all times.
This Policy aims to provide you with all relevant details about how we process your Information in a concise, transparent, intelligible and easily accessible form, using clear and plain language. If you have any difficulty in reading or understanding this Policy, or if you would like this Policy in another format (for example audio, large print or braille), please get in touch with us.
Our contact details
We welcome your feedback and questions. If you wish to contact us, please send an email to firstname.lastname@example.org or you can write to us at ModPods International Ltd, 5 The Quadrant, Coventry, CV1 2EL