This Privacy Policy sets out the basis on which we will process any Personal Data that we may collect about you as a visitor to our website at www.99websites.com or our customers or potential customers, or other business partners or in any other cases where we specifically state that this policy will apply. This policy further sets out how we protect your privacy and your rights in respect of our use of your Personal Data.
WHO IS THE DATA CONTROLLER?
A “data controller” is a person or organisation who alone or jointly determines the purposes for which, and the manner in which, any personal data is, or is likely to be, processed. In this sense, SIMPLYSOCIALMEDIAGROUP LTD of 56 Church Road, Lytham St. Annes, Lancashire, United Kingdom, FY8 3TL (“£99websites”, “we”, “us”, “our”) is the data controller. If you have any questions about data protection at £99websites in general, you can reach us by email using info@99poundsite.co.uk.
WHAT IS PERSONAL DATA?
Personal data is any information that relates to an identified or identifiable living individual. Different pieces of information, which collected together can lead to the identification of a particular person, also constitute Personal Data.
WHY DO WE HAVE A PRIVACY POLICY?
The UK’s Data Protection Act (“DPA”) and the EU’s General Data Protection Regulation (“GDPR”) control how your Personal Data is used by us. We are also required to explain which Personal Data we collect from you via our website and shop, what we use it for, when we delete it and how your data is protected.
WHAT ARE THE LEGAL BASES FOR PROCESSING PERSONAL DATA
All Personal Data that we obtain from you via our website will only be processed for the purposes described in more detail below. This is done within the framework of the DPA and the GDPR and only if at least one of the following applies: a) you have given your consent, b) the data is necessary for the fulfilment of a contract / pre-contractual measures, c) the data is necessary for the fulfilment of a legal obligation, or d) the data is necessary to protect the legitimate interests of our company, provided that your interests are not overridden.
WHAT PERSONAL DATA DO WE COLLECT FROM YOU?
a) Collection of access data and log files
When you visit our website, we collect the Personal Data that your browser automatically transmits to our server. This is technically necessary for us to display our website and to ensure its stability and security. In this sense, we collect the following data: i) IP address of the requesting computer, ii) Date and time of access, iii) name and URL of the file accessed, iv) website from which the access was made (referrer URL), v) browser used and, if applicable, the operating system of your device as well as the name of your access provider. The legal basis is our legitimate interest.
b) Hosting
We do not use a hosting service for the purpose of operating our website and instead our website is self-hosted. In doing so we process inventory data, contact data, content data, contract data, usage data, meta data and communication data of our customers, interested parties and visitors ourselves and on our own servers. The legal basis is our legitimate interests in an efficient and secure provision of the website and services in conjunction with the provision of contractual services.
c) Content Management System
We also use the open source Content Management System (CMS) of WordPress.Org to publish and maintain the created and edited content and texts on our website. This means that all content and texts
submitted to us by our users is transferred to our own server. In addition to texts, this also includes, for example your data in our forms. The legal basis for this processing is our legitimate interest.
d) Cookies
For the processing of personal data using cookies and similar technologies on our website, please refer to our Cookie Policy. The legal basis for the use of cookies is our legitimate interest or your consent when you agree to the use of technically non-essential cookies as further explained in our Cookie Policy.
e) Cookie consent
As set out in the UK’s Privacy and Electronic Communications Regulations (“PECR”) and the EU`s Privacy and Electronic Communications Directive (“PECD”), we need to obtain consent for the use of technically non-essential cookies. For this purpose we use a cookie consent tool, to obtain your consent to the storage of cookies and to document this consent. When you enter our website, the following Personal Data is transferred to us via our cookie consent tool: i) Your consent(s) or revocation of your consent(s); ii) Your IP address; iii) Information about your browser; iv) Information about your device; v) Time of your visit to our website. The basis for processing is our legitimate interest and your consent.
f) Contact options
We process and store the Personal Data provided in the contact enquiry solely for the purpose of processing and responding to your enquiry and contacting you. If you contact us, we will process the data you provide to respond to you and answer your questions and requests. In doing so, the principle of data economy and data avoidance is observed in that you only have to provide the data that we absolutely need from you in order to contact you. These are usually your first and last name, your email address, the topic selection and the message itself. The legal basis for processing is our legitimate interest, the provision or initiation of a contractual service and your consent.
g) Working with us
If you wish to use our website development services, we process the data you provide which typically includes Personal Data and non-personal data (“Service Data”). We recognise that you own your Service Data and provide you with complete control over your Service Data by providing you the ability to (i) access your Service Data, (ii) share your Service Data, and (iii) request export or deletion of your Service Data.
When we process Service Data, we become your Data Processor or in other words, we will process the Service Data involved in your use of our website development services in accordance with your instructions and shall use it only for the purpose of providing you our services.
We ensure that access by our employees to your data is only available on a need-to-know basis, restricted to specific individuals, and is logged and audited. We communicate our privacy and security guidelines to our employees and enforce privacy and protection safeguards strictly. The legal basis for the processing of your Service Data is our obligation to fulfil the contract we have with you.
Please note: Some jurisdictions may require you to disclose your use of our services and us as your processor in your privacy policy and/or data processing agreement as applicable. For this purpose all Service Data processed by us will be processed using our own server and take appropriate legal precautions and corresponding technical and organisational measures to ensure the protection of your Service Data.
h) Payment Data
If you make a purchase your payment data will be processed via our payment service provider Stripe. Payment data will solely be processed through Stripe and we have no access to any Payment Data you
may submit. The legal basis for the provision of a payment system is the establishment and implementation of the contract.
i) Administration, financial accounting, office organisation, contact management
We process data in the context of administrative tasks as well as organisation of our business, and compliance with legal obligations, such as archiving. In this regard, we process the same data that we process in the course of providing our contractual services. The processing bases are our legal obligations and our legitimate interest.
j)Promotional use of your data
We use your data within the legally permissible scope for marketing purposes, e.g., to draw your attention to special promotions and discount offers via email. In addition, we reserve the right to use your first and last name as well as your postal address for our own advertising purposes, e.g., to send you interesting offers and information about our products by post. This serves to protect our legitimate interests.
k)Testimonials
Within the customer reviews section, we may display certain Personal Data, share certain details, knowledge and insights. When you approve and submit your Testimonial to us your consent is obtained, and you have choices about the information in your Testimonial. The storage of Testimonials is based on your consent.
l)Newsletter
If you register for our newsletter, we use your email address to send you our email newsletter on a regular basis on the basis of your consent. Unsubscribing from the newsletter is possible at any time and can be done via the unsubscribe link provided in each newsletter. After unsubscribing, we will delete your email address unless you have expressly consented to further use of your data or we reserve the right to use data beyond this, which is permitted by law and about which we inform you in this declaration.
DISCLOSURES OF YOUR PERSONAL DATA
We will not disclose or otherwise distribute your Personal Data to third parties unless this is a) necessary for the performance of our services b) you have consented to the disclosure, c) or if we are legally obliged to do so e.g., by court order or if this is necessary to support criminal or legal investigations or other legal investigations or other legal proceedings; or proceedings at home or abroad or to fulfil our legitimate interests.
INTERNATIONAL TRANSFER
We may transfer your Personal Data to other companies as necessary for the purposes described in this Privacy Policy. In order to provide adequate protection for your Personal Data when it is transferred, we have contractual arrangements regarding such transfers. We take all reasonable technical and organisational measures to protect the Personal Data we transfer.
SOCIAL MEDIA
We are present on social media on the basis of our legitimate interest (currently, Facebook, Instagram and LinkedIn). If you contact or connect with us via social media, we and the relevant social media platform are jointly responsible for the processing of your data and enter into a so-called joint controller agreement. The Personal Information collected when contacting us is to handle your request and the bases are both your consent and our legitimate interest.
In addition, your data may be processed for market research and advertising purposes. For example, usage profiles can be created from your usage behaviour and the resulting interests. This allows, for example, advertisements to be placed within and outside the platforms that presumably correspond to
your interests. The legal basis is our legitimate interest.
When you visit our social media profiles, we, as the operator of the profile, process your actions and interactions with our profile (e.g., the content of your messages, enquiries, posts or comments that you send to us or leave on our profile or when you like or share our posts) as well as your publicly viewable profile data (e.g., your name and profile picture). Which Personal Information from your profile is publicly viewable depends on your profile settings, which you can adjust yourself in the settings of your social media account. The legal basis is our legitimate interest and your consent.
ADVERTISING
We would like to show you interesting advertising outside of our website and use various third-party tools and cookies for this purpose. These collect and process information about your activities on our website – for example, which products you are interested in or which pages you visit. By knowing what you are looking for and how you use our website, we can adapt our advertising to your needs. And thus increase the likelihood that you will also be shown suitable and interesting advertising outside our website.
We also analyse this data to evaluate the relevance of the advertisements and to optimise the advertisements for you. Through the tools, your browser regularly establishes a connection to the server of the tool provider when you visit our website. For some tools, we have no direct influence on what data is processed by the providers. The following personal data may be processed by third-party providers i) HTTP header information (e.g., IP address, web browser, website URL, date and time); ii) measuring pixel-specific data (e.g., pixel ID and cookie ID); and iii) additional information about visits to our website (e.g., orders placed, products clicked on). The legal bases for processing are our legitimate interest and your consent in case of cookies. For further information, please refer to our Cookie Policy.
HOW LONG DO WE KEEP YOUR PERSONAL DATA?
We will delete your Personal Data when we no longer need such Personal Data, for instance where:
Sometimes, however there are legal or regulatory requirements which may require us to retain your Personal Data for a specified period, and in such cases we will retain your Personal Data for such specified period; and we may need to retain your Personal Data for certain longer periods in relation to legal disputes, and in such cases we will retain it for such longer periods to the extent required.
HOW WE SECURE YOUR PERSONAL DATA
We take appropriate organisational, technical, and physical measures to help safeguard against accidental or unlawful destruction, loss, alteration, and unauthorised disclosure of, or access to, the Personal Data we collect and process. However, no method of collection, storage, or transmission is 100% secure. You are solely responsible for protecting your password, limiting access to your devices, and signing out of websites after your sessions.
SOCIAL MEDIA
We are present on social media and if you contact or connect with us via social media websites, we and the relevant social media website are jointly responsible for the processing of your data and enter into a so-called joint controller agreement. The legal basis is our legitimate interest, your consent or, in some cases, the initiation of a contract.
When you visit our social media profiles, we, as the operator of the profile, process your actions and interactions with our profile (e.g., the content of your messages, enquiries, posts or comments that you send to us or leave on our profile or when you like or share our posts) as well as your publicly viewable profile data (e.g., your name and profile picture).
Which Personal Data from your profile is publicly viewable depends on your profile settings, which you can adjust yourself in the settings of your social media account. Please take care not to transmit or share sensitive data or confidential information (e.g., application documents, bank or payment data) via social media platforms; we recommend that you use a more secure means of transmission (e.g. e-mail).
LINKED SITES
For your convenience, there may be hyperlinks on our website that link to other websites. We are not responsible for, and this Privacy Policy does not apply to the privacy practices of any linked websites or of any companies that we do not own or control. The website links may collect information in addition to the information we collect.
We do not endorse any of these linked websites, their products, services, or any of the content on their websites. We encourage you to seek and read the Privacy Policy of each linked website that you visit to understand how the information that is collected about you is used and protected.
YOUR RIGHTS AND PRIVILEGES
a. Privacy rights
You can exercise the following rights:
b) Updating your information and withdrawing your consent
If you believe that the information we hold about you is inaccurate or request its rectification, deletion, or object to legitimate interest processing, please do so by contacting us.
c) Access Request
In the event you want to make a Data Subject Access Request, please contact us. We will respond to requests regarding access and correction as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days, we will tell you why and when we will be able to respond to your request. If we are unable to provide you with any Personal Data or to make a correction requested by you, we will tell you why.
d) Complaint to a supervisory authority
The Information Commissioner’s Office (ICO) is the UK`s authority in matters of data protection. You have the right to make a complaint at any time to the ICO (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO in the first instance.
e) What we do not do
HELP AND COMPLAINTS
If you have any questions about this policy or the information we hold about you please contact us by email using info@99poundsite.co.uk.
CHANGES
The first version of this policy was issued on Wednesday 31st of July 2024 and is the current version. Any prior versions are invalid and if we make changes to this policy, we will revise the effective date.
