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Privacy policy 

1. Introduction 

1.1 We are committed to safeguarding the privacy of our website visitors, service  users, individual customers and customer personnel. 

1.2 This policy applies where we are acting as a data controller with respect to  the personal data of such persons; in other words, where we determine the  purposes and means of the processing of that personal data. 

1.3 We use cookies on our website. Insofar as those cookies are not strictly  necessary for the provision of our website and services, we will ask you to  consent to our use of cookies when you first visit our website. 

1.4 In this policy, "we", "us" and "our" refer to Retinize Limited. For more  information about us, see Section 13. 

2. The personal data that we collect 

2.1 In this Section 2 we have set out the general categories of personal data that  we process and, in the case of personal data that we did not obtain directly  from you, information about the source and specific categories of that data. 

2.2 We may process data enabling us to get in touch with you ("contact data").  The contact data may include your name, email address, telephone number,  postal address and/or social media account identifiers. The source of the  contact data is you and/or your employer. If you log into our website using a  social media account, we will obtain elements of the contact data from the  relevant social media account provider. 

2.3 We may process your website user account data ("account data"). The  account data may include your account identifier, name, email address,  business name, account creation and modification dates, website settings and  marketing preferences. The primary source of the account data is you and/or  your employer, although some elements of the account data may be  generated by our website. If you log into our website using a social media  account, we will obtain elements of the account data from the relevant social  media account provider. 

2.4 We may process information relating to transactions, including purchases of  goods and/or services, that you enter into with us and/or through our website  ("transaction data"). The transaction data may include your name, your  contact details and the transaction details. The source of the transaction data  is you and/or our payment services provider. 

2.5 We may process information contained in or relating to any communication  that you send to us or that we send to you ("communication data"). The  communication data may include the communication content and metadata  associated with the communication. Our website will generate the metadata  associated with communications made using the website contact forms. 

2.6 We may process data about your use of our website and services ("usage  data"). The usage data may include your IP address, geographical location,  browser type and version, operating system, referral source, length of visit,  page views and website navigation paths, as well as information about the  timing, frequency and pattern of your service use. The source of the usage  data is our analytics tracking system.

3. Purposes of processing and legal bases 

3.1 In this Section 3, we have set out the purposes for which we may process  personal data and the legal bases of the processing. 

3.2 Operations - We may process your personal data for the purposes of  operating our website, the processing and fulfilment of orders, providing our  services, generating invoices, bills and other payment-related documentation,  and credit control. The legal basis for this processing is our legitimate  interests, namely the proper administration of our website, services and  business. 

3.3 Publications - We may process account data for the purposes of publishing  such data on our website and elsewhere through our services in accordance  with your express instructions. The legal basis for this processing is our  legitimate interests, namely the publication of content in the ordinary course  of our operations. 

3.4 Relationships and communications - We may process contact data,  account data, transaction data and/or communication data for the purposes  of managing our relationships, communicating with you (excluding  communicating for the purposes of direct marketing) by email, SMS, post, fax  and/or telephone, providing support services and complaint handling. The  legal basis for this processing is our legitimate interests, namely  communications with our website visitors, service users, individual customers  and customer personnel, the maintenance of relationships, and the proper  administration of our website, services and business. 

3.5 Direct marketing - We may process contact data, account data and/or  transaction data for the purposes of creating, targeting and sending direct  marketing communications by email, SMS, post and/or fax and making  contact by telephone for marketing-related purposes. The legal basis for this  processing is our legitimate interests, namely promoting our business and  communicating marketing messages and offers to our website visitors and  service users. 

3.6 Research and analysis - We may process usage data and/or transaction  data for the purposes of researching and analysing the use of our website and  services, as well as researching and analysing other interactions with our  business. The legal basis for this processing is our legitimate interests,  namely monitoring, supporting, improving and securing our website, services  and business generally. 

3.7 Record keeping - We may process your personal data for the purposes of  creating and maintaining our databases, back-up copies of our databases and  our business records generally. The legal basis for this processing is our  legitimate interests, namely ensuring that we have access to all the  information we need to properly and efficiently run our business in  accordance with this policy. 

3.8 Security - We may process your personal data for the purposes of security  and the prevention of fraud and other criminal activity. The legal basis of this  processing is our legitimate interests, namely the protection of our website,  services and business, and the protection of others. 

3.9 Insurance and risk management - We may process your personal data  where necessary for the purposes of obtaining or maintaining insurance  coverage, managing risks and/or obtaining professional advice. The legal 

basis for this processing is our legitimate interests, namely the proper  protection of our business against risks. 

3.10 Legal claims - We may process your personal data where necessary for the  establishment, exercise or defence of legal claims, whether in court  proceedings or in an administrative or out-of-court procedure. The legal basis  for this processing is our legitimate interests, namely the protection and  assertion of our legal rights, your legal rights and the legal rights of others. 

3.11 Legal compliance and vital interests - We may also process your personal  data where such processing is necessary for compliance with a legal  obligation to which we are subject or in order to protect your vital interests or  the vital interests of another natural person. 

4. Providing your personal data to others 

4.1 We may disclose your personal data to our insurers and/or professional  advisers insofar as reasonably necessary for the purposes of obtaining or  maintaining insurance coverage, managing risks, obtaining professional  advice. 

4.2 Your personal data held in our website or service database will be stored on  the servers of our hosting services providers in the UK, EEA or USA. 

4.3 Financial transactions relating to our website and services are handled by our  payment services providers, currently paddle.com. We will share transaction  data with our payment services providers only to the extent necessary for the  purposes of processing your payments, refunding such payments and dealing  with complaints and queries relating to such payments and refunds.  

4.4 In addition to the specific disclosures of personal data set out in this Section  4, we may disclose your personal data where such disclosure is necessary for  compliance with a legal obligation to which we are subject, or in order to  protect your vital interests or the vital interests of another natural person. We  may also disclose your personal data where such disclosure is necessary for  the establishment, exercise, or defence of legal claims, whether in court  proceedings or in an administrative or out-of-court procedure. 

5. International transfers of your personal data 

5.1 In this Section 5, we provide information about the circumstances in which  your personal data may be transferred to a third country under UK and/or EU  data protection law. 

5.2 We may transfer your personal data from the European Economic Area (EEA)  to the UK and process that personal data in the UK for the purposes set out in  this policy, and may permit our suppliers and subcontractors to do so, during  any period with respect to which the UK is not treated as a third country  under EU data protection law or benefits from an adequacy decision under EU  data protection law; and we may transfer your personal data from the UK to  the EEA and process that personal data in the EEA for the purposes set out in  this policy, and may permit our suppliers and subcontractors to do so, during  any period with respect to which EEA states are not treated as third countries  under UK data protection law or benefit from adequacy regulations under UK  data protection law. 

5.3 The hosting facilities for our website are situated in UK, EEA and USA. The  competent data protection authorities have made an adequacy determination  with respect to the data protection laws of each of these countries. Transfers 

to each of these countries will be protected by appropriate safeguards,  namely the use of standard data protection clauses adopted or approved by  the competent data protection authorities. 

5.5 You acknowledge that personal data that you submit for publication through  our website or services may be available, via the internet, around the world.  We cannot prevent the use (or misuse) of such personal data by others.

 

6. Retaining and deleting personal data 

6.1 This Section 6 sets out our data retention policies and procedures, which are  designed to help ensure that we comply with our legal obligations in relation  to the retention and deletion of personal data. 

6.2 Personal data that we process for any purpose or purposes shall not be kept  for longer than is necessary for that purpose or those purposes. 

6.3 We will retain your personal data as follows: 

(a) contact data will be retained for a minimum period of 12 months following the date of the most recent contact between you and us, and  for a maximum period of 12 months following that date; 

(b) account data will be retained for a minimum period of 12 months  following the date of closure of the relevant account, and for a  maximum period of 12 months following that date; 

(c) transaction data will be retained for a minimum period of 12 months  following the date of the transaction, and for a maximum period of 12 months following that date; 

(d) communication data will be retained for a minimum period of 12 months following the date of the communication in question, and for a  maximum period of 12 months following that date; 

(e) usage data will be retained for 12 months following the date of  collection. 

6.4 Notwithstanding the other provisions of this Section 6, we may retain your  personal data where such retention is necessary for compliance with a legal  obligation to which we are subject, or in order to protect your vital interests  or the vital interests of another natural person. 

7. Your rights 

7.1 In this Section 7, we have listed the rights that you have under data  protection law. 

7.2 Your principal rights under data protection law are: 

(a) the right to access - you can ask for copies of your personal data; 

(b) the right to rectification - you can ask us to rectify inaccurate  personal data and to complete incomplete personal data; 

(c) the right to erasure - you can ask us to erase your personal data; 

(d) the right to restrict processing - you can ask us to restrict the  processing of your personal data;

(e) the right to object to processing - you can object to the processing  of your personal data; 

(f) the right to data portability - you can ask that we transfer your  personal data to another organisation or to you; 

(g) the right to complain to a supervisory authority - you can  complain about our processing of your personal data; and 

(h) the right to withdraw consent - to the extent that the legal basis of  our processing of your personal data is consent, you can withdraw that  consent. 

7.3 These rights are subject to certain limitations and exceptions. You can learn  more about the rights of data subjects by visiting  

https://edpb.europa.eu/our-work-tools/general-guidance/gdpr-guidelines recommendations-best-practices_en and https://ico.org.uk/for 

organisations/guide-to-data-protection/guide-to-the-general-data-protection regulation-gdpr/individual-rights/. 

7.4 You may exercise any of your rights in relation to your personal data by  written notice to us, using the contact details set out below. 

8. About cookies 

8.1 A cookie is a file containing an identifier (a string of letters and numbers) that  is sent by a web server to a web browser and is stored by the browser. The  identifier is then sent back to the server each time the browser requests a  page from the server. 

8.2 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. 

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

9. Cookies that we use 

9.1 We use cookies to identify you when you visit our website and as you  navigate our website, and to help us determine if you are logged into our  website  

10. Cookies used by our service providers 

10.1 Our service providers use cookies and those cookies may be stored on your  computer when you visit our website. 

10.2 We use Google Analytics. Google Analytics gathers information about the use  of our website by means of cookies. The information gathered is used to  create reports about the use of our website. You can find out more about  Google's use of information by visiting  

https://www.google.com/policies/privacy/partners/ and you can review  Google's privacy policy at https://policies.google.com/privacy. 

11. Managing cookies

11.1 Most browsers allow you to refuse to accept cookies and to delete cookies.  The methods for doing so vary from browser to browser, and from version to  version. You can however obtain up-to-date information about blocking and  deleting cookies via these links: 

(a) https://support.google.com/chrome/answer/95647 (Chrome); 

(b) https://support.mozilla.org/en-US/kb/enhanced-tracking-protection-firefox-desktop (Firefox); 

(c) https://help.opera.com/en/latest/security-and-privacy/ (Opera); 

(d) https://support.microsoft.com/en-gb/help/17442/windows-internet explorer-delete-manage-cookies (Internet Explorer); 

(e) https://support.apple.com/en-gb/guide/safari/manage-cookies-and website-data-sfri11471/mac (Safari); and 

(f) https://support.microsoft.com/en-gb/help/4468242/microsoft-edge browsing-data-and-privacy (Edge). 

11.2 Blocking all cookies will have a negative impact upon the usability of many  websites. 

11.3 If you block cookies, you will not be able to use all the features on our  website. 

12. Amendments 

12.1 We may update this policy from time to time by publishing a new version on  our website. 

12.2 You should check this page occasionally to ensure you are happy with any  changes to this policy. 

12.3 We may notify you of significant changes to this policy by email.

13. Our details 

13.1 This website is owned and operated by Retinize Limited. 

13.2 We are registered in Northern Ireland under registration number NI663613,  and our registered office is at 2 Crescent Gardens, Belfast, BT7 1NS, UK. 

13.3 You can contact us: 

(a) by post, to the postal address given above; 

(b) using our website contact form; 

(c) by email, using the email address published on our website.

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