This Policy applies as between you, the User of this Website, and fp-tower LTD, the owner and provider of this Website. This Policy applies to our use of any and all Personal Information collected by us in relation to your use of the Website, any Services or Systems therein.
1. Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
Account: means collectively the Personal Information, payment information and credentials used by Users to access material and/or any communications System on the Website;
Content: means any text, graphics, images, audio, video, software, data compilations and any other form of information capable of being stored in a computer that appears on or forms part of this Website;
External Third Parties:
Service providers who provide IT and system administration services;
Service providers who provide business support services, which may include, but are not limited to, payment handling, delivery of purchased items, search engine facilities, advertising and marketing;
Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services;
HM Revenue & Customs, regulators and other authorities;
Other third parties as required from time to time for the purposes of the provision of the Services;
fp-tower: means fp-tower LTD, Ibex House, 162-164 Arthur Road, London, England, SW19 8AQ;
Personal Information: means any personally identifiable information that the User provided to us, such as User’s name, email address, or billing information;
Service: means collectively any online facilities, tools, services or information that fp-tower makes available through the Website either now or in the future;
System: means any online communications infrastructure that fp-tower makes available through the Website either now or in the future. This includes, but is not limited to, web-based email, message boards, live chat facilities and email links;
User / Users: means any third party that accesses the Website and is not employed by fp-tower and acting in the course of their employment; and
Website: means the website that you are currently using (www.fp-tower.com) and any sub-domains of this site (e.g. subdomain.fp-tower.com) unless expressly excluded by their own terms and conditions.
3. Data Controller
fp-tower is the controller and responsible for your Personal Information.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
4. Third-Party Links
5. Data Collected
We may collect, use, store and transfer different kinds of Personal Information and other data about you, including, without limitation, any of the following data:
date of birth;
job title & profession;
contact information such as email addresses and telephone numbers;
demographic information such as post code, preferences and interests;
financial information such as credit / debit card numbers;
IP address (automatically collected);
web browser type and version (automatically collected);
operating system (automatically collected);
a list of URLS starting with a referring site, your activity on this Website, and the site you exit to (automatically collected).
- We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
6. Data Collection
We use different methods to collect the Personal Information from and about you including through:
Direct interactions. You may give us your Personal Information by filling in forms or by corresponding with us by post, email or otherwise. This includes Personal Information you provide when you:
apply for or use our products or Services;
create an Account on our Website;
subscribe to our Service or publications;
request marketing to be sent to you;
enter a competition, promotion or survey; or
give us feedback or contact us.
7. Our Use of Personal Information
- We will only use your Personal Information when the law allows us to. Most commonly, we will use your Personal Information in the following circumstances:
where we need to perform the contract we are about to enter into or have entered into with you;
where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
where we need to comply with a legal obligation.
- We do not rely on consent as a legal basis for processing your Personal Information. You have the right to withdraw consent to marketing at any time by contacting us.
8. Purposes for use of your Personal Information
We have set out below a description of the ways we plan to use your Personal Information:
To register you as a new customer;
To process and deliver your order including:
Deliver the Services;
Manage payments, fees and charges;
Collect and recover money owed to us;
To manage our relationship with you which will include:
Asking you to leave a review or take a survey;
To enable you to partake in a prize draw, competition or complete a survey;
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data);
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you;
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences;
To make suggestions and recommendations to you about goods or services that may be of interest to you.
We will only use your Personal Information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your Personal Information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your Personal Information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We strive to provide you with choices regarding certain Personal Information uses, particularly around marketing and advertising.
We may use your identity, contact, technical, usage and Account data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased Services from us and you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your Personal Information with any third party for marketing purposes
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to Personal Information provided to us as a result of a Service purchase, Service experience or other transaction.
10. Disclosure of your Personal Information
We may share your Personal Information with the parties listed below for the purposes set out in Clause 8 (Purposes for which we will use your Personal Information) above:
External Third Parties;
We require all third parties to respect the security of your Personal Information and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Information for their own purposes and only permit them to process your Personal Information for specified purposes and in accordance with our instructions.
11. International Transfers
Whenever we transfer your Personal Information out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your Personal Information to countries that have been deemed to provide an adequate level of protection for Personal Information by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give Personal Information the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to Personal Information shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
Please contact us if you want further information on the specific mechanism used by us when transferring your Personal Information out of the EEA.
12. Personal Information Retention
We will only retain your Personal Information for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your Personal Information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for Personal Information, we consider the amount, nature and sensitivity of the Personal Information, the potential risk of harm from unauthorised use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
By law we have to keep basic information about our customers (including contact, identity, financial and transaction Personal Information) for six years after they cease being customers for tax purposes.
In some circumstances we will anonymise your Personal Information (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
13. Controlling Access to your Personal Information
Under certain circumstances, you have rights under data protection laws in relation to your Personal Information:
Request access to your Personal Information (commonly known as a “data subject access request”). This enables you to receive a copy of the Personal Information we hold about you and to check that we are lawfully processing it.
Request correction of the Personal Information that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your Personal Information. This enables you to ask us to delete or remove Personal Information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your Personal Information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your Personal Information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Withdraw consent at any time where we are relying on consent to process your Personal Information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us at firstname.lastname@example.org.
You will not have to pay a fee to access your Personal Information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Information (or to exercise any of your other rights). This is a security measure to ensure that Personal Information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Data security is of great importance to fp-tower and to protect your Personal Information we have put in place suitable physical, electronic and managerial procedures to safeguard and secure Personal Information collected online.
We have put in place appropriate security measures to prevent your Personal Information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your Personal Information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Information on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected Personal Information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
15. Change to this Policy
16. Contacting Us