Privacy Policy

6 April 2021

Introduction

This Privacy Policy describes the type of information that we collect from you ("you/your") through the use of our services ("Services") or by providing services to us and how that information may be used or disclosed by us and the safeguards we use to protect it. We have drafted this Privacy Policy to be as clear and concise as possible. Please read it carefully to understand our policies regarding your information and how we will treat it. By using the Services or with us, providing services to us you agree to the collection, use and disclosure of information in accordance with this Privacy Policy. This Privacy Policy may change from time to time and your continued use of our Services or provision of services to us is deemed to be acceptance of such changes, so please check periodically for updates. 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. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us. If you have any comments on this Privacy Policy, please email them to privacy@firstcoders.co.uk.

2. Who We Are

• 2.1 Here are our details:
  • Our Website address is https://www.firstcoders.co.uk
  • Our company name is First Coders Ltd
  • Our registered address is The Great Barn, Gaddesden Row, Hemel Hempstead, England, HP2 6HG
  • Our nominated representative is Mark Cremer and he can be contacted at privacy@firstcoders.co.uk.
• 2.2 We respect your right to privacy and will only process personal information about you or provided by you in accordance with the Data Protection Legislation which for the purposes of this Privacy Policy shall mean: (i) the retained EU law version of the General Data Protection Regulation ((EU) 2016/679) (UK GDPR), the Data Protection Act 2018 and any other national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK and then (ii) any successor legislation to the UK GDPR or the Data Protection Act 2018 and other applicable privacy laws.

3. What we may collect

• 3.1 Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
• 3.2 We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
  • Identity Data includes first name, last name, username or similar identifier. When you email, phone, or contact us otherwise, we may collect information such as your first name, last name, email address and phone number.
  • Contact Data includes billing address, invoicing address, email address and telephone numbers.
  • Financial Data includes bank account and payment card details.
• 3.3 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.
• 3.4 Under UK 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; or
  • c) processing is necessary for compliance with a legal obligation to which we are subject; and/or d) processing is necessary for the purposes of the legitimate interests pursued by us or by a third party such as our financial payments.
• 3.5 If you provide personal information to us about another data subject, you are responsible for ensuring that you have their consent to provide that data for the uses set out in this Privacy Policy and for bringing this Privacy Policy to their attention.

4.How we may collect and use your data

• 4.1 We (or third party data processors, agents and sub-contractors acting on our behalf) may collect, store and use your personal information by way of different methods to collect data from and about you including through: Direct interactions. You may give us your information by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • a) use any of our Services;
  • b) provide services to us; or
  • c) contact us via our website.
• 4.2 In addition to the above, we may use the information in the following ways:
  • a) provide information, and services that you request, or (with your consent) which we think may interest you;
  • b) carry out our contracts with you; or
  • c) provide the relevant Services to you.
• 4.3 If you are already our customer, we will only contact you electronically about things similar to what was previously sold to you.
• 4.4 If you are a new customer, you will only be contacted if you agree to it.
• 4.5 In addition, if you don't want us to use your personal data for any of the other reasons set out in this section in 4, you can let us know at any time by contacting us at privacy@firstcoders.co.uk, and we will delete your data from our systems. However, you acknowledge this will limit our ability to provide the best possible services to you.
• 4.6 We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
  • a) Where we need to perform the contract we are about to enter into or have entered into with you.
  • b) 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.
  • c) Where we need to comply with a legal or regulatory obligation, for example compliance with health and safety, tax or other statutory obligations.

5.Cookies

• 5.1 We do not use any cookies on our website.

6.Where we store your data and security

• 6.1 We may transfer your collected data to storage outside the UK. It may be processed outside the UK to receive our Services and deal with payment. If we do store or transfer data outside the UK, we will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the UK GDPR. Such steps may include, but not be limited to, the use of legally binding contractual terms between us and any third parties we engage with and the use of approved Model Contractual Arrangements. Your acceptance of this Privacy Policy shall be your consent permitting us to store or transfer data outside the UK if it is necessary for us to do so.
• 6.2 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 personal data that we hold. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
• 6.3 We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
• 6.4 By giving us your personal data, you agree to this arrangement. We will do what we reasonably can to keep your data secure.
• 6.5 We have implemented security measures such as a firewall to protect any data and maintain a high level of security.
• 6.6 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 and you take the risk that any sending of that data turns out to be not secure despite our efforts.
• 6.7 We will keep personal data for as long as is necessary which is usually the life of our relationship and up to a period of seven years after our relationship have ended. We may however be required to retain personal data for a longer period of time to ensure we comply with our legislative and regulatory requirements. We review our data retention obligations to ensure we are not retaining data for longer than we are legally obliged to.

7.Disclosing your information

• We are allowed to disclose your information in the following cases:
  • 7.1.1 If we want to sell our business, or our company, we can disclose it to the potential buyer.
  • 7.1.2 We can disclose it to other businesses in our group.
  • 7.1.3 We can disclose it if we have a legal obligation to do so, or in order to protect other people's property, safety or rights.
  • 7.1.4 We can exchange information with others to protect against fraud or credit risks.
• 7.2 We may contract with third parties to supply services to you on our behalf such as sub-contractors. We will notify you of this if it is relevant to our provision of Services to you. In addition, we use certain third parties to store personal data that we collect such as Fastmail and iCloud backup.
• 7.3 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 UK GDPR and the law. Any third party that we share data with will not be permitted to use it for any other purpose than fulfilling their contract with us.

8.Your rights

• 8.1 Under the UK GDPR, you have the right to:
  • request access to, deletion of or correction of, your personal data held by us at no cost to you;
  • request that your personal data be transferred to another person (data portability);
  • be informed of what data processing is taking place;
  • restrict processing;
  • to object to processing of your personal data; and
  • complain to a supervisory authority.
• 8.2 You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes.
• 8.3 To enforce any of the foregoing rights or if you have any other questions about this Privacy Policy, please contact us at privacy@firstcoders.co.uk.

9.Dispute Resolution

• 9.1 We will use our best efforts to negotiate in good faith and settle any dispute that may arise out of or relate to this Privacy Policy or any breach of it.
• 9.2 Any dispute shall not affect our ongoing obligations under this Privacy Policy.
• 9.3 This Privacy Policy and any dispute or claim relating to or connected with it (including non-contractual disputes or claims) shall be governed by and construed in accordance with the laws of England and Wales and the courts of England and Wales are the only place where disputes or claims relating to or connected with this Privacy Policy (including non-contractual disputes or claims) may be decided.