Global Private Solutions Limited (also trading as "GPS” and “FOS")
This statement sets out how Global Private Solutions Limited, a company incorporated and registered in England and Wales (registered number 08134425) and having its registered office at Palladium House, 1-4 Argyll Street, London W1F 7LD, (“we”, “us” or "our") uses and protects personal information that a user (“you” or "your") provides when using our website at www.globalprivatesolutions.com (the "Site"), in compliance with European Union (EU) and United Kingdom (UK) data protection laws and regulations, including the Data Protection Act 1998 and EC Directive 95/46/EC (up to and including 24 May 2018) and Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and repealing Directive 95/46/EC (General Data Protection Regulation) OJ L 119/1, 4.5.2016 ("GDPR") (on and from 25 May 2018) (together, the "Data Protection Laws").
WHAT INFORMATION DO WE COLLECT?
When you register to use the Site you will be required to provide us with certain personal information, including:
· your name; and
· your contact information, including email address.
We may also collect and process personal information from you:
· where you provide us with your personal details, including when you fill in any forms or upload information on the Site;
· where you use the Software and the Services, any personal information about you that is submitted by or obtained from your third party providers via the Software and the Services;
· where you report a problem to us, or if you submit an enquiry to us relating to the Site;
· where you provide your credit card or other financial information in order to purchase Services;
· where you respond to any surveys which, for research purposes, we may ask you to complete;
· from your usage of the Site (including technical information such as IP addresses and URLs); and/or
· which you email to us or otherwise provide your personal information to us.
WHAT DO WE DO WITH THE INFORMATION WE COLLECT?
We will use the personal information you provide for the following reasons:
· where you have a User Account, to administer your registration, including welcome emails and other emails in relation to account management or system maintenance;
· to provide you with the Services and access and use of all functionality of the Software;
· to send you information about the Services and Software that you have downloaded or purchased via the Site;
· to process payments you make for our Services;
· to collect and use information about your usage of our Site on an anonymised basis in order to identify trends on usage and improve our products and to provide further services to our customers (including sharing such data to our third party partners to enable them to do the same);
· to help the investigation and resolution of any legal issues arising out of the use of the Site or the Software;
· to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you where permitted;
· to provide you with marketing information about goods and services we offer (you have a right to opt out of these communications at any time by contacting info@globalprivate solutions.com);
· to improve our Site to ensure that content is presented in the most effective manner for you and for your computer; and
· as part of our efforts to keep our Site safe and secure.
WHO DO WE SHARE THIS INFORMATION WITH?
We will not transfer, disclose, sell, distribute or lease your personal information to third parties unless (i) we have your permission; (ii) we are required to do so by law; or (iii) in the following circumstances:
· to payments services providers in order for your purchase of Services to be processed, in which case we will disclose certain credit card or other financial information about you;
· to certain third party service providers who help us to deliver the Site to you (for example third party technology companies who may provide elements of the Site's functionality) or to provide Services to you;
· in the event that we sell or buy any business or assets, in which case we will disclose your personal information to the prospective seller or buyer of such business or assets;
· if we, or substantially all of our assets, are acquired by a third party, in which case personal information held by us about our users will be one of the transferred assets;
· as required to enforce or apply our Website Terms and Conditions;
· if third parties claim that any Content you provide via your User Account infringes their rights (e.g. their privacy or intellectual property rights); and
· to relevant authorities where you carry out criminal activity (e.g. breach of the Computer Misuse Act 1990).
HOW LONG DO WE KEEP THE INFORMATION?
We keep your personal information for a period of 6 years from the date of collection or, if you continue to be our customer, for a period of 6 years from the end of the customer relationship, to enable us to retain the information we may require for legal and regulatory purposes. Please be assured that we will only keep your information to the extent we require to do so for legal and regulatory purposes.
WHAT ARE YOUR RIGHTS
DESCRIPTION OF RIGHT
A right to access personal information held by us about you.
A right to require us to rectify any inaccurate personal information held by us about you.
A right to require us to erase personal information held by us about you. This right will only apply where (for example): we no longer need to use the personal information to achieve the purpose we collected it for; or where you withdraw your consent (if we are using your personal data based on your consent); or where you object to the way we process your data (in line with Right 6 below).
A right to restrict our processing of personal information held by us about you. This right will only apply where (for example): you dispute the accuracy of the personal information held by us; or where you would have the right to require us to erase the personal information but would prefer that our processing is restricted instead; or where we no longer need to use the personal data to achieve the purpose we collected it for, but you require the data for the purposes of dealing with legal claims.
A right to receive personal information, which you have provided to us, in a structured, commonly used and machine readable format. You also have the right to require us to transfer this personal information to another organisation, at your request.
A right to object to our processing of your personal information (including for the purposes of sending marketing materials to you).
A right to withdraw your consent, where we are relying on it to use your personal data (for example, to provide you with marketing information about our services or products).
HOW WILL WE COMPLY WITH DATA PROTECTION LAWS?
· Providing the Site : We will process your personal information to the extent that this is necessary for the performance of our obligations under our Website Terms and Conditions; and
SECURITY OF DATA
· Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your data transmitted to us; any transmission is at your own risk.
· However, we will take all steps reasonably necessary to ensure that your personal information is secure. In order to try to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.
· Where we have given you (or where you have chosen) Login Details which enable you to access certain parts of the Site, you are responsible for keeping these details confidential. You agree that you will not share your login details with anyone else.
· The information that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA who work for us or for one of our third-party suppliers, including Microsoft in the United States. This includes staff engaged in, among other things, the processing of your payment details and the provision of support services to us. We will take all steps reasonably necessary to ensure adequate protections are in place to ensure the security of your information in accordance with the Data Protection Laws, including putting appropriate contractual arrangements with our third-party suppliers. If you would like further information in relation to the third-party suppliers to whom we may transfer your personal data, please contact us at firstname.lastname@example.org.
· As outlined in the Website Terms and Conditions, we may link to other websites, which are not within our control.
· Once you have left the Site, we cannot be responsible for the protection and privacy of any information which you provide to these sites. You should exercise caution and look at the privacy statement applicable to the website in question.
USER ACTIVITY DATA AND COOKIES
If you have any concerns regarding our processing of your personal information, or are not satisfied with our handling of any request by you in relation to your rights, you also have the right to make a complaint to the Information Commissioner's Office. Their address is:
First Contact Team, Information Commissioner's Office