1. Introduction
    1.1 We are committed to safeguarding the privacy of our website visitors and
    service users.
    1.2 This policy applies where we are acting as a data controller with respect to
    the personal data of our website visitors and service users; in other words,
    where we determine the purposes and means of the processing of that
    personal data.
    1.3 We use do not use cookies on our website
  2. Credit
    2.1 This document was created using a template from SEQ Legal
    (https://seqlegal.com).
  3. How we use your personal data
    3.1 In this Section 3 we have set out:
    (a) The general categories of personal data that we may process;
    (b) The purposes for which we may process personal data; and
    (c) The legal bases of the processing.

    3.2 We may process data about your use of our website (“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. This usage data may be processed for the purposes of
    analysing the use of the website. The legal basis for this processing is our
    legitimate interests, namely monitoring and improving our website.

    3.3 We may process your account data (“account data”).The account data may
    include your name, phone number and email address. The source of the
    account data is you. The account data may be processed for the purposes of
    providing our services, ensuring the security of our website and
    communicating with you. The legal basis for this processing is consent OR our
    legitimate interests, namely the proper administration of our business.

    3.4 We may process information contained in any enquiry you submit to us
    regarding goods and/or services] (“enquiry data”). The enquiry data may be
    processed for the purposes of offering, marketing and selling relevant
    services to you. The legal basis for this processing is consent.

    3.5 We may process information contained in or relating to any communication
    that you send to us (“correspondence data”). The correspondence 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. The correspondence
    data may be processed for the purposes of communicating with you and
    record-keeping. The legal basis for this processing is our legitimate interests,
    namely the proper administration of our business and communications with
    users.

    3.6 We may process any of your personal data identified in this policy 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.

    3.7 We may process any of your personal data identified in this policy where
    necessary for the purposes of obtaining or maintaining insurance coverage,
    managing risks, or obtaining professional advice. The legal basis for this
    processing is our legitimate interests, namely [the proper protection of our
    business against risks].

    3.8 In addition to the specific purposes for which we may process your personal
    data set out in this Section 3, we may also process any of 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.

    3.9 Please do not supply any other person’s personal data to us, unless we
    prompt you to do so.

    3.9 We may process information relating to transactions, including purchases of
    services, that you enter into with us and/or through our website
    “transaction data”). The transaction data may include your contact details,
    The transaction data may be processed for the purpose of supplying the
    purchased services and keeping proper records of those transactions. The
    legal basis for this processing is the performance of a contract between you
    and us and/or taking steps, at your request, to enter into such a contract and
    our legitimate interests, namely the proper administration of our website and
    business.
  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, or the establishment, exercise or defence of legal claims, whether in
    court proceedings or in an administrative or out-of-court procedure].

    4.2 We may disclose name, email address, phone number to our suppliers or
    subcontractors insofar as reasonably necessary for delivering goods and
    providing services.

    4.3 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 [countries outside the European
    Economic Area (EEA)].
    5.2 We will not transfer your personal data outside of the EEA.
    5.3 The hosting facilities for our website are situated in the UK.
  6. Retaining and deleting personal data
    6.1 This Section 6 sets out our data retention policies and procedure, 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 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. Amendments
    7.1 We may update this policy from time to time by publishing a new version on
    our website.

    7.2 You should check this page occasionally to ensure you are happy with any
    changes to this policy.
  8. Your rights
    8.1 In this Section 8, we have summarised the rights that you have under data
    protection law. Some of the rights are complex, and not all of the details have
    been included in our summaries. Accordingly, you should read the relevant
    laws and guidance from the regulatory authorities for a full explanation of
    these rights.

    8.2 Your principal rights under data protection law are:
    (a) the right to access;
    (b) the right to rectification;
    (c) the right to erasure;
    (d) the right to restrict processing;
    (e) the right to object to processing;
    (f) the right to data portability;
    (g) the right to complain to a supervisory authority; and
    (h) the right to withdraw consent.

    8.3 You have the right to confirmation as to whether or not we process your
    personal data and, where we do, access to the personal data, together with
    certain additional information. That additional information includes details of
    the purposes of the processing, the categories of personal data concerned
    and the recipients of the personal data. Providing the rights and freedoms of
    others are not affected, we will supply to you a copy of your personal data.
    The first copy will be provided free of charge, but additional copies may be
    subject to a reasonable fee.

    8.4 You have the right to have any inaccurate personal data about you rectified
    and, taking into account the purposes of the processing, to have any
    incomplete personal data about you completed.

    8.5 In some circumstances you have the right to the erasure of your personal
    data without undue delay. Those circumstances include: the personal data are
    no longer necessary in relation to the purposes for which they were collected
    or otherwise processed; you withdraw consent to consent-based processing;
    you object to the processing under certain rules of applicable data protection
    law; the processing is for direct marketing purposes; and the personal data
    have been unlawfully processed. However, there are exclusions of the right to
    erasure. The general exclusions include where processing is necessary: for
    exercising the right of freedom of expression and information; for compliance
    with a legal obligation; or for the establishment, exercise or defence of legal
    claims.

    8.6 In some circumstances you have the right to restrict the processing of your
    personal data. Those circumstances are: you contest the accuracy of the
    personal data; processing is unlawful but you oppose erasure; we no longer
    need the personal data for the purposes of our processing, but you require
    personal data for the establishment, exercise or defence of legal claims; and
    you have objected to processing, pending the verification of that objection.
    Where processing has been restricted on this basis, we may continue to store
    your personal data. However, we will only otherwise process it: with your
    consent; for the establishment, exercise or defence of legal claims; for the
    protection of the rights of another natural or legal person; or for reasons of
    important public interest.

    8.7 You have the right to object to our processing of your personal data on
    grounds relating to your particular situation, but only to the extent that the
    legal basis for the processing is that the processing is necessary for: the
    performance of a task carried out in the public interest or in the exercise of
    any official authority vested in us; or the purposes of the legitimate interests
    pursued by us or by a third party. If you make such an objection, we will
    cease to process the personal information unless we can demonstrate
    compelling legitimate grounds for the processing which override your
    interests, rights and freedoms, or the processing is for the establishment,
    exercise or defence of legal claims.

    8.8 You have the right to object to our processing of your personal data for direct
    marketing purposes (including profiling for direct marketing purposes). If you
    make such an objection, we will cease to process your personal data for this
    purpose.

    8.9 You have the right to object to our processing of your personal data for
    scientific or historical research purposes or statistical purposes on grounds
    relating to your particular situation, unless the processing is necessary for the
    performance of a task carried out for reasons of public interest.

    8.10 To the extent that the legal basis for our processing of your personal data is:
    (a) consent; or
    (b) that the processing is necessary for the performance of a contract to
    which you are party or in order to take steps at your request prior to
    entering into a contract,
    and such processing is carried out by automated means, you have the right
    to receive your personal data from us in a structured, commonly used and
    machine-readable format. However, this right does not apply where it would
    adversely affect the rights and freedoms of others.

    8.11 If you consider that our processing of your personal information infringes
    data protection laws, you have a legal right to lodge a complaint with a
    supervisory authority responsible for data protection. You may do so in the
    EU member state of your habitual residence, your place of work or the place
    of the alleged infringement.

    8.12 To the extent that the legal basis for our processing of your personal
    information is consent, you have the right to withdraw that consent at any
    time. Withdrawal will not affect the lawfulness of processing before the
    withdrawal.
    8.13 You may exercise any of your rights in relation to your personal data by
    written notice to us in addition to the other methods specified in this Section
  9. About cookies
    9.1 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.

    9.2 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.

    9.3 Cookies do not typically contain any information that personally identifies a
    user, but personal information that is stored about you may be linked to the
    information stored in and obtained from cookies.
  10. Cookies that we use
    10.1 We do not use cookies
  11. Cookies used by our service providers
    11.1 Our service providers, may use cookies and those cookies may be stored on
    your computer when you visit our website. Please refer to their individual
    Privacy Policy when redirected from our site.
  12. Our details
    12.1 This website is owned and operated by Hot Tub Response.
    12.3 Our principal place of business is at
    Ladds Garden Village
    Bath Road
    Hare Hatch
    Reading
    RG10 9SB
    12.4 You can contact us:
    (a) by post, to the postal address given above;
    (b) using our website contact form;
    (c) by telephone, on the contact number published on our website; or
    (d) by email, using the email address published on our website
  13. Data protection officer
    14.1 Our data protection officer’s contact details are
    Kieran Sendall
    07505 735678
    info@hottubresponse.co.uk