Tiercel (Europe) Limited Privacy Policy

BACKGROUND:

Tiercel (Europe) Limited understands that your privacy is important to you
and that you care about how your personal data is used and shared online.
We respect and value the privacy of everyone who visits this website,
http://www.tierceleurope.co.uk (“Our Site”) and will only collect and use
personal data in ways that are described here, and in a manner that is
consistent with our obligations and your rights under the law.

Please read this Privacy Policy carefully and ensure that you understand
it. Your acceptance of our Privacy Policy is deemed to occur upon your
first use of our site.
If you do not accept and agree with this Privacy Policy, you must
stop using our site immediately.

1. Definitions and Interpretation

In this Policy, the following terms shall have the following meanings:

“Account”

means an account required to access and/or use certain
areas and features of our site;

“Cookie”

means a small text file placed on your computer or device
by our site when you visit certain parts of our site and/or
when you use certain features of our site. Details of the
Cookies used by our site are set out in section 13, below;

“Cookie Law”

means the relevant parts of the Privacy and Electronic
Communications (EC Directive) Regulations 2003;

“personal data”

means any and all data that relates to an identifiable
person who can be directly or indirectly identified from
that data. In this case, it means personal data that you
give to Us via Our Site. This definition shall, where
applicable, incorporate the definitions provided in the
Data Protection Act 1998 OR EU Regulation
2016/679 – the General Data Protection Regulation (“GDPR”);
and

“We/Us/Our”

means Tiercel (Europe) Limited, a limited company
registered in England under company number 7640508, whose
registered address is 5, Tutbury Row, Worcester. WR4 0RU,
and whose main trading address is 5, Tutbury Row,
Worcester. WR4 0RU.

2. Information About Us

2.1 Our Site is owned and operated by Tiercel (Europe) Limited, a limited
company registered in England under company number 7640508, whose
registered address is 5, Tutbury Row, Worcester. WR4 0RU and whose main
trading address is 5, Tutbury Row, Worcester. WR4 0RU. Our site is hosted
by Yola Inc.

3. What Does This Policy Cover?

This Privacy Policy applies only to your use of our site. Our site may
contain links to other websites. Please note that we have no control over
how your data is collected, stored, or used by other websites and we advise
you to check the privacy policies of any such websites before providing any
data to them.

4. Your Rights

4.1 As a data subject, you have the following rights under the GDPR, which
this policy and our use of personal data have been designed to uphold:

4.1.1 The right to be informed about our collection and use of personal
data;

4.1.2 The right of access to the personal data We hold about you (see
section 12);

4.1.3 The right to rectification if any personal data We hold about you is
inaccurate or incomplete (please contact Us using the details in section
14);

4.1.4 The right to be forgotten – i.e. the right to ask us to delete any
personal data we hold about you (We only hold your personal data for a
limited time, as explained in section 6 but if you would like us to delete
it sooner, please contact us using the details in section 14);

4.1.5 The right to restrict (i.e. prevent) the processing of your personal
data;

4.1.6 The right to data portability (obtaining a copy of your personal data
to re-use with another service or organisation);

4.1.7 The right to object to us using your personal data for particular
purposes; and

4.1.8 Rights with respect to automated decision making and profiling.

4.2 If you have any cause for complaint about our use of your personal
data, please contact us using the details provided in section 14 and we
will do our best to solve the problem for you. If we are unable to help,
you also have the right to lodge a complaint with the UK’s supervisory
authority, the Information Commissioner’s Office.

4.3 For further information about your rights, please contact the
Information Commissioner’s Office or your local Citizens Advice Bureau.

5. What Data Do We Collect?

Depending upon your use of our site, we may collect some or all of the
following personal and non-personal data (please also see section 13 on our
use of Cookies and similar technologies. More information about cookies,
including details on viewing what cookies have been set and how to delete
them is available at allaboutcookies.org

5.1 name;

5.2 date of birth

5.3 gender

5.4 business/company name

5.5 job title

5.6 profession

5.7 contact information such as email addresses and telephone numbers;

5.8 demographic information such as post code, preferences and interests;

5.9 financial information such as credit / debit card numbers;

5.10 IP address;

5.11 web browser type and version;

5.12 operating system;

5.13 a list of URLs starting with a referring site, your activity on our
site, and the site you exit to.

6. How Do We Use Your Data?

6.1 All personal data is processed and stored securely, for no longer than
is necessary in light of the reason(s) for which it was first collected. We
will comply with our obligations and safeguard your rights under the GDPR at all times. For more details on security see section 7,
below.

6.2 Our use of your personal data will always have a lawful basis, either
because it is necessary for our performance of a contract with you, because
you have consented to our use of your personal data (e.g. by subscribing to
emails), or because it is in our legitimate interests. Specifically, We may
use your data for the following purposes:

6.2.1 Providing and managing your access to our site;

6.2.2 Supplying our services to you (please note that we
require your personal data in order to enter into a contract with you);

6.2.3 Personalising and tailoring our services for you;

6.2.4 Replying to emails from you;

6.2.5 Analysing your use of our site to enable us to
continually improve our Site and your user experience;

6.3 With your permission and/or where permitted by law, we may also
use your data for marketing purposes which may include contacting you by
email and/or telephone and/or post with information, news and offers on our services.
We will not, however, send you any unsolicited marketing or spam and will
take all reasonable steps to ensure that we fully protect your rights and
comply with our obligations under the GDPR and the Privacy and Electronic
Communications (EC Directive) Regulations 2003.

6.4 Third parties (including, for example, advertising networks and
providers of external services like web traffic analysis services) whose
content appears on our site may also us cookies, over which we have no
control. These cookies are likely to be analytical/performance cookies or
targeting cookies, as detailed below in section 13 (Please refer to section
13 for more information on controlling cookies). Please note that we do not
control the activities of such third parties, nor the data they collect and
use and advise you to check the privacy policies of any such third parties.

6.5 You have the right to withdraw your consent to us using your personal
data at any time, and to request that we delete it.

6.6 We do not keep your personal data for any longer than is necessary in
light of the reason(s) for which it was first collected. Data will
therefore be retained for the following periods (or its retention will be
determined on the following bases):

6.6.1 6 months after the matter you contacted us about has been resolved.

7. How and Where Do We Store Your Data?

7.1 We only keep your personal data for as long as we need to in order to
use it as described above in section 6, and/or for as long as we have your
permission to keep it.

7.2 Some or all of your data may be stored outside of the European Economic
Area (EEA) (The EEA consists of all EU member states, plus Norway, Iceland
and Liechtenstein). You are deemed to accept and agree to this by using our
site and submitting information to us. If we do store data outside the EEA,
we will take all reasonable steps to ensure that your data is treated as
safely and as securely as it would be within the UK and under GDPR.

7.3 Data security is very important to us, and to protect your data we have
taken suitable measures to safeguard and secure data collected through our
site.

7.4 Steps We take to secure and protect your data include:

7.4.1 All access to information restricted by password and/or secure key.

8. Do We Share Your Data?

8.1 In certain circumstances, We may be legally required to share
certain data held by us, which may include your personal data, for
example, where we are involved in legal proceedings, where we are
complying with legal obligations, a court order, or a governmental
authority.

8.2 We may sometimes contract with third parties to supply services to you
on our behalf. These may include payment processing, delivery of goods,
search engine facilities, advertising, and marketing. In some cases, the
third parties may require access to some or all of your data. 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 the law.

8.3 We may compile statistics about the use of our site including data on
traffic, usage patterns, user numbers, sales, and other information. All
such data will be anonymised and will not include any personally
identifying data, or any anonymised data that can be combined with other
data and used to identify you. We may from time to time share such data
with third parties such as prospective investors, affiliates, partners, and
advertisers. Data will only be shared and used within the bounds of the
law.

9. What Happens If Our Business Changes Hands?

9.1 We may, from time to time, expand or reduce our business and this may
involve the sale and/or the transfer of control of all or part of our
business. Any personal data that you have provided will, where it is
relevant to any part of our business that is being transferred, be
transferred along with that part and the new owner or newly controlling
party will, under the terms of this Privacy Policy, be permitted to use
that data only for the same purposes for which it was originally collected
by us.

9.2 In the event that any of your data is to be transferred in such a
manner, you will be contacted in advance and informed of the changes. When
contacted you will, be given the choice to have your data
deleted or withheld from the new owner or controller.

10. How Can You Control Your Data?

10.1 In addition to your rights under the GDPR, set out in section 4, OR when you submit personal data via our
site, you may be given options to restrict our use of your data. In
particular, we aim to give you strong controls on our use of your data for
direct marketing purposes (including the ability to opt-out of receiving
emails from us which you may do by unsubscribing using the links provided
in our emails).

10.2 You may also wish to sign up to one or more of the preference services
operating in the UK: The Telephone Preference Service (“the TPS”), the
Corporate Telephone Preference Service (“the CTPS”), and the Mailing
Preference Service (“the MPS”). These may help to prevent you receiving
unsolicited marketing. Please note, however, that these services will not
prevent you from receiving marketing communications that you have consented
to receiving.

11. Your Right to Withhold Information

11.1 You may access certain areas of our site without providing any data at
all. However, to use all features and functions available on our site you
may be required to submit or allow for the collection of certain data.

11.2 You may restrict our use of Cookies. For more information, see section
13.

12. How Can You Access Your Data?

You have the right to ask for a copy of any of your personal data held by
us (where such data is held). Under the GDPR, no fee is payable and we will
provide any and all information in response to your request free of charge.
Please contact us for more details at tammymurphy@tierceleurope.co.uk, or
using the contact details below in section 14.

13. Our Use of Cookies

Our Site may place and access certain first party cookies on your computer
or device. First party cookies are those placed directly by us and are used
only by us. We use cookies to facilitate and improve your experience of our
site and to provide and improve our services. By using our site you may
also receive certain third party cookies on your computer or device. Third
party cookies are those placed by websites, services, and/or parties other
than us, over which we have no control. In addition, our site uses third
party analytics services which also use cookies. Website analytics refers
to a set of tools used to collect and analyse usage statistics, enabling us
to better understand how people use our site. For more details, please
refer to our cookie policy.

14. Contacting Us

If you have any questions about our site or this Privacy Policy, please
contact us by email at: jpmurphy@tierceleurope.co.uk. Please ensure that
your query is clear, particularly if it is a request for information about
the data we hold about you (as under section 12, above).

15. Changes to Our Privacy Policy

We may change this Privacy Policy from time to time (for example, if the
law changes). Any changes will be immediately posted on our site and you
will be deemed to have accepted the terms of the privacy policy on your
first use of our site following the alterations. We recommend that you
check this page regularly to keep up-to-date.

Updated 11 March 2023