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We are committed to safeguarding the privacy of our website visitors and service users.

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.

We process personal data in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018, and we use cookies in accordance with the Privacy and Electronic Communications Regulations 2003 (PECR).

In this policy, "we", "us" and "our" refer to Bespoke Software Limited. Our contact details are set out in Section 11.

In this Section 2 we have set out:

1. the general categories of personal data that we may process;
2. in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
3. the purposes for which we may process personal data; and
4. the legal bases of the processing.

We may process data about your use of our website and services ("usage data"). The usage data may include your approximate 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 use of our website. The source of the usage data is Google Analytics, our analytics tracking system, which we only use where you have consented to analytics cookies. The usage data may be processed for the purposes of analysing the use of our website and services. The legal basis for this processing is your consent.

We may process your account data ("account data"). The account data may include your name, your company name, your telephone number and your email address. The source of the account data is you or your employer. The account data may be processed for the purposes of providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you.

Where you are our client, the legal basis for this processing is the performance of a contract between you and us or taking steps, at your request, to enter into such a contract. Where you deal with us on behalf of your employer, the legal basis is our legitimate interests, namely the proper administration of our business and our relationships with our clients.

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. Where you contact us using the contact form on our website, the correspondence data will include the details you enter in the form (your name, email address, telephone number and message), and our website will generate the metadata associated with the communication. 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 website and business and communications with users.

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.

In addition to the specific purposes for which we may process your personal data set out in this Section 2, 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.

We do not use your personal data for automated decision-making, including profiling, that produces legal or similarly significant effects for you.

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

We use trusted service providers to help us run our website and business, including providers of website hosting, email, IT and data storage, and website analytics (Google Analytics). These providers process personal data on our behalf, only on our instructions and under written contracts that require them to keep it secure.

We may disclose your personal data to our insurers or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance cover, 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.

In addition to the specific disclosures of personal data set out in this Section 3, 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 do not sell your personal data.

In this Section 4, we provide information about the circumstances in which your personal data may be transferred to countries outside the United Kingdom.

Google Analytics is provided by Google, and usage data collected through it may be transferred to and stored on servers in the United States. Google LLC is certified under the UK Extension to the EU-US Data Privacy Framework (sometimes called the "UK-US data bridge"), which the UK Government recognises as providing adequate protection for personal data.

Where any of our other service providers process personal data outside the United Kingdom, we will ensure that the transfer is covered by UK adequacy regulations or by appropriate safeguards, such as the International Data Transfer Agreement or the International Data Transfer Addendum issued by the Information Commissioner's Office. You can request further information about these safeguards by contacting us.

This Section 5 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

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.

We will retain your personal data as follows:

1. usage data will be retained for 14 months from the date of collection, after which it is deleted automatically;
2. account data will be retained for the duration of our business relationship and for a maximum period of six years following its end; and
3. correspondence data will be retained for a maximum period of five years following the date of our last communication with you.

Where personal data is needed in connection with an actual or potential legal claim, we will determine the period of retention with reference to the limitation period that applies to that claim (typically six years in England and Wales).

Notwithstanding the other provisions of this Section 5, 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.

We may update this policy from time to time by publishing a new version on our website. The date of the latest version is shown at the top of this page.

You should check this page occasionally to ensure you are happy with any changes to this policy.

In this Section 7, 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 Information Commissioner's Office for a full explanation of these rights.

Your principal rights under data protection law are:

1. the right to access;
2. the right to rectification;
3. the right to erasure;
4. the right to restrict processing;
5. the right to object to processing;
6. the right to data portability;
7. the right to complain to the Information Commissioner's Office; and
8. the right to withdraw consent.

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.

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.

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.

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.

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.

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.

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.

To the extent that the legal basis for our processing of your personal data is:

1. consent; or
2. 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.

If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with the Information Commissioner's Office (ICO), the UK supervisory authority for data protection. You can contact the ICO at ico.org.uk/make-a-complaint or by telephone on 0303 123 1113. We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

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. You can withdraw your consent to analytics cookies at any time using the cookie settings described in Section 9.

You may exercise any of your rights in relation to your personal data by email to info@bespokesoftware.co.uk or by written notice to us at the postal address set out in Section 11. We will respond to your request within one month of receiving it, although this may be extended in some circumstances permitted by law, in which case we will let you know.

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.

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.

Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

We use cookies for the following purposes:

1. cookie preferences: we use a cookie to remember whether you have accepted or declined analytics cookies, so that we do not ask you again on every visit. This cookie is strictly necessary and does not require your consent; and
2. analysis: with your consent, we use cookies to help us analyse the use and performance of our website and services.

The cookies we use are:

Analytics cookies are only set if you accept them in the cookie banner shown on your first visit. You can change your choice at any time by selecting Cookie settings at the bottom of any page.

Most browsers also allow you to refuse or delete cookies. The method for doing so varies from browser to browser, so please refer to your browser's help pages. Blocking all cookies may affect how some websites work.

Our service providers use cookies and those cookies may be stored on your computer when you visit our website, if you have consented to them.

We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. You can find out how Google uses this information at policies.google.com/technologies/partner-sites, and Google's privacy policy is available at policies.google.com/privacy.

In addition to our cookie settings, you can prevent Google Analytics from collecting data on all websites by installing the Google Analytics opt-out browser add-on.

This website is owned and operated by Bespoke Software Limited.