Privacy Policy

1.       Introduction

1.1      We are committed to safeguarding the privacy of our website visitors.

1.2      This policy applies where we are acting as a data controller with respect to the personal data of our website visitors in other words, where we determine the purposes and means of the processing of that personal data.

1.3      We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website, we will ask you to consent to our use of cookies when you first visit our website.

1.4      In this policy, "we", "us" and "our" refer to Wildfire Internet Ltd.

2.       How we use your personal data

2.1      In this Section 2 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.

2.2      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 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 and services and identifying malicious visitors to our site.

2.3      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 selling relevant goods and/or services to you. The legal basis for this processing is contract.

2.4      We may process information relating to our customer relationships, including customer contact information ("customer relationship data"). The customer relationship data may include your name, your employer, your job title or role, your contact details, and information contained in communications between us and you or your employer. The source of the customer relationship data is you or your employer. The customer relationship data may be processed for the purposes of managing our relationships with customers, resolving support issues, and keeping records of those communications. The legal basis for this processing is our legitimate interests, namely the proper management of our customer relationships.

2.5    We may process information about prospects (“prospect data”).  This data may include your name, your employer, your job title or role, your contact details, quotations and information contained in communications between us and you or your employer. The source of this data is from you or your employer, introducers or publicly available data. This data may be processed for promoting our products and services to you. The legal basis for this processing is our legitimate interests, namely commercially bringing useful products or services to your attention.

2.6    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.

2.7    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.

2.8    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.

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

3.       Providing your personal data to others

3.1      We may disclose your data to any member of our group of companies (this means other companies we work with in partnership) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.

3.2      We may disclose your 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.

3.3      We may disclose data to our suppliers, subcontractors or third party services insofar as reasonably necessary for statistical tracking and reporting, error resolution and live chat.

3.4      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 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.

4.       International transfers of your personal data

4.1      In this Section 4, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).

4.2      Cloudflare process data submitted on the site in their role as a global content delivery network (CDN). Transfers to each of the countries involved in the Cloudflare CDN will be protected by appropriate safeguards, as set out in the Cloudflare data processing agreement available at https://www.cloudflare.com/media/pdf/cloudflare-customer-dpa-20180402.pdf.

4.3      You acknowledge that any personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

5.       Retaining and deleting personal data

5.1      This Section 5 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.

5.2      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.

5.3      We will retain your personal data as follows:

(a)       account, notification and enquiry data will be retained for a minimum period of 6 months following date of sign up or registration and reviewed for deletion every 12 months.

(b)      all other categories of data will be retained for a minimum of 2 years

5.4      In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:

(a)       the period of retention will be determined based on the legal bases of legitimate interests and contract.

5.5      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.

6.       Amendments

6.1      We may update this policy from time to time by publishing a new version on our website.

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

6.3      We may notify you of significant changes to this policy by email or through the private messaging system on our website when you are logged in to the Admin Console.

7.       Your rights

7.1      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 regulatory authorities for a full explanation of these rights.

7.2      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.

7.3      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. You can access your personal data by logging into our website using your registered user credentials.

7.4      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.

7.5      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.

7.6      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.

7.7      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.

7.8      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.

7.9      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.

7.10    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.

7.11    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.

7.12    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.

7.13    You may exercise any of your rights in relation to your personal data by written notice to us via letter of email.

8.       Cookies

8.1      We use first party cookies for our site and third party cookies from our service providers as set out in our Cookie Policy at https://www.recplus.co.uk/Cookie_Policy.html.

8.2      You can view and manage which cookies are in use in the cookie pop-up message via Cookie Settings which is displayed when you first visit the website or visit again subsequently without having clicked to accept the use of cookies. Thereafter this can be accessed either via a link on our website or visiting our site from a browser which either has not been used before or is in private browsing mode.

9.       Our details

9.1      This website is owned and maintained by Wildfire Internet Limited.

9.2      Our company address and contact details are available on our contact page at https://www.recplus.co.uk/Contact.html.