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

1.4    Our website incorporates privacy controls which affect how we will process your
          personal data. By using the privacy controls, you can specify whether you would like to
          receive direct marketing communications and limit the publication of your information.
          You can access the privacy controls via [URL].

1.5    In this policy, “we”, “us” and “our” refer to Obelisk London Limited Managing Director
         Ciaran Comerford. For more information about us, see Section 13.

2.0  Credit

2.1    This document was created using a template from SEQ Legal https://seqlegal.com/free-legal-documents/privacy-policy.

3.0  How we use your personal data

3.1     In this Section we have set out:

         (a)   the general categories of personal data that we may process;

         (b)  in the case of personal data that we did not obtain directly from you, the source
                 and specific categories of that data;

         (c)  the purposes for which we may process personal data; and

         (d)  the legal bases of the processing.

3.2    We may process data about your use of our website and services (“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 and
         services. The legal basis for this processing is our legitimate interests, namely
         monitoring and improving our website and services.

3.3    We may process information that you post for publication on our website or through our
         services (“publication data”). The publication data may be processed for the purposes
         of enabling such publication and administering our website and services. The legal basis
         for this processing is our legitimate interests, namely the proper administration of our
         website and 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
        Privacy Policy of offering, marketing and selling relevant goods and/or services to you. The legal basis
        for this processing is our legitimate interests, namely the proper administration of our
        website and business.

3.5   We may process information relating to transactions, including purchases of goods
        and/or services, that you enter into with us and/or through our website (“transaction
        data”). The source of the transaction data is you and/or our payment services provider.
        The transaction data may be processed for the purpose of supplying the purchased
        goods and/or 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; providing that, if you are not the
        person contracting with us, the legal basis for this processing is our legitimate interests,
        namely the proper administration of our website and business.

3.6   We may process information that you provide to us for the purpose of subscribing to our
        email notifications and/or newsletters (“notification data”). The notification data may be
        processed for the purposes of sending you the relevant notifications and/or newsletters.
        The legal basis for this processing is our legitimate interests, namely communications
        with our website visitors and service users.

3.7    We may process email and telephone contact details. The source of this data is
         gathered from you supplying information on our website. This data may be processed
         for matching relevant products and services to our clients and prospects needs as we
         see fit. The legal basis for this processing is our legitimate interests, namely our
         prospects and clients showing initial interest in our products and services. We have a
         subscription management system where subscribers can opt out at anytime.

3.8    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.

3.9    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.

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

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

4.0 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    Your personal data held in our website database will be stored on the servers of our
          hosting services providers.


4.3    We may disclose personal data to our suppliers or subcontractors insofar as reasonably
          necessary for smooth process of demand in our products and services to be carried out
          effectively.


4.4    In addition to the specific disclosures of personal data set out in this Section, 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.

5.0  International transfers of your personal data


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


5.2    The hosting facilities for our website are situated in United Kingdom. The European
         Commission has made an “adequacy decision” with respect to the data protection laws
         of each of these countries.


5.3    Automated Email Service Providers (which are subject to change to meet business
         requirements are situated in United Kingdom. The European Commission has made an
        “adequacy decision” with respect to the data protection laws of each of these countries.
         Transfers to each of these countries will be protected by appropriate safeguards, namely
         contact Ciaran Comerford via email support@obelisk-london.com to obtain information
         about our Automated Email Service Providers host data storage provider.


5.4   You acknowledge that 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.

6.0 Retaining and deleting personal data


6.1    This Section 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    We will retain your personal data as follows:


         (a) usage data will be retained for a minimum period of 30 days following the date of
               collection, and for a maximum period of which is determined by users of our
               website following that date;


        (b) account data will be retained for a minimum period of 30 days following the date of
              closure of the relevant account, and for a maximum period of which is determined
              by users of our website following that date;

        (c) publication data will be retained for a minimum period of 30 days following the
             date when the relevant publication ceases to be published on our website or
             through our services, and for a maximum period of which is determined by users
             of our website following that date;


        (d) enquiry data will be retained for a minimum period of 30 days following the date of
              the enquiry, and for a maximum period of which is determined by users of our
              website following that date;


         (e) transaction data will be retained for a minimum period of 30 days following the
              date of the transaction, and for a maximum period of which is determined by users
              of our website following that date;


          (f) notification data will be retained for a minimum period of 30 days following the
               date that we are instructed to cease sending the notifications, and for a maximum
               period of which is determined by users of our website following that date
               (providing that we will retain notification data insofar as necessary to fulfil any
               request you make to actively suppress notifications); and


         (g) contact details name, email, address, telephone number will be retained for a
               minimum period of 30 days following point of initial contact, and for a maximum
               period of which is determined by users of our website following last date of contact.


6.4   Notwithstanding the other provisions of this Section, 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.

7.0  Your rights


7.1    In this Section, we have listed the rights that you have under data protection law.


7.2    Your principal rights under data protection law are:


        (a) the right to access – you can ask for copies of your personal data;


        (b) the right to rectification – you can ask us to rectify inaccurate personal data and to
              complete incomplete personal data;


        (c) the right to erasure – you can ask us to erase your personal data;


        (d) the right to restrict processing – you can ask use to restrict the processing of your
              personal data;


        (e) the right to object to processing – you can object to the processing of your
              personal data;


        (f) the right to data portability – you can ask that we transfer your personal data to
             another organisation or to you;


        (g) the right to complain to a supervisory authority – you can complain about our
              processing of your personal data; and


        (h) the right to withdraw consent – to the extent that the legal basis of our processing
              of your personal data is consent, you can withdraw that consent.


7.3    These rights are subject to certain limitations and exceptions. You can learn more about
         the rights of data subjects by visiting

         https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.


7.4    You may exercise any of your rights in relation to your personal data by written notice to
         us, using the contact details set out below.

8.0  About cookies


8.1     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.


8.2    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.


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

9.0  Cookies that we use


9.1     We use cookies for the following purposes:


        (a) authentication and status – we use cookies to identify you when you visit our
              website and as you navigate our website, and to determine if you are logged into
              the website (cookies used for this purpose are: Google, Facebook, Instagram,
              YouTube, Pinterest, Twitter tracking analytics);


        (b) personalisation – we use cookies to store information about your preferences and
              to personalise the website for you (cookies used for this purpose are: Google,
              Facebook, Instagram, YouTube, Pinterest, Twitter tracking analytics);


         (c) security – we use cookies as an element of the security measures used to protect
              user accounts, including preventing fraudulent use of login credentials, and to
              protect our website and services generally (cookies used for this purpose are:
              Google, Facebook, Instagram, YouTube, Pinterest, Twitter tracking analytics);


        (d) advertising – we use cookies to help us to display advertisements that will be
              relevant to you (cookies used for this purpose are: Google, Facebook, Instagram,
              YouTube, Pinterest, Twitter tracking analytics);


        (e) analysis – we use cookies to help us to analyse the use and performance of our
              website and services (cookies used for this purpose are: Google, Facebook,
              Instagram, YouTube, Pinterest, Twitter tracking analytics); and


        (f) cookie consent – we use cookies to store your preferences in relation to the use of
             cookies more generally (cookies used for this purpose are: Google, Facebook,
             Instagram, YouTube, Pinterest, Twitter tracking analytics).

10.0 Cookies used by our service providers


10.1   Our service providers use cookies and those cookies may be stored on your computer
         when you visit our website.


10.2  We use Google Analytics. Google Analytics gathers information about the use of our
         website by means of cookies. The information gathered is used to create reports about
         the use of our website. You can find out more about Google’s use of information by
         visiting https://www.google.com/policies/privacy/partners/ and you can review Google’s
         privacy policy at https://policies.google.com/privacy.


10.3   We use Google, Facebook, Instagram, YouTube, Pinterest, Twitter to track analytics.
         This service uses cookies for advertising relevant products and services to our website
         users. The relevant cookies are: Google, Facebook, Instagram, YouTube, Pinterest,
         Twitter tracking analytics.

11.1  Managing cookies


11.1   Most browsers allow you to refuse to accept cookies and to delete cookies. The
        methods for doing so vary from browser to browser, and from version to version. You
        can however obtain up-to-date information about blocking and deleting cookies via these
        links:


        (a) https://support.google.com/chrome/answer/95647 (Chrome);


        (b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);


        (c) https://help.opera.com/en/latest/security-and-privacy/ (Opera);


        (d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);


        (e) https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac (Safari); and


        (f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).


11.2   Blocking all cookies will have a negative impact upon the usability of many websites.


11.3  If you block cookies, you will not be able to use all the features on our website.

12.0  Amendments


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


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


12.3   We may notify you of significant changes to this policy by email.

13.0 Our details


13.1   This website is owned and operated by Obelisk London Limited and uses the trading
         names ‘Obelisk London Limited’ for offering specific products or services.
         Privacy Policy


13.2   We are registered in England and Wales under registration number 07178403, and our
         registered office is at 12 London Road, London SE1 6JZ, United Kingdom.

13.3   Our principal place of business is at 12 London Road, London SE1 6JZ, UnitedKingdom.


13.4  You can contact us:


         (a) by post, to the postal address given above;


         (b) by telephone, on +44 207 928 5358; or


         (c) by email, using support@obelisk-london.com.

14.0  Data protection officer


14.1   Our data protection officer’s contact details are: Ciaran Comerford +44 207928 5258 |
         Email: support@obelisk-london.com