What we do to protect your privacy
This website is owned and operated by ComForm Solutions Limited (“we”, “us”, “our”, and “ourselves”) trading as ComForm Solutions. For the purposes of the Data Protection Act 1998 (Act), the data controller is ComForm Solutions Limited.
Our website is not intended for children and we do not knowingly collect data relating to children.
ComForm Solutions is the controller and responsible for your personal data (we, us or our).
You have the right to make a complaint at any time to the ICO (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Your duty to inform us of changes – it is important that the data we hold about you is accurate and current, therefore please keep us informed of any changes to your personal data.
Third-party links - our website may include links to third-party websites, plug-ins and applications. By clicking on these links or enabling connections you may be allowing third parties to collect or share your personal data. We have no control of these third-party websites, plug in or applications and are not responsible for their privacy policies, therefore you should also read their privacy policies to understand what personal data they collect about you and how they use it.
We may collect, use, store and transfer the types of personal data about you listed in Part 1 of Schedule 1.
We also collect, use and share aggregated data. However, if we combine aggregated data with your personal data so that it can directly or indirectly identify you, we treat this as your personal data.
We do not collect any special categories of personal data.
Failure to provide personal data - If we are required by law, or under the terms of a contract we have with you, to collect your personal data and you fail to provide it, we may not be able to enter into perform the contract with you and, we may have to cancel a product or service. We will notify you of this at the relevant time.
We collect personal data in the following ways:
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data:
Part 2 of Schedule 1 sets out the lawful basis we will rely on to process your personal data.
We do generally only rely on consent as a legal basis for processing your personal data to send email and you have the right to withdraw your consent at any time by contacting us. Please note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your information.
We do not share any of your personal information with third parties for marketing purposes. We do not sell lists, accept advertising, or generate any third-party revenue from the information that is generated on this website.
Change of purpose - We will only use your personal data for the purpose that we originally collected it for, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to use your personal data in this manner.
We may process your personal data (without your knowledge or consent) where this is required or permitted by law.
We may have to share your personal data with third parties further details of which are set out in Part 4 of Schedule 1. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes. They can only process your personal data for specified purposes and in accordance with our instructions.
When sharing your data with third parties as specified in Part 4 of Schedule 1, it may be transferred outside the European Economic Area (EEA).
Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
The security of your personal information is important to us. Please bear in mind, however, that no security system is guaranteed to be 100% secure. Whilst we strive to protect your personal information, 1st Formations cannot guarantee or warrant the security of our servers, nor can we guarantee that information you supply through this Website will not be intercepted whilst being transmitted over the Internet. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We also limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know and they can only process your personal data on our instructions and will be subject to a duty of confidentiality.
We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us. However, we are legally required to keep basic information about our customers (including contact, identity, financial and transaction data) for six years after they cease being customers, for tax purposes.
We may also anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes. We can use anonymised information indefinitely without further notice to you.
You have certain rights in certain circumstances under data protection law. These are set out in full in Part 3 of Schedule 1. If you wish to exercise any of your rights, please contact us.
You will not have to pay a fee to exercise any of your rights. However, if your request is clearly unfounded, repetitive or excessive, we may charge a reasonable fee for this information or refuse to comply with your request.
We may request specific information from you to help us confirm your identity when you contact us. This is a security measure to ensure that personal data is not disclosed to any person who does not have the right to receive it.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
The lawful basis upon which we may rely on to process your personal data are:
Set out below are specific details of the processing activities we undertake with your personal data and the lawful basis for doing this.
|Purpose/Activity||Type of data||Lawful basis for processing|
|to register you as a new customer||identity & contact||to perform our contract with you|
|to process and deliver your order, manage payments, fees and charges and debt recovery||identity, contact, financial, transaction and marketing & communications||
|to administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||identity, contact & technical||
|to deliver relevant website content/advertisements to you and measure or understand the effectiveness of our advertising||identity, contact, profile, usage, marketing & communications & technical||as necessary for our legitimate interests in studying how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy|
|to use data analytics to improve our website, products/services, marketing, customer relationships and experiences||technical & usage||as necessary for our legitimate interests to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy|
|to make suggestions and recommendations to you about goods or services that may be of interest to you, including promotional offers||identity, contact, technical, usage & profile||as necessary for our legitimate interests to develop our products/services and grow our business|
You have the following legal rights in relation to your personal data:
you can object to the processing of your personal data where:
In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms and, in such circumstances, we can continue to process your personal data for such purposes
you can ask us to us to suspend or restrict the processing of your personal data, if: