UltimateLG would like to make you aware in this instance your legal rights, so that as you are reading the rest of this notice you are aware of any rights you have under data protection laws in relation to your personal data. If you wish to exercise any of the rights set out above, please contact us or use the details in Section 3.

Under certain circumstances you have the following rights under data protection laws:

1. Request access to your personal data.
2. Request correction of your personal data.
3. Request erasure of your personal data.
4. Object to processing of your personal data.
5. Request restriction of processing your personal data.
6. Request transfer of your personal data.
7. Right to withdraw consent.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights) if the request is legitimate. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances whereby we would have a legal ability to do so. UltimateLG will never refuse any request without first reviewing the request and considering the circumstance.

We may need to request specific information from you (such as a passport) to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

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.

For the purpose of the applicable national data protection legislation and to abide by GDPR requirements, you should be aware that the data controller responsible for your personal data you submit to this webpage is:

TLAM GROUP LIMITED, The Third Floor, Library Building, Sun Street, Tewkesbury, Gloucestershire, GL20 5NX  bearing the company number 11863257.

Our representative for conducting our business and associated activities is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact them using the details set out below:

Contact details

TLAM GROUP LIMITED

The Third Floor, Library Building, Sun Street, Tewkesbury, Gloucestershire, GL20 5NX or

Email rco@tlamtech.co.uk

 

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact rco@tlamtech.co.uk  in the first instance, if we aren’t made aware that something has happened we won’t be able to improve our approach in the future.

This version of the Privacy Notice was first developed on the 03 September 2019, the first approved version comes into effect as soon as it is published on our website.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

There are some websites on the internet that are related to the services, schemes and contracts that UltimateLG either administers or is involved with, we recommend that when visiting these pages, you review the Privacy Policies as some may be determined or have slight variations because of involvement by additional Data Controllers (such as HM Government) or Joint Controllers.

UltimateLG’s website(s) may also include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous or ‘anonymised’ data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as:

• Identity Data includes first name, last name, username or similar identifier, title.
• Contact Dataincludes company address, home address, email address and telephone number.
• Technical Dataincludes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website (such as smart phones, laptops or desktops).
• Usage Dataincludes information about how you use our website, products and services.
• Marketing and Communications Dataincludes your preferences in receiving marketing from us and our third parties and your communication preferences.

Whereby we need to collect personal data from you by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter with you (for example, to provide you with services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

UltimateLG do not, and will not, collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you are approached by someone pertaining to be from UltimateLG, or, if a webpage that appears to be UltimateLG marked asks for Special Categories of data or information relating to criminal convictions and offences, we ask that you contact rco@tlamtech.co.uk in the immediate instance.

We use different methods to collect data from and about you including through the following methods:

Direct interactions. You may give us your personal, business and contact information by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

• Sign up to the UltimateLG platform;
• Request to read our publications;
• Download one of our whitepapers or information packs;
• Request marketing to be sent to you; or
• Provide information via a survey;
• Interact with our Software when inputting information into the textbox
• Booking a meeting with one of our staff.

Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy for further details.

We may also receive personal data about you from various third parties and public sources as set out below:

• Analytics providers such as Google or additional providers of the service based outside the EU;
• If and to the extent, we use advertising networks;
• Smart Booking Plugin that is used to set up meetings with our staff.

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• To contact you in response to an enquiry
• Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal, or regulatory, obligation.
• To gather feedback from you for new blogs and articles
• When you have registered and subscribed to the UltimateLG platform we use this information to give you access to the UltimateLG subscription service or UltimateLG website content, and to communicate with you about your use of UltimateLG, for instance to let you know about any updates or changes to UltimateLG. If you are a business, we may also use this information to send you marketing communications about products or services provided by us or our group companies. If you are a consumer then we will only send you the aforementioned marketing communications if you have ticked the appropriate opt-in boxes that signify informed and granular consent on the website registration form (trust us, we are not in this to spam you).
• We may collect certain statistical information (Technical Data)
  about how you access and use our Site and Software, such as browser version, publications you download, and the pages you access during a session. This information is used in order to help us build a general picture about how people are using our Site and whether we need to update the Site to make the information more easily accessible and to improve your overall User Experience (UX) – we made the UltimateLG for you after all. This information is also used to identify technical or usability problems with the Site. We do not retain this statistical information in a way which identifies you personally, except where you register or subscribe to the website.

More details on the types of lawful basis that we will rely on to process your personal data can be found in Section 10 and definitions can be found in the Glossary of this notice. The ICO also publishes guidance and definitions on all the lawful basis for processing here.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email. You have the right to withdraw consent to marketing at any time by contacting us.

You should be aware of any time you have provided your consent to UltimateLG as we will ensure that it is explicit and requires a positive opt-in (no more pre-ticked boxes).

We retain personal data for as long as is strictly necessary and in keeping with our data retention and data deletion policies. Given the various products, services and software applications offered for and on behalf of our group of companies the data retention policies are individualised to the specific product or service, in this instance UltimateLG. If you are interested in finding out how long, we retain your information then please contact us.  To speed up this process, please use ‘UltimateLG Data Retention Query’ as the email subject header.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

We have set out below, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. 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 data.

To register you as a new customer

Type of data:

1. Identity
2. Contact

Purpose for use:

• Performance of a contract with you

To manage our relationship with you which will include:

1. Notifying you about changes to our terms or privacy policy
2. Asking you to leave a review or take a survey
3. Provide you with updates on your profile about new content

Type of data:

1. Identity (email address, financial billing address)
2. Contact (including name, surname)
3. Profile
4. Marketing
5. Communications Preferences

Purpose for use:

1. Performance of a contract with you
2. Necessary to comply with a legal obligation
3. Necessary for our legitimate interests (to keep our records updated and to study how you use our products/services).
4. We may use your information to invite you to take part in market research, surveys, or promotions where you have consented to us doing so.
5. To respond to any enquiries or complaints we may receive from you, and/or in accordance with our legitimate interests including to investigate any complaints received from you or from others, about our website or our services.

To administer and protect our business and this website

(including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

Type of data:

1. Identity
2. Contact
3. Technical

Purpose for use:

1. Performance of a contract with you
2. Necessary to comply with a legal obligation
3. Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services).
4. To monitor use of our websites, communications and online services and we may use your information to help us check, improve, promote and protect our products, content, services and websites, both online and offline, in accordance with our legitimate interests
5. To comply with applicable law and regulation and for the prevention of fraud.

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

Type of data:

1. Technical
2. Usage

Purpose for use:

• Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services).

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

Promotional Offers from Us; We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.

Third Party Marketing; UltimateLG does not engage in third party advertising and currently has no plan to do so. If you receive marketing from a business that claims to be doing so on the behalf of UltimateLG we request that you contact us in the first instance.

Opt-out; You can ask us to stop sending you marketing messages by contacting us at any time. Please be aware that where you opt out of receiving marketing messages, this will not apply to personal data provided to us as a requirement for continuing to receive our services or continue our business operations with you this will have been provided to us, by you, during a separate ‘transaction’.

Cookies are small files saved to your computer’s hard drive that track, save and store information about your interactions and usage of our website. Cookies allow us to store your preferences to correctly present content, options or functions throughout our website. They also enable us to see information like how many people use our website and what pages they tend to visit.

Overall, cookies help us provide you with a better website by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. If you would like more information about this practice, including how to prevent it, please visit www.aboutcookies.org, www.allaboutcookies.org or optout.networkadvertising.org

 

• For information on the cookies we use then please contact us. To speed up this process, please use ‘UltimateLG List of Cookies Query’ as the email subject header.

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

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 do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law and where there is no confliction with the requirements of the GDPR or Data Protection Legislation.

We may have to share your personal data with the parties set out below for the purposes set out in the table in Section 10 above. This could include:

1. Internal Third Parties
2. External Third Parties
3. Third parties that we may choose to sell, transfer, or merge parts of our business or our assets with. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require, and demand, that all third parties 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 and only permit them to process your personal data for specified purposes and in accordance with our instructions.

UltimateLG does not transfer your personal data outside of the European Economic Area (EEA). Should this situation change then we will always ensure you are made aware prior to the commencement of international transfers. In the event personal data is sent outside of the EEA we will ensure that we safeguard your privacy rights and that such transfers:

• Will only be made to recipients where the European Commission has issued an “adequacy decision” (this is a European Commission decision that confirms a country has adequate safeguards in place for the protection of personal data);
• Carried out under standard data protection contractual clauses that have been approved by the European Commission or by the adoption of EU-US Privacy Shield.

UltimateLG and its parent company has a robust framework of policies and procedures that includes all legal, physical and technical controls involved in an organisation’s information risk management processes.

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. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures 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.

Where we have given you a password which enables you or your employees to access certain restricted parts of our site, you and your employees are responsible for keeping this password confidential. The password should not be shared with anyone, it should be a minimum of 7 characters long and a mix of numbers and characters.

As mentioned at the start of this notice the following will provide useful definitions to help you better understand some of the legal terms associated with data protection and our responsibilities in protecting your data.

LAWFUL BASIS

 

Legitimate Interest; means the interest of our business in conducting and managing our business to enable us to give you the best service and the most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

 

Performance of Contract; means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. Many of our contracts we look after within UltimateLG will fall under this lawful basis for processing and if you are a client, customer or otherwise involved in these activities conducted by UltimateLG we advise you to contact us for further information.

 

Comply with a Legal or Regulatory Obligation; means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

 

THIRD PARTIES

Internal Third Parties; means any internal companies within TLAM GROUP LIMITED who are based within the European Economic Area (EEA) and provide services to TLAM GROUP LIMITED. We should state that none of these third parties will be granted access to any data you submit here in our website.

YOUR LEGAL RIGHTS

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal or regulatory reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object if we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios.

• if you want us to establish the data’s accuracy;
• where our use of the data is unlawful but you do not want us to erase it;
• where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or,
• you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. This would be possible in a situation whereby we are processing your data based upon us gaining your explicit consent. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Subject Access Requests. The General Data Protection Regulation (GDPR) determines how we process personal data (information relating to living people). The regulation means you can ask to access the information we hold about you. These requests are called Subject Access Requests. You have the right to access to your information. It’s free and requests will be processed within one calendar month. UltimateLG processes subject access requests for information held on our system. Follow these three steps to find out what information is held about you:

1. Submit a subject access request to UltimateLG
2. Provide your proof(s) of identity
3. Receive your information You can submit your request either online or by post. It’s quicker and easier to submit a request online, but we know that doesn’t suit everyone.