Privacy policy for our clients’ data

Privacy Policy – GDPR and our Clients Data

This policy (together with our Terms and Conditions and any other documents referred to on it) sets out the basis on which any personal information we collect and process on behalf of our clients, or that our clients provide to us, will be processed by us.

This includes our practices regarding personal information and how we will treat it, including what type of information is collected and tracked on our client’s websites (referred to as ‘the website’), how the information is used, and with whom the information is shared.

What we collect and process
On behalf of our clients we may collect two types of information from via the clients website:


1)  “Semi-Personal Information” (SPII) – Encrypted IP address, and Outward Postcode (the first half of the postcode) or Zipcode. We term this as semi-personal as it is not possible to directly identify someone with this information unlike as is the case with ‘personally identifiable information’ (PII). However, governmental or ISP organisations would have the ability to reverse engineer these SPII data points to PII should they be willing.


 2)  Anonymous Non-Personally Identifiable Information (such as information about how many users log on to the website). The personal information we may collect and process on behalf of our clients includes:

  • Anonymised details of user’s visits to the website including, but not limited to, traffic data, location data, weblogs, whether this is required for the clients’ billing purposes or otherwise and the resources that users’ access;
  • If users’ contact our clients via the website, we may keep a record of that correspondence
  • Anonymised details of any transactions users’ carry out through the website and of the fulfilment of orders


How the information collected will be used

The information we collect and process on behalf of our clients, via the website, will be used to

– To enable the client to provide users with information, products or services that the user may request from the client, or which the client feels may be of interest to the user, where the user has given consent to be contacted for such purposes in accordance to our clients privacy policy and terms and conditions.

– To enable the client to provide users a personalised version of the website and carry out transactions and have access to information about their account

– For the client’s marketing purposes and statistical analysis as per the client’s privacy policy and terms and conditions

Use of cookies

Cookies are used to anonymously identify users’ when they visit the website, to keep track anonymously of users’ browsing patterns and build up an anonymous profile of the client’s customers.



We will only disclose data to other companies within our group/ our client’s group of companies and their affiliates, as needed for reasonable management, analysis, planning and decision making; business partners; government bodies and law enforcement agencies; successors in title to our business and suppliers we engage to help us process data on our clients’ behalf.


International processing and transfers
To enable us to collect and process personal data on behalf of our clients’ means the data we collect may be processed outside of the European Economic Area. All data will always be held securely and in accordance with UK data protection legislation. By using our products and services you acknowledge and agree to our processing of personal data in this way.


March 2018 – This privacy policy was updated in accordance with, and complying to, the General Date Protection Regulation (May 2018).