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Introduction

Privacy Statement for Personally Identifiable Information of Neltek.

Updated: May 20th, 2018

In this policy, "we", "us" and "our" refer to Neltek. For more information about us, see Section 1. Neltek (referred to as "we", "us", "Neltek" or "Business") is committed to protecting your privacy and processing your personally identifiable information (referred to as "PII" or "personal data" or "personal information") with transparency. The PII we collect and process depends on the purpose of your visit and the service or services you have purchased or otherwise agreed to receive from us.

This privacy statement for personally indentifiable information:

  • provides an overview of how Neltek collects and processes your personal information and informs you about your rights according to the local laws for the protection of personal information and the European Union's General Data Protection Regulation (GDPR).
  • is addressed to natural persons who are either existing or prospective clients of the Business or are authorized representatives / assignees, or the beneficial owners of legal or natural persons who are existing or potential clients of the Business
  • is addressed to natural persons who had a business relationship of this nature with the Business in the past
  • contains information regarding when your PII will be conveyed to / exchanged with other companies or subcontractors of Neltek and other third parties

For the purposes of this statement, personal information is understood to be any information which is relevant to you, with which your identity is or can be identified and which include, for example, your name, email address, physical address, VAT number, IP address (only when we have collected it in conjunction with directly identifying information) or the information you submit in your private tickets.

We are committed to safeguarding the privacy of our website visitors and service users.

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.

By using our website and agreeing to this policy, you consent to our use of cookies in accordance with the terms of this policy.

 

1. Who are we

This website is owned and operated by Ian Nelson trading as Neltek Website Design.

Our principal place of business is at 12 High House Drive, Inkberrow, Worcestershire. WR7 4EG.

If you have any questions about your use of personal information you can contact us:

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

(b) using our website contact form;

(c) by telephone, on the contact number published on our website ; or

(d) by email, using the email address published on our website.

If you want a copy of your personal information kept on file ("data portability right") or delete the personal information we keep on file for you ("right to be forgotten") please contact us.

2. Which personal information we process and where do we collect it from

We collect personal information of our current and prospective clients through our web site. We never collect information in person, through any other means or using a third party representative.

Invoicing information. In accordance to the local tax laws and the European Union's invoicing directives we collect the following personal information: your name, email address, physical address, company name (if applicable), company activity (if applicable), IP address, country based on your IP address and the User Agent string of the web browser you used when subscribing. This information is used to generate the legally stipulated invoice upon successful payment of your purchase.

IP address. Your IP address is temporarily collected whenever you are accessing our site in our web server's logs and our security software's logs. This information is used to ensure the security of our web site and to prevent abuse. IP address information is not directly identifiable information but if it's stored in conjunction with your user account ID it might be an indirect identifier.

Support ticket information. Any identifiable information you provide when requesting support through our ticket system's private tickets feature including but limited to connection information to your site(s) and any other personally identifiable information you may volunteer. We use that information to provide you with technical and account support and, generally, to answer your questions and address your requests. Please note that when filing a public ticket or when you are providing your ticket system signatureyou have no reasonable expectation of privacy and as such any information volunteered in a public ticket is not subject to our privacy statement.

Contact form information. Any information you volunteer by submitting a contact form through this web site's Contact Us page. We use this information to respond to your requests.

3. Personal Information of minors

We do not allow minors (persons under the age of 13) to use our site. Any accounts found in violation of this term will be terminated without a refund and all information pertaining to that user account will be erased.

4. Whether you are legally obliged to provide us your personal information

Providing your invoicing information is legally required.

Your IP address in the context of security and abuse prevention is specifically exempt from requiring your consent per the European Union's GDPR. We are legally required to ensure the security of your personal information through any appropriate technical means and that includes collecting your IP address in that context.

Any other personal information is volunteered by you in order for us to be able to provide our services to you. You are not legally required to provide it but unless you do we won't be able to provide you the services agreed upon. Simply put, if you don't tell us what the problem is and give us the means to reproduce and troubleshoot it we can't do anything for you except tell you to read our documentation.

As we mentioned already, we process your personal information with transparency and as such we process your personal information per the GDPR and the local data protection laws for one of the following reasons:

5.a. Contractual obligations

We process your personal information to provide the hosting and website and support services we have agreed upon when you subscribed to our services.

When logging in we automatically process your PII to protect you against unauthorized access to your account and ensure your account safety. We also display you parts of your PII for reasons of personalization of our site's pages and ensuring that it's clear who is the currently logged in user.

When you ask for a username reminder or password reset we automatically process your PII to provide the service requested.

When using our support ticket system we process your PII to reply to your request. We also automatically process your PII to send you automated email notifications about the handling of your request.

When using our contact form we process your PII to reply to your request. We also automatically process your PII to send you automated email notifications about the handling of your request.

When you are a subscriber we automatically process your PII send you automated transactional emails, i.e. reminders about your subscription expiration and any changes in your subscription's status with us including domain renewals.

There are certain obligations in accordance to local and international laws, as well as Directives issued by the European Union. These legal obligations require the processing of your personal information. In other cases we may receive a court order or otherwise be legally obliged to process or convey your personal information to third parties.

When you are subscribing we automatically process your PII to issue the legally required invoice and send you automated emails with the invoice and information about your purchase.

5.c. To protect our interests

We process your personal information to protect the legal interests of us and others. A legal interest exists when we have a business or commercial reason to use your information. Even then it must not be against what is fair to you and your best interests. Examples of such processing are as follows:

In case of a suspected abuse or an attempt to compromise, deteriorate, disrupt or otherwise interfere with of our services we may process PII to identify the perpetrator and pursue redress. Such steps may for example (not an inclusive list) include contacting the suspected offender or pursuing the matter legally.

In rare occasions we may send you a personal, manual email to address a concern regarding your subscription e.g. if there is an unexpected problem with your payment as we are notified by the company processing the payment.

In case of a serious security issue in our software where a public announcement is deemed inadequate we may send you an email informing you of the situation, the risks and what you can do.

If you have explicitly provided your consent the processing of your personally identifiable information draws its legality upon your explicit consent. You have the right to withdraw your consent at any time. However, any processing which took place before your consent's withdrawal is not affected.

6. Who are the recipients of your personal information

While fulfilling our contractual or legal obligations your your personally identifiable information may be conveyed to our partners and subcontractors. These providers and suppliers are in contract with Neltek with which they are obliged to uphold the confidentiality and protection of your personal information in accordance to the local data protection laws and the GDPR.

The recipients of your personal information are as follows.

  1. Siteground. Our website is hosted through Siteground in a datacentre in the UK. Any clients where we provide hosting for their website as part of the services we provide, will be hosted by Siteground. Our emails and clients emails are managed through Siteground.
  2. WHMCS. This platform is used to hold your client account, records of services bought from us, quotes, invoices, customer emails, domain management (if bought through us) and support tickets.
  3. ResellerClub. If you register a domain through us, the registrar is ResellerClub. The process the information required to register and renew domains.
  4. Dropbox International Unlimited Company. They are used to hold backups of customers websites where set up as part of the service we provide. This ensures if a customer's website has a problem we can restore from a backup held externally.
  5. PayPal (Europe) S.à r.l. et Cie, S.C.A. 5th Floor, 22-24 Boulevard Royal, Luxembourg, 2449, LUXEMBOURG. They process payment for us. Any PII submitted to them is subject to their own privacy policy. We only convey PII to them for pre-filling the payment form when you explicitly select them as a payment processor and click on they Pay Now button on our site.
  6. Google, Inc. 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Provides analytics for our site, as well as Neltek's emails are managed through Gmail. For analytics purposes only anonymized information is sent to Google. Therefore any email correspondence with customers is held on Google's gmail email servers.
  7. myJoomla.com - Blue Flame Digital Solutions Limited - Calista House, Lewis Street, St Helier, JE2 3PB. No personal data is shared with myJoomla.com, however they do access our and customer websites to perform security monitoring and management of the Joomla! software our website and customers websites are built with.

7. Remittance of your PII to a third party country or international Organization

Your personal information may be conveyed to third countries (countries outside the European Economic Area) in certain cases, e.g. payments made using a non-EEA payments processing company , or whenever this is mandated by law or if you have explicitly consented. All the Processors are obliged to comply and conform to the European Union's data protection norms and provide appropriate assurances regarding the remittance of of your personal information according to Article 46 of the GDPR.

8. To which extent is there automated decision making, including profiling

In general, in the course of the creation and carrying out a business relationship we do not use automated decision making.

In general, we do not perform any kind of automated profiling of our clients and web site visitors. We provide the same service to everybody. In case of an abnormally high number of downloads, support tickets or other signs of potential abuse we may process your PII on file to create a profile of your usual behaviour to determine if there is a potential problem with your account.

9. How we deal with your personal information for marketing purposes and whether we use profiling for such activities

In general, we do not base our marketing activites on the personal information we have collected from our clients. We do not perform personalized marketing and we do not make use of profiling for marketing purposes.

10. How long do we keep your personal information

We retain your personal information for as long as we have a business relationship with you as evidenced by the existence of an active subscription or a log in to your account.

We are legally required to retain your invoicing information for a period of up to SEVEN (7) years after your purchase.

After SIX (6) months after the termination of our business relationship (explicitly: the expiration of your last service date invoiced with us or your last log in to our site, whichever comes later) the following actions will be taken:

  • Your user account will be locked to make logging in impossible.
  • Your private tickets will be permanently removed and you will forever lose access to them. Please note that your public tickets remain intact.
  • Invoicing information will be retained as described above

Other logs which may contain personal infomration such as server access logs and security logs are kept for up to FOURTEEN (14) months.

We may retain your personal information longer than that for regulatory, technical or legal reasons.

Your information may be stored longer than that in encrypted backups. 

11. Your data protection rights

You have the following rights with regards to the personally identifiable information we keep on file for you:

  • Access your personal information. This lets you for example get a copy of the personal data we keep on file for you and confirm that we are processing it legally. You can request a copy of your data through the contact form on our site.
  • Request the correction of the personal inforamtion we keep on you. This allows you to correct incomplete or inaccurate information we keep on file for you. Please note that correcting your invoicing information is only possible to newly issued invoices only. This is a legal requirement.
  • Ask for the deletion of your personal information (a.k.a. "right to be forgotten"). This lets you request that we delete your personal information when there is no real reason for us to process it. This does not include information needed for the above reasons - ongoing contract with us and invoicing.
  • Object to processing your personal information (a.k.a. "right to objection") when we base our processing on protecting our interests bit there is something special in your situation which makes you want to object to the processing for this reason. If you object we will no longer process your personal information unless we can prove pressing legal reasons for the processing which trump your interests, rights and freedoms. Please note that this is largely inapplicable to our business relationship since our processing is done either on a legal basis, your explicit consent or is exempt from the GDPR protections (e.g. keeping an IP log for security reasons).
  • You have the right to object in cases where we process your personal information for reasons of direct marketing. This also includes profiling, to the extent that this is used for direct marketing. This is also inapplicable to our business relationship since we do not engage in direct marketing.
  • Ask the limitation of the processing of your personal information. This allows you to ask us to limit the processing of your personal information, that is to use it only for specific cases, if:
    • they are inaccurate;
    • they have been used illegally but you do not wish us to delete them;
    • they are no longer necessary but you want us to retain them for their use in potential legal demands;
    • you have asked us to stop using your personal information but you are waiting us to confirm if we have legal reasons to use them.
  • Ask for a copy of the personal information pertaining to you in a structured, commonly used and machine readable format, to convey this information to other organizations. You may also request that we directly convey that file to another organization of your choice. This is also known as "data portability right".
  • Withdraw your consent regarding the processing of your personal information at any time. Please note that withdrawal of your consent at any time does not invalidate the legality of the processing based on your consent before that was revoked or withdrawn by you.

To exercise any of your rights we kindly ask you to contact us via support ticket or contact form. Alternatively, or if you have questions about the use of your personal information from us, you can contact us through the Contact Form. Or you can contact our Data Protection Officer directly as explained earlier in this document.

According to the law, we will reply to your requests promptly and within 30 business days. If you have not received a reply from us for over three weeks (21 days) please retry contacting us with alternate means; most likely your request never reached us. Kindly note that we reserve the right to direct you to our site's tools and / or this Privacy Statement if your concern is readily addressed by it. Per the law, we reserve the right to not reply to your requests if they are too often or are otherwise in abuse of the provisions of the law.

Right to file a complaint

If you have exercised some or all of your rights to data protection and you still feel that your concerns about the way we use your personal data have not been addressed satisfactorily by us, you have the right to file a complaint by filling in the Contact Us form on our site. You also have the right to file a complaint with the Office of the Personal Data Protection Commissioner. On the relevant website you will find information on how to file complaints.

12. Changes in this Privacy Statement

We may periodically modify or amend this privacy statement.

When this happens we will change the date on the top of the page and keep a change log at the end of this page. We do not have the technical means to notify our clients about any changes. We recommend that you re-examine this statement periodically so that you are always updated on the way we process and protect your personal information.

13. Cookies Policy

Our site uses small text files, known as Cookies, to enhance your experience and work better.

To learn more about the use of cookies on our site please consult our Cookies Policy. Links to this statement, our Cookies Policy and our Terms of Service can be found at the bottom of every page of our public (meaning: no user logged in yet) site.

NOTICE: The European Union's General Data Protection Regulation 2016/679 is in effect on May 25th 2018. Until then the Laws for Processing Personal Data Information (Protection of the Individual) from 2001 to 2012 are still in effect.

 

Changelog (changes made to this page)

  • April 2018: Initial version
  • May 20th 2018: Rewritten with the wording and sections required by the European Union

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