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Privacy Notice

SLS 360 Ltd is the data controller in respect to all personal data collected on this website.

We are committed to ensuring the privacy of our clients and other website visitors. In this Notice we explain how we hold, process and retain your personal data.

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1. How we use your personal data

 

We are committed to protecting your personal data.

 

We will use your sensitive personal data for the purposes of providing our services to you or if we need to comply with a legal obligation. 

 

We will use your non-sensitive personal data to (i) register you as a new client, (ii) manage payment, (iii) collect and recover monies owed to us (iv) to manage our relationship with you, (v) send you details of our goods and services.

 

Our legal grounds for processing your data are in relation to points (i) to (iv) above are for performance of a contract with you and in relation to (iii) and (v) above, necessary for our legitimate interests to develop our products/services and grow our business and to recover monies owed.

 

We will not share your details with third parties for marketing purposes except with your express consent.

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1.1 This section provides you with information about:

(a) what personal data we hold and process;

(b) in respect of personal data that we did not collect from you directly, where we obtained that data from, and what types of data we have collected;

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

(d) the legal grounds on which we process your data.

 

We will not pass on your information to any third party without your explicit consent.

 

1.2 Contact data / Enquiry data. We may process contact details that you provide to us (“contact data”). This contact data may include your name, company address, telephone number, and email address, and may be provided through our website. We may use this contact data to manage your enquiry or contract with us and to contact you to discuss your use of our website.

The legal basis for this processing your personal information is to fulfil our contractual obligation to you or  our legitimate interest in responding to your enquiries and ensuring the efficient administration and continued function of our website.

 

1.3 Profile Data. If you opt-in to our mailing list, you will receive emails that may include company news, updates, related product or service information. If at any time you wish to unsubscribe from receiving future emails, we include detailed unsubscribe instructions appear at the bottom of each e-mail.

 

1.4 Sensitive Personal Data. During the course of using our services, you may provide us with sensitive information about yourself (“sensitive data”). However, we will only process this sensitive data if you consent to us doing so.

 

1.5 Website data. We may process data about your use of our website and services (“website data”). The website data may include, but is not limited to, 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 website data is our analytics tracking system. This website 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.

 

1.6 Notification data. We may process information that you provide to us for the purpose of subscribing to our newsletters (“notification data”). The notification data may be processed for the purposes of sending you newsletters.

The legal basis for this processing is consent.

 

1.7 Correspondence data. We may process information contained in or relating to any communication that you send to us (“correspondence data”). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping.

 

The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.

 

1.8 Other processing activities. In addition to the specific purposes for which we may process your personal data set out above, 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.

 

1.9 Our partner service providers. In order to deliver our services to the highest possible standard, we may use third party service providers to help us operate our business and our web site or administer activities on our behalf, such as sending out newsletters or surveys. We may share your information with these third parties for those limited purposes provided that you have given us your permission.

 

1.10 Our professional advisers. We may disclose your personal data to our professional advisers insofar as reasonably necessary for the purposes of managing risks, obtaining professional advice and managing legal disputes.

 

1.11 Where we provide your personal data to any third party. Where we share your personal data with any third party, we will ensure this processing is protected by appropriate safeguards including a suitable data processing agreement with that third party.

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1.12 To comply with legal obligations. In addition to the specific disclosures of personal data detailed above, we may also disclose your personal data where such disclosure is necessary for compliance with a legal obligation we have to comply with, or in order to protect your vital interests or the vital interests of another individual.

 

2. Retaining and deleting personal data

 

We will only keep your personal data for as long as is necessary to fulfil the purposes for which we collected it. We may retain your data to satisfy any legal, accounting, or reporting requirements so for example we need to keep certain information about you for 6 years after you cease to be a client for tax purposes.

 

You have the right to ask us to delete the personal data we hold about you in certain circumstances. See section 5 Your Rights for further details.

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2.1 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.

2.2 Unless we contact you and obtain your consent for us to retain your personal data for a longer period, we will retain and delete your personal data as follows:

(a) Contact data will be retained for 3 years following the date of our last contact or dealing with you, at the end of which period it will be deleted from our systems.

(b) Profile data will be retained for 3 years following the date of our last contact or dealing with you, at the end of which period it will be deleted from our systems.

(c) Sensitive data will be retained for 3 years following the date of our last contact or dealing with you, at the end of which period it will be deleted from our systems.

(d) Transaction data will be retained for 3 years following the date of our last contact or dealing with you, at the end of which period it will be deleted from our systems.

(e) Website data will be retained for 3 years following the date of our last contact or dealing with you, at the end of which period it will be deleted from our systems.
(f) Notification data will be retained for 3 years following the date of our last contact or dealing with you, at the end of which period it will be deleted from our systems.

(g) Correspondence data will be retained for 3 years following the date of our last contact or dealing with you, at the end of which period it will be deleted from our systems.

2.3 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.

 

3. How do we store, use, share and disclose our site visitors' personal information?

 

Our company is hosted on the Wix.com platform. Wix.com provides us with the online platform that allows us to sell our products and services to you. Your data may be stored through Wix.com’s data storage, databases and the general Wix.com applications. They store your data on secure servers behind a firewall.  

 

All direct payment gateways offered by Wix.com and used by our company adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of credit card information by our store and its service providers.

 

We may have to share your personal data with (i) service providers who provide IT and system administration support, (ii) professional advisors including lawyers, bankers, auditors and insurers (iii) HMRC and other regulatory authorities and/or (iv) third parties to whom we sell, transfer or merge parts of our business or our assets.

 

We require all of these third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. They are only allowed to process your personal data on our instructions.

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4. How we communicate with site visitors

 

​We may contact you to notify you regarding your account, to troubleshoot problems with your account, to resolve a dispute, to collect fees or monies owed, to poll your opinions through surveys or questionnaires, to send updates about our company, or as otherwise necessary to contact you to enforce our User Agreement, applicable national laws, and any agreement we may have with you. For these purposes we may contact you via email and telephone.

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​5. Your rights

 

Under the GDPR, you have specific rights regarding your personal data, which you may choose to exercise. These are set out in more detail at

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

 

In relation to a Subject Access Right request, you may request that we inform you of the data we hold about you and how we process it. We will not charge a fee for responding to this request unless your request is clearly unfounded, repetitive or excessive in which case we may charge a reasonable fee or decline to respond. 

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For example;

 

5.1 You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to:

(a) your request not being found to be unfounded or excessive, in which case a charge may apply; and

(b) the supply of appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address).

 

5.2 We may withhold personal information that you request to the extent permitted by law.

 

5.3 The rights you have under data protection law are:

(a) the right to access;

(b) the right to rectification;

(c) the right to erasure;

(d) the right to restrict processing;

(e) the right to object to processing;

(f) the right to data portability;

(g) the right to complain to a supervisory authority; and

(h) the right to withdraw consent.                                

 

5.4 Your right to access your data. You have the right to ask us to confirm whether or not we process your personal data and, to have access to the personal data, and any additional information. That additional information includes the purposes for which we process your data, the categories of personal data we hold and the recipients of that personal data. You may request a copy of your personal data, we may charge a reasonable fee for copies.

 

5.5 Your right to rectification. If we hold any inaccurate personal data about you, you have the right to have these inaccuracies rectified. Where necessary for the purposes of the processing, you also have the right to have any incomplete personal data about you completed.

 

5.6 Your right to erasure. In certain circumstances you have the right to have personal data that we hold about you erased. This will be done without undue delay. These circumstances include the following: it is no longer necessary for us to hold those personal data in relation to the purposes for which they were originally collected or otherwise processed; you withdraw your consent to any processing which requires consent; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are certain general exclusions of the right to erasure, including where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for establishing, exercising or defending legal claims.

 

5.7 Your right to restrict processing. In certain circumstances you have the right for the processing of your personal data to be restricted. This is the case where: you do not think that the personal data we hold about you is accurate; your data is being processed unlawfully, but you do not want your data to be erased; it is no longer necessary for us to hold your personal data for the purposes of our processing, but you still require that personal data in relation to a legal claim; and you have objected to processing, and are waiting for that objection to be verified. Where processing has been restricted for one of these reasons, we may continue to store your personal data. However, we will only process it for other reasons: with your consent; in relation to a legal claim; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

 

5.8 Your right to object to processing. You can object to us processing your personal data on grounds relating to your particular situation, but only as far as our legal basis for the processing is that it is necessary for: the performance of a task carried out in the public interest, or in the exercise of any official authority vested in us; or the purposes of our legitimate interests or those of a third party. If you make an objection, we will stop processing your personal information unless we are able to: demonstrate compelling legitimate grounds for the processing, and that these legitimate grounds override your interests, rights and freedoms; or the processing is in relation to a legal claim.

 

5.9 Your right to object to direct marketing. You may instruct us at any time not to process your personal information for marketing purposes.
In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.

You can object to us processing your personal data for direct marketing purposes. If you make an objection, we will stop processing your personal data for this purpose.

 

5.10 Your right to object for statistical purposes. You can object to us processing your personal data for statistical purposes on grounds relating to your particular situation, unless the processing is necessary for performing a task carried out for reasons of public interest.

 

5.11 Automated data processing. To the extent that the legal basis we are relying on for processing your personal data is consent, and where the processing is automated, you are entitled to receive your personal data from us in a structured, commonly used and machine-readable format. However, you may not have this right if it would adversely affect the rights and freedoms of others.

 

5.12 Complaining to a supervisory authority. If you think that our processing of your personal data infringes data protection laws, you can lodge a complaint with a supervisory authority responsible for data protection. You may do this in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.

 

5.13 Right to withdraw consent. To the extent that the legal basis we are relying on for processing your personal data is consent, you are entitled to withdraw that consent at any time by contacting the Data Protection Officer via email at info@sls360.org. Withdrawal will not affect the lawfulness of processing before the withdrawal.

 

5.14 Exercising your rights. You may exercise any of your rights in relation to your personal data by written notice to us in addition to the other methods specified above.

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6. Transfers of your personal data outside of the European Economic Area

 

Some of our third party providers are businesses outside of the EEA in countries which do not always offer the same levels of protection for your personal data. We do our best to ensure a similar degree of security by ensuring that contracts, code of conduct or certification are in place which give your personal data the same protection it has within Europe. If we are not able to do so, we will request your explicit consent to the transfer and you can withdraw this consent at any time.

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Where your personal data is transferred outside of the EEA, we will ensure that either (a) The European Commission has made an “adequacy decision” with respect to the data protection laws of the country to which it is transferred, or (b) we have entered into a suitable data processing agreement with the third party situated in that country to ensure the adequate protection of your data. In all cases, transfers outside of the EEA will be protected by appropriate safeguards.

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7. Data security

 

We have put in place 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 such data. They will only process your personal data on our instructions and are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breaches and will notify you and any applicable regulator where we are legally required to do so.

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In certain circumstances you can ask us to delete your data. See section 5 entitled ‘Your Rights’ above for more information.

 

We may anonymise your personal data (so that you can no longer be identified from such data) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.​

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8. Cookies policy

 

Our website uses cookies – small text files that are placed on your machine to help the site provide a better user experience. For more details, please see our Cookies Policy. For more information generally on cookies, including how to disable them, please refer to www.aboutcookies.org You will also find details on how to delete cookies from your computer.

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9. Our details

 

9.1 The website www.sls360.org is owned and operated by SLS 360 Ltd.

9.2 We are registered in England and Wales under registration number 13893586, and our registered office is at: 

1st Floor, HealthAid House

Marlborough Hill

Harrow, Middlesex

HA1 1UD

United Kingdom

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9.3 You can contact us:

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

(b) using our website contact form;


​10. How we keep your data up to date

 

We have a duty to keep your personal data up to date and accurate so from time to time we will contact you to ask you to confirm that your personal data is still accurate and up to date.

 

If there are any changes to your personal data (such as a change of address) please let us know as soon as possible by writing to or emailing the addresses set out in section 9 above.

 

11. Complaints

 

We are committed to protecting your personal data but if for some reason you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk).

 

We should be grateful if you would contact our Data Protection Officer first if you do have a complaint so that we can try to resolve it for you: info@sls360.org

Implementation date: Dec 2021.

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12. Amendments

 

We may update this notice from time to time by publishing a new version on our website. You should check this page occasionally to ensure you are happy with any changes to this notice. We may notify you of changes to this notice by email.

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