myFacet5 Privacy & Cookies Policy

1. Introduction

1.1 Facet5 are committed to safeguarding the privacy of our website visitors and service users; in this policy we explain how we will handle your personal data.

1.2 Our website incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can specify whether you would like to receive direct marketing communications and limit the publication of your information. You can access the privacy controls via Account Settings and Sharing from the main menu.

1.3 We have therefore developed this privacy policy to inform you of the data we collect, what we do with your information, what we do to keep it secure as well as the rights and choices you have over your personal information.

1.4 Throughout this document we refer to Data Protection Legislation which means the Data Protection Act 2018 which incorporates the UK and EU General Data Protection Regulation (GDPR), the Privacy and Electronic Communications (EC Directive) Regulations 2003 and any legislation implemented in connection with the General Data Protection Regulation which is the governing legislation that regulates data protection across the European Economic Area (EEA). This includes any replacement legislation coming into effect from time to time.

1.5 We are registered with the Information Commissioner’s Office (the ICO) with registration number ZA065026

1.6 You can contact us via:

a) Our main postal address: Facet5 Ltd Mill Yard Offices Childerley Estates St Neots Road Dry Drayton Cambridgeshire CB23 8BA

b) Phone:+44 (0)1954 602460

c) Email: support@facet5global.com

d) Our Data Protection Officer is: The Business Operations Manager

e) Our EU Representative Data Protection Officer is: The DPO Centre Ltd. Alexandra House, Ballsbridge Business Park, Ballsbridge Park, Merrion Road, Dublin DO4 C7H2 Phone: +353 1 631 9460 email: eurep@facet5global.com

1.7 The hosting facilities for our websites are situated in the Republic of Ireland (EU).

2 How we use your personal data

2.1 We only collect personal information that we know we will genuinely use and in accordance with the Data Protection Legislation. The type of personal information that we will collect on you, and you voluntarily provide to us on this website, form or service may include some or all of the following: your name; Email address; Survey responses & IP address

You are under no statutory or contractual requirement or obligation to provide us with your personal information; however we require at least the information above in order for us to deal with you as a prospective client, client or user of Facet5 services, in an efficient and effective manner.

The legal basis for processing your data is based on your legitimate interest that we will have requested at the point the information was initially provided, therefore we will not store, process or transfer your data unless we have an appropriate lawful reason to do so.

2.2 We may use your data to: contact you following your enquiry; reply to any questions; suggestions, issues, or complaints you have contacted us about; make available our products and services to you; process your orders; take payment from you or give you a refund; personalise your Facet5 experience, for example we may provide you with details of products that match a product, which you may have purchased or enquired about previously; review statistical analysis and to get feedback from you about our products, websites, and other services and activities. For example, occasionally we may invite you to review a product or service you've bought or used from us. If we do, it's possible that we'll use independent research and feedback providers to act on our behalf; power our security measures and services so you can safely access our website; help us understand more about you as a customer, the products, and services you have purchased, so we can serve you better; contact you about products and services from us; provide you with online advertising and promotions; and help answer your questions and solve any issues you have.

3 Providing your personal data to others

We may share your personal data with other organisations in the following circumstances: If the law or a public authority says we must share the personal data; If we need to share personal data in order to establish, exercise or defend our legal rights (this includes providing personal data to others for the purposes of preventing fraud and reducing credit risk); or From time to time, employ the services of other parties for dealing with certain processes necessary for the operation of the Website. However, all the information we share will be collected and anonymised, so neither you nor any of your devices can be identified from it. We will not share your information with any third parties for the purposes of direct marketing.

We use data processors who are third parties who provide elements of services for us. We have Data Processor Agreements in place with our data processors. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will not share your personal information with any organisation apart from us. They will hold your personal data securely and retain it for the period we instruct.

4 How we keep you updated on our products and services

We will send you relevant offers and news about our products and services in a number of ways including by email, but only if you have previously consented to receive these marketing communications. When you register with Facet5 we will ask if you would like to receive marketing communications, and you can change your marketing choices online, over the phone or in writing at any time.

If you wish to amend your marketing preferences, you can do so by updating your preferences on our website or via email to datasecurity@facet5global.com

5 Your rights over your information

5.1 The right to be informed about our collection and use of personal data;

You have the right to be informed about the collection and use of your personal data. We ensure we do this with our internal data protection policies and through our external website policy. These are regularly reviewed and updated to ensure these are accurate and reflect our data processing activities.

5.2 Right to Access Your Personal Information

You have the right to access the personal information that we hold about you in many circumstances, by making a request. This is sometimes termed ‘Subject Access Request’. If we agree that we are obliged to provide personal information to you (or someone else on your behalf), we will provide it to you or them free of charge and aim to do so within 1 month from when your identity has been confirmed. We would ask for proof of identity and sufficient information about your interactions with us that we can locate your personal information. If you would like to exercise this right, please contact us as set out in section 1.6.

5.3 Right to Correction Your Personal Information

If any of the personal information we hold about you is inaccurate, incomplete, or out of date, you may ask us to correct it. If you would like to exercise this right, please contact us as set out in section 1.6.

5.4 Right to Stop or Limit Our Processing of Your Data

You have the right to object to us processing your personal information for particular purposes, to have your information deleted if we are keeping it too long or have its processing restricted in certain circumstances. If you would like to exercise this right, please contact us as set out in section 1.6.

5.5 Right to Erasure

You have the right to have personal data erased. This is also known as the ‘right to be forgotten’. The right is not absolute and only applies in certain circumstances. If you would like to exercise this right, please contact us as set out in section 1.6.

5.6 Right to Portability

The right to portability gives you the right to receive personal data you have provided to a controller in a structured, commonly used, and machine-readable format. It also gives them you the right to request that a controller transmits this data directly to another controller. If you would like to exercise this right, please contact us as set out in section 1.6.

5.7 For more information about your privacy rights

The Information Commissioner's Office (ICO) regulates data protection and privacy matters in the UK. They make a lot of information accessible to consumers on their website and they ensure that the registered details of all data controllers such as ourselves are available publicly. You can access them here https://ico.org.uk/for-the-public.

6 Retaining personal data

We retain a record of your personal information in order to provide you with a high quality and consistent service. We will always retain your personal information in accordance with the Data Protection Legislation. Unless otherwise required by law, your data will be stored indefinitely unless your right to erasure is executed, at which point it will be deleted.

7 Third party websites and social media

7.1 Our website includes hyperlinks to, and details of, third party websites or social media links.

7.2 We have no control over, and are not responsible for, the privacy policies and practices of third parties.

8 Giving your reviews and sharing your thoughts

When using our websites, you may be able to share information through social networks like Facebook and Twitter. For example, when you ‘like’, ‘share’ or review our Services. When doing this, your personal information may be visible to the providers of those social networks and/or their other users. Please remember it is your responsibility to set appropriate privacy settings on your social network accounts, so you are comfortable with how your information is used and shared on them.

9 Personal data of children

9.1 Our website and services are targeted at persons over the age of 18.

9.2 If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.

10 Updating information

Please let us know if the personal information that we hold about you needs to be corrected or updated.

11 Security

Data security is of great importance to Facet5 and to protect your data we have put in place suitable physical, electronic, and managerial procedures to safeguard and secure your collected data. We take security measures to protect your information including: Limiting access to our buildings to those that we have determined are entitled to be there by use of electronic access; Implementing access controls to our information technology; We use appropriate procedures and technical security measures (including strict encryption, anonymisation and archiving techniques) to safeguard your information across all our computer systems, networks, websites, and offices; Never asking you for your passwords;

12 What happens if our business changes hands?

Should Facet5 sell and/or the transfer control of all or part of our business, any personal data that you have provided will, where it is relevant to any part of our business that is being transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use that data only for the purposes for which it was originally collected by us.

13 Changes to our privacy policy

We may change this Privacy Policy from time to time (for example, if the law changes). We recommend that you check this policy regularly to keep up to date.

14 Cookies

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. You can set your cookie preference when you first visit our site based on your own preferences. A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

We use the following cookies:

Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.

Strictly necessary cookies we use to identify you when you visit our website and as you navigate our website. Authentication: AspNet.ApplicationCookie, __RequestVerificationToken & ASP.NET_SessionId; viewed_cookie_policy (used to store whether or not user has consented to the use of cookies. It does not store any personal data); cookielawinfo-checkbox-necessary (The purpose of this cookie is to check whether or not the user has given the consent to the usage of cookies); cookielawinfo-checkbox-non-necessary (The purpose of this cookie is to check whether or not the user has given their consent to the usage of cookies under the category 'Non-Necessary') Memberships Authentication: __hs_preview_auth (Authentication of membership to allow access)

Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.

Analytical/performance cookies used are: Analysis- .AspNet.ApplicationCookie, __RequestVerificationToken & ASP.NET_SessionId) (we use cookies to help us to analyse the use and performance of our website and services); _ga (This cookie is set by Google Analytics used to distinguish users); _gid (Google Analytics. The cookie is used to store information of how visitors use a website and helps in creating an analytics report of how the website is doing. The data collected including the number visitors, the source where they have come from, and the pages visited in an anonymous form.); _gat_gtag_UA_149585792_1 (Google uses this cookie to distinguish users.) Twitter - personalization_id (This cookie is set by Twitter. The cookie allows the visitor to share content from the website on his/her Twitter profile.)

Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

Functionality cookies used are: Security- .AspNet.ApplicationCookie, __RequestVerificationToken & ASP.NET_SessionId (we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally); _gat_UA-149585792-1 (contains the unique identity number of the account or website it relates to.). Language - lang (This cookie is used to store the language preferences of a user) Analysis: _gat (To manage the request rate to limit the collection of data on high traffic sites.). Authentication - hubspotauthremember (Authorization to manage data). Hotjar - _hjClosedSurveyInvites (Hotjar cookie that is set once a visitor interacts with an External Link Survey invitation modal. It is used to ensure that the same invite does not reappear if it has already been shown.)

Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

Targeting cookies used are: status - .AspNet.ApplicationCookie, __RequestVerificationToken & ASP.NET_SessionId (we use cookies to help us to determine if you are logged into our website). Facebook - _fbp (Used by Facebook to deliver a series of advertisement products such as real time bidding from third party advertisers.)

We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google's privacy policy is available at: https://www.google.com/policies/privacy/.

15 Managing cookies

Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version.

Blocking all cookies will have a negative impact upon the usability of many websites

If you block cookies, you will not be able to use all the features on our website.

16 Our details

This website is owned and operated by Facet5 Ltd.

We are registered in England and Wales under registration number 08659593, and our registered office is at Facet5 Ltd, 29 Harbour Exchange Square, London, E14 9GE.