Last updated: 1st October 2019
PT Digital Services Limited trading as Safra London ("Safra London", "us", "we", or "our") operates the https://www.safralondon.com website (the "Service"). This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Service and the choices you have associated with that data.
By using the Service, you agree to the collection and use of information in accordance with this policy.
Our commitment to protecting your privacy is paramount at Safra London. This Policy sets out when and why we collect personal information, how we use it and how we keep it secure. If you have any queries about this Policy please contact us at 20 Leith Road, London, N22 5QA email firstname.lastname@example.org.
Service is the https://www.safralondon.com website and content operated by Safra London
Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession). Non-personal data means data that is in no way personally identifiable.
Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
Cookies are small pieces of data stored on your device (computer or mobile device).
Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed.
Data Processors (or Service Providers)
Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller.
We may use the services of various Service Providers in order to process your data more effectively.
Data Subject (or User)
Data Subject is any living individual who is using our Service and is the subject of Personal Data. This term may also be used interchangeably collectively to refer to a visitor or member.
A visitor is someone who browses our website
A member is someone who has registered with us to uses our services
We will collect several different types of information including personal information from you for various purposes to provide and improve our Service to you. You volunteer this information in a variety of ways including, but not limited to, when you register with us to become a volunteer, sign up to receive our newsletter, make a donation to us or otherwise provide us with personal information.
Types of data collected
While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information may include, but is not limited to:
- Email address
- First name and last name
- Phone number
- Address, State, Province, ZIP/Postal code, City
- Cookies and Usage Data
We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send or by contacting us.
We may also collect information about how the Service is accessed and used (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
We may use and store information about your location if you give us permission to do so (“Location Data”). We use this data to provide features of our Service, to improve and customise our Service.
You can enable or disable location services when you use our Service at any time, through your device settings.
‘Cookies’ are small files saved to your device that track, save and store information which may include an anonymous unique identifier about your interactions and usage of the website. Cookies are useful because they allow a website to recognise a user’s device and to provide you with a tailored experience within this website. You can find more information about cookies at https://ico.org.uk/for-the-public/online/cookies
Tracking technologies also used are beacons, tags, and scripts to collect and track information to improve and analyse our Service.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.
Examples of Cookies we use:
- Session Cookies. We use Session Cookies to operate our Service to link the actions of a user during a browser session. Session cookies expire after a browser session ends. Session cookies are not stores beyond this.
Use of data
Safra London uses the collected data for various purposes:
- To provide and maintain our Service
- To notify you about changes to our Service
- To allow you to participate in interactive features of our Service when you choose to do so
- To provide customer support
- To gather analysis or valuable information so that we can improve our Service
- To monitor the usage of our Service
- To detect, prevent and address technical issues
- To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information
Legal Basis for Processing Personal Data under General Data Protection Regulation (GDPR)
Safra London may process your Personal Data because:
- We need to perform a contract with you
- You have given us permission to do so
- The processing is in our legitimate interests and it’s not overridden by your rights
- To comply with the law
Retention of data
Safra London will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, approximately 50 months, except, when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.
Volunteer data collected through online forms will be held for at least three months from the last date of interaction with Safra London.
Transfer of Data
Your information, including Personal Data, may be transferred to and maintained on computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.
Safra London may also share your data within the Safra London regional network.
If you are located outside United Kingdom and choose to provide information to us, please note that we transfer the data, including Personal Data, to United Kingdom and process it there.
Disclosure of data
We do not sell, trade or otherwise transfer your personal date to outside third parties.
We do reserve the right to release such personal data to provide you with the product or services you have requested within our Safra London network.
Non-personal information may be provided to other parties for marketing, advertising or other Safra London use.
Disclosure for law enforcement
Under certain circumstances, Safra London may be required to disclose your Personal Data to enforce our site policies, protect your rights or the rights of others’ property or safety if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
Safra London may disclose your Personal Data in the good faith belief that such action is necessary to:
- To comply with a legal obligation
- To protect and defend the rights or property of Safra London
- To prevent or investigate possible wrongdoing in connection with the Service
- To protect the personal safety of users of the Service or the public
- To protect against legal liability
Security of data
The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
Your Data Protection Rights Under General Data Protection Regulation (GDPR)
If you are a resident of the European Economic Area (EEA), you have certain data protection rights. Safra London aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.
If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us at email@example.com
In certain circumstances, you have the following data protection rights:
The right to access, update or to delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete. We will do this within 30 days of your request.
The right to object. You have the right to object to our processing of your Personal Data.
The right of restriction. You have the right to request that we restrict the processing of your personal information.
The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
The right to withdraw consent. You also have the right to withdraw your consent at any time where Safra London relied on your consent to process your personal information.
Please note that we may ask you to verify your identity before responding to such requests.
You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).
Consent and communication
We will not contact you for marketing purposes by email or phone unless you have given your prior consent. We will not contact you for marketing purposes by post if you have indicated that you do not wish to be contacted. To change your marketing preferences at any time please contact us at 20 Leith Road, London, N22 5QA, email firstname.lastname@example.org or call 020 7394 2461. Your personal information is kept private and stored securely. You have the right to ask for a copy of the information we hold about you (for which we may charge a small fee) and to have any inaccuracies in your information corrected. Your information will never be shared with a third party.
The data we are given access to by social media services will vary but will always be in line with the Terms of that particular service. We will not be able to access your private messages or photos and it will include only what you specifically send to us.
Safra London’s website may use social sharing buttons which help share web content directly from web pages to the social media platform in question. Users are advised before using such social sharing buttons that they do so at their own discretion and note that the social media platform may track and save your request to share a web page respectively through your social media platform account.
Twitter remarketing service is provided by Twitter Inc.
You can opt-out from Twitter’s interest-based ads by following their instructions: https://support.twitter.com/articles/20170405
Facebook remarketing service is provided by Facebook Inc.
You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/164968693837950
To opt-out from Facebook’s interest-based ads follow these instructions from Facebook: https://www.facebook.com/help/568137493302217
Facebook adheres to the Self-Regulatory Principles for Online Behavioural Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings.
For more information on the privacy practices of Facebook, please visit Facebook’s Data Policy: https://www.facebook.com/privacy/explanation
Google AdWords remarketing service is provided by Google Inc.
You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads
Google also recommends installing the Google Analytics Opt-out Browser Add-on – https://tools.google.com/dlpage/gaoptout – for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.
For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: http://www.google.com/intl/en/policies/privacy/
We may use third-party Service Providers to monitor and analyse the use of our Service.
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: http://www.google.com/intl/en/policies/privacy/
These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
Safra London email marketing campaigns may contain tracking facilities within the actual email. Subscriber activity is tracked and stored in a database for future analysis and evaluation. Such tracked activity may include; the opening of emails, forwarding of emails, the clicking of links within the email content, times, dates and frequency of activity, and other activity. This information is used to refine future email campaigns and supply the user with more relevant content based around their activity.
External Links – Third Party
Our Service may contain links to other sites that are not operated by us.
Although this website only looks to include quality, safe and relevant external links, users are advised to adopt a policy of caution before clicking any external web links mentioned throughout this website or on Safra London’s social media channels.
Safra London cannot guarantee or verify the contents of any externally linked website despite our best efforts. Users should therefore note they click on external links at their own risk and Safra London cannot be held liable for any damages or implications caused by visiting any external links mentioned.
Resources and further information
Data Protection Act 1998
Privacy and Electronic Communications Regulations 2003
Privacy and Electronic Communications Regulations 2003 – The Guide
General Data Protection Regulation