Privacy and Cookies Policy
1. Introduction
1.1 Excelerator Ltd t/a Write For Results is committed to safeguarding the privacy of our website visitors and service users.
1.2 This policy applies where we are acting as a data controller for the personal data of our website visitors and service users; in other words, where we determine the purposes and means of processing that personal data.
1.3 By using our website and agreeing to this policy, you consent to our use of cookies in accordance with the terms of this policy.
1.4 In this policy, “we”, “us” and “our” refer to Excelerator Ltd t/a Write For Results. For more information about us, see Section 10.
2. How we use your personal data
2.1 In this Section we set out:
(a) the general categories of personal data that we may process;
(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
(c) the purposes for which we may process personal data; and
(d) the legal bases of the processing.
2.2 We may process data on how you use our website and services (“usage data“). The usage data may include 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 usage data is Google Analytics. This usage data may be processed to analyse the use of the website and services. The legal basis for this processing is to monitor and improve our website and services.
2.3 We may process information contained in any enquiry you submit to us about goods and/or services (“enquiry data”). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is consent OR legitimate interest.
2.4 We may process information that you give us to subscribe to our email notifications and/or newsletters (“notification data”). The notification data may be processed to send you the relevant notifications and/or newsletters. The legal basis for this processing is consent OR legitimate interest.
2.5 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 to communicate with you and keep records. The legal basis for this processing is our legitimate interest, namely the proper administration of our website and business and communications with users.
2.6 We may process your account data (“account data”). The account data may include your name, work address, telephone number and email address. The source of the account data is you, your colleague or your employer. The account data may be processed to operate our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is consent OR our legitimate interest, namely the proper administration of our website and business OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
2.7 We may process information on our customer relationships, including customer contact information (“customer relationship data“). The customer relationship data may include your name, your employer, your job title or role, your contact details, and information contained in communications between us and you, a colleague or your employer. The source of the customer relationship data is you, a colleague or your employer. The customer relationship data may be processed to manage our relationships and communicate with customers, keep records of those communications and promote our products and services to customers. The legal basis for this processing is consent OR our legitimate interest, namely the proper management of our customer relationships.
2.8 We may process any of your personal data identified in this policy where necessary to establish, exercise or defend legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely to protect and assert our legal rights, your legal rights and the legal rights of others.
2.9 We may process any of your personal data identified in this policy where necessary to obtain or maintain insurance coverage, manage risks, or get professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
2.10 In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary to comply with a legal obligation to which we are subject, or to protect your vital interests or the vital interests of another natural person.
2.11 Please do not supply any other person’s personal data to us, unless we prompt you to do so.
3. Providing your personal data to others
3.1 We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.
3.2 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
3.3 In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data where such disclosure is necessary to comply with a legal obligation to which we are subject, or to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary to establish, exercise or defend legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
4. Retaining and deleting personal data
4.1 This Section sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations around retaining and deleting personal data.
4.2 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.
4.3 In some cases it is not possible for us to specify in advance how long your personal data will be kept. In such cases, we will determine the period of retention based on the following criteria:
(a) the period of retention of personal data will be determined based on: legal requirements, reasonable business practices and practical considerations.
4.4 Notwithstanding the other provisions of this Section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or to protect your vital interests or the vital interests of another natural person.
5. Amendments
5.1 We may update this policy from time to time by publishing a new version on our website.
5.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
5.3 We may notify you of changes to this policy by email.
6. Your rights
6.1 In this Section, we have summarised your rights under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
6.2 Your principal rights 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.
6.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Provided the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be free of charge, but additional copies may be subject to a reasonable fee.
6.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
6.5 In some circumstances you have the right to have your personal data erased without undue delay. Those circumstances include: the personal data are no longer necessary for the reason they were initially collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: to exercise the right of freedom of expression and information; to comply with a legal obligation; or to establish, exercise or defend legal claims.
6.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
6.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary: to perform a task carried out in the public interest or in the exercise of any official authority vested in us; or for legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is to establish, exercise or defend legal claims.
6.8 You have the right to object to our processing of your personal data for direct marketing (including profiling for direct marketing). If you make such an objection, we will cease to process your personal data for this purpose.
6.9 To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) legitimate interest: or
(c) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request before entering into a contract,
and such processing is automated, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
6.10 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
6.11 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
7. About cookies
7.1 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.
7.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
7.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
8. Cookies that we use
8.1 We use cookies for the following:
Google Analytics: used to track number of visits, and the time of the visit and keeps track of returning visits. No personal information is stored in the cookie.
Twitter: a collection of cookies set by Twitter. The cookies help to display tweets on the site, monitor referral links, used to identify those logged into Twitter and collect data related to the Twitter platform.
8.2. Cookies used by our service providers
8.3 Our service providers use cookies and those cookies may be stored on your computer when you visit our website.
8.4 We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use through 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/.[ The relevant cookies are: _ga, _gat, _gid]
8.5 We use Twitter to display tweets on our website. Twitter’s privacy policy is available at: https://twitter.com/en/privacy . [The relevant cookies are: ct0, eu_cn, external_referer, guest_id, personalization_id, tfw_exp]
9. Managing cookies
9.1 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. You can however obtain up-to-date information about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);
(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
(c) http://www.opera.com/help/tutorials/security/cookies/ (Opera);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(e) https://support.apple.com/kb/PH21411 (Safari); and
(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
9.2 Blocking all cookies will have a negative impact upon the usability of many websites.
10. Our details
10.1 This website is owned and operated by Excelerator Ltd t/a Write For Results.
10.2 We are registered in England and Wales under registration number 04484772 and our registered office is at 19 Parkthorne Road, London, United Kingdom, SW12 0JN.
10.3 Our principal place of business is at Excelerator Ltd, 19 Parkthorne Road, London, United Kingdom, SW12 0JN.
10.4 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 from 9am – 5pm; or
(d) by email, using the email address published on our website;
11. Data protection officer
11.1 Our data protection officer’s contact details are: Scott Keyser, 19 Parkthorne Road, London, United Kingdom, SW12 0JN.