Privacy Policy

We use cookies for certain areas of our website. Cookies are files that store information on your hard drive or browser that means that our website can recognise that you have visited our website before. Cookies make it easier for you to maintain your preferences on the website, and by seeing how you use the website, we can tailor the website around your preferences and measure usability of the website.

As of 26th May 2011, we are required under EU law to tell you what cookies and other local shared objects this site sets.

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We do not currently use Flash/Flash cookies (also known as LSO’s).

The above information is subject to constant review and is liable to change.

We believe that you should not be unduly concerned with the use of cookies on this site. No information obtained from the cookie will be used by us for marketing purposes. We do recognise and understand that you can, should you choose, disable cookies on your browser and delete all cookies currently stored on your computer. This may prevent you from taking full advantage of the website. You can find out how to delete and block cookies for your particular browser by clicking “help” on your browser’s menu or by contacting us or by visiting http://www.allaboutcookies.org/manage-cookies/index.html.

 

1.1 PrimeLife makes no warranty or representation
that this website will meet your requirements, that it will be of satisfactory
quality, that it will be fit for a particular purpose, that it will not
infringe the rights of third parties, that it will be compatible with all
systems, that it will be secure and that all information provided will be
accurate. We make no guarantee of any specific results from the use of this
website.1.1 PrimeLife makes no warranty or representation
that this website will meet your requirements, that it will be of satisfactory
quality, that it will be fit for a particular purpose, that it will not
infringe the rights of third parties, that it will be compatible with all
systems, that it will be secure and that all information provided will be
accurate. We make no guarantee of any specific results from the use of this
website.

1.2 No part of this website is intended to
constitute advice and the content of this website should not be relied upon
when making any decisions or taking any action of any kind.

1.3 No part of this website is intended to
constitute a contractual offer capable of acceptance.  No goods and / or services are sold through this website and
product and / or service details are provided for information purposes only.

1.4 Whilst every effort has been made to ensure that
all graphical representations of products and / or descriptions of services
available from PrimeLife correspond to the actual products and / or services, PrimeLife
is not responsible for any variations from these descriptions.

1.5 PrimeLife does not represent or warrant that
such products and / or services will be available from us or our premises.  For this reason, please contact us
prior to visiting if you wish to enquire as to the availability of any products
and / or services.  Any such
enquiry does not give rise to any express or implied warranty that the products
and / or services forming the subject matter of your enquiry will be available
upon your arrival at our premises.

1.6 All pricing information on the website is
correct at the time of going online. 
PrimeLife reserves the right to change prices and alter or remove any
special offers from time to time and as necessary.  All pricing information is reviewed and updated every PrimeLife.

 

 

1. Introduction

This document sets out the obligations of PrimeLife (“the
Company”) with regard to data protection and the rights of people with whom it
works in respect of their personal data under the Data Protection Act 1998
(“the Act”).

This Policy shall set out procedures which are to be
followed when dealing with personal data. 
The procedures set out herein must be followed by the Company, its
employees, contractors, agents, consultants, partners or other parties working
on behalf of the Company.

The Company views the correct and lawful handling of
personal data as key to its success and dealings with third parties.  The Company shall ensure that it
handles all personal data correctly and lawfully.

 

2. The Data Protection Principles

This Policy aims to ensure compliance with the Act.  The Act sets out eight principles with
which any party handling personal data must comply.  All personal data:

2.1 Must be processed fairly and lawfully (and shall
not be processed unless certain conditions are met);

2.2 Must be obtained only for specified and lawful
purposes and shall not be processed in any manner which is incompatible with
those purposes;

2.3 Must be adequate, relevant and not excessive
with respect to the purposes for which it is processed;

2.4 Must be accurate and, where appropriate, kept
up-to-date;

2.5 Must be kept for no longer than is necessary in
light of the purpose(s) for which it is processed;

2.6 Must be processed in accordance with the rights
of data subjects under the Act;

2.7 Must be protected against unauthorised or
unlawful processing, accidental loss, destruction or damage through appropriate
technical and organisational measures; and

2.8 Must not be transferred to a country or
territory outside of the European Economic Area unless that country or
territory ensures an adequate level of protection for the rights and freedoms
of data subjects in relation to the processing of personal data.

 

3. Rights of Data Subjects

Under the Act, data subjects have the following rights:

  • The right to be informed that their personal
    data is being processed;
  • The right to access any of their personal data
    held by the Company within 40 days of making a request;
  • The right to prevent the processing of their
    personal data in limited circumstances; and
  • The right to rectify, block, erase or destroy
    incorrect personal data.

 

 

4. Personal Data

Personal data is defined by the Act as data which relates
to a living individual who can be identified from that data or from that data
and other information which is in the possession of, or is likely to come into
the possession of, the data controller, and includes any expression of opinion
about the individual and any indication of the intentions of the data
controller or any other person in respect of the individual.

The Act also defines “sensitive personal data” as personal
data relating to the racial or ethnic origin of the data subject; their
political opinions; their religious (or similar) beliefs; trade union
membership; their physical or mental health condition; their sexual life; the
commission or alleged commission by them of any offence; or any proceedings for
any offence committed or alleged to have been committed by them, the disposal
of such proceedings or the sentence of any court in such proceedings.

The Company only holds personal data which is directly
relevant to its dealings with a given data subject.  That data will be held and processed in accordance with the
data protection principles and with this Policy.  The following data may be collected, held and processed by
the Company from time to time:

  • name;
  • date
    of birth;
  • gender;
  • job
    title;
  • profession;
  • contact
    information such as email addresses and telephone numbers;
  • demographic
    information such as post code, preferences and interests;
  • financial
    information such as credit / debit card numbers;
  • IP
    address (automatically collected);
  • web
    browser type and version (automatically collected);
  • operating
    system (automatically collected);
  • a
    list of URLS starting with a referring site, your activity on this Web Site,
    and the site you exit to (automatically collected); and
  • Cookie
    information (see Clause 10 below).

     

5. Processing Personal Data

Any and all personal data collected by the Company
(including that detailed in Section 4 of this Policy) is collected in order to
ensure that the Company can facilitate efficient transactions with third
parties including, but not limited to, its customers, partners, associates and
affiliates and efficiently manage its employees, contractors, agents and
consultants.  Personal data shall
also be used by the Company in meeting any and all relevant obligations imposed
by law.

Personal data may be disclosed within the Company.  Personal data may be passed from one
department to another in accordance with the data protection principles and
this Policy.  Under no
circumstances will personal data be passed to any department or any individual
within the Company that does not reasonably require access to that personal
data with respect to the purpose(s) for which it was collected and is being
processed.

The Company shall ensure that:

  • All personal data collected and processed for
    and on behalf of the Company by any party is collected and processed fairly and
    lawfully;
  • Data subjects are made fully aware of the
    reasons for the collection of personal data and are given details of the
    purpose for which the data will be used;
  • Personal data is only collected to the extent
    that is necessary to fulfil the stated purpose(s);
  • All personal data is accurate at the time of
    collection and kept accurate and up-to-date while it is being held and / or
    processed;
  • No personal data is held for any longer than
    necessary in light of the stated purpose(s);
  • All personal data is held in a safe and secure
    manner, taking all appropriate technical and organisational measures to protect
    the data;
  • All personal data is transferred using secure
    means, electronically or otherwise;
  • No personal data is transferred outside of the
    UK or EEA (as appropriate) without first ensuring that appropriate safeguards
    are in place in the destination country or territory; and
  • All data subjects can exercise their rights set
    out above in Section 3 and more fully in the Act.

 

 

6. Data Protection Procedures

The Company shall ensure that all of its employees,
contractors, agents, consultants, partners or other parties working on behalf
of the Company comply with the following when processing and / or transmitting
personal data:

  • All emails containing personal data must be
    encrypted;
  • Personal data may be transmitted over secure
    networks only – transmission over unsecured networks is not permitted in any
    circumstances;
  • Personal data may not be transmitted over a
    wireless network if there is a wired alternative that is reasonably
    practicable;
  • Personal data contained in the body of an email,
    whether sent or received, should be copied from the body of that email and
    stored securely.  The email itself
    should be deleted.  All temporary
    files associated therewith should also be deleted;
  • Where Personal data is to be sent by facsimile
    transmission the recipient should be informed in advance of the transmission
    and should be waiting by the fax machine to receive the data;
  • Where Personal data is to be transferred in
    hardcopy form it should be passed directly to the recipient.  Using an intermediary is not permitted;
  • All hardcopies of personal data should be stored
    securely in a locked box, drawer, cabinet or similar;
  • All electronic copies of personal data should be
    stored securely using passwords and suitable data encryption, where possible on
    a drive or server which cannot be accessed via the internet; and
  • All passwords used to protect personal data
    should be changed regularly and should not use words or phrases which can be
    easily guessed or otherwise compromised.

 

7. Organisational Measures

The Company shall ensure that the following measures are
taken with respect to the collection, holding and processing of personal data:

  • A designated officer (“the Designated Officer”) within
    the Company shall be appointed with the specific responsibility of overseeing
    data protection and ensuring compliance with the Act.
  • All employees, contractors, agents, consultants,
    partners or other parties working on behalf of the Company are made fully aware
    of both their individual responsibilities and the Company’s responsibilities
    under the Act and shall be furnished with a copy of this Policy.
  • All employees, contractors, agents, consultants,
    partners or other parties working on behalf of the Company handling personal
    data will be appropriately trained to do so.
  • All employees, contractors, agents, consultants,
    partners or other parties working on behalf of the Company handling personal
    data will be appropriately supervised.
  • Methods of collecting, holding and processing
    personal data shall be regularly evaluated and reviewed.
  • The Performance of those employees, contractors,
    agents, consultants, partners or other parties working on behalf of the Company
    handling personal data shall be regularly evaluated and reviewed.
  • All employees, contractors, agents, consultants,
    partners or other parties working on behalf of the Company handling personal
    data will be bound to do so in accordance with the principles of the Act and
    this Policy by contract.  Failure by
    any employee to comply with the principles or this Policy shall constitute a
    disciplinary offence.  Failure by
    any contractor, agent, consultant, partner or other party to comply with the
    principles or this Policy shall constitute a breach of contract.  In all cases, failure to comply with
    the principles or this Policy may also constitute a criminal offence under the
    Act.
  •  All contractors, agents, consultants, partners
    or other parties working on behalf of the Company handling personal data must
    ensure that any and all of their employees who are involved in the processing
    of personal data are held to the same conditions as those relevant employees of
    the Company arising out of this Policy and the Act.
  • Where any contractor, agent, consultant, partner
    or other party working on behalf of the Company handling personal data fails in
    their obligations under this Policy that party shall indemnify and hold
    harmless the Company against any costs, liability, damages, loss, claims or
    proceedings which may arise out of that failure.

 

8. Access by Data Subjects

A data subject may make a subject access request (“SAR”)
at any time to see the information which the Company holds about them.

  • SARs must be made in writing, accompanied by the
    correct fee.
  • The Company currently requires a fee of £10 (the
    statutory maximum) with all SARs. [A
    fee of £2 shall be required for access to a credit file.]
  • Upon receipt of a SAR the Company shall have a maximum period
    of 40 days within which to respond. 
    The following information will be provided to the data subject:
  • Whether or not the Company holds any personal
    data on the data subject;
  • A description of any personal data held on the
    data subject;
  • Details of what that personal data is used for;
  • Details of any third-party organisations that
    personal data is passed to; and
  • Details of any technical terminology or codes.

 

9. Notification to the Information Commissioner’s
Office

As a data controller, the Company is required to notify
the Information Commissioner’s Office that it is processing personal data.  The Company is registered in the
register of data controllers.

Data controllers must renew their notification with the
Information Commissioner’s Office on an annual basis.  Failure to notify constitutes a criminal offence.

Any changes to the register must be notified to the
Information Commissioner’s Office within 28 days of taking place.

The Designated Officer shall be responsible for notifying
and updating the Information Commissioner’s Office.

 

10. Implementation of Policy

This Policy shall be deemed effective as of PrimeLife.  No part of this Policy shall have
retroactive effect and shall thus apply only to matters occurring on or after
this date.
This Policy has been approved & authorised by:

Name:

Jay Hairsine

Position:

Company Secretary

Date:

April 2012