Privacy Policy - Firescape

Privacy Policy

Section 1 – Identity of the data controller

Firescape Global Limited (also referred to in this policy as “Us”, or “Ourselves”) protect the personal data of clients (also referred to in this policy as “Users”, “You”, or “Your”) in line with the General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679), and adhere to the principles of providing you with clear information as to;

  • What personal data we collect;
  • How we process this data, and the reasoning behind this processing;
  • Your rights as a data subject, including how you can access your personal data or request for your data to be deleted;
  • How your data is stored and kept secure;
  • Details regarding our cookies policy, and;
  • Details of how you can contact ourselves in the case of any enquiries.

The data controller is Firescape Global Ltd, registered at 1 Sopwith Crescent, Wickford, Essex, England, SS11 8YU (Company number: 09786885). In the event of any query regarding this privacy policy, you can contact our Data Protection Officer emailing with “FAO: The Data Protection Officer” in the subject line.

Section 2 – Your obligations, and the right to withdraw consent

By agreeing to this Privacy Policy, you confirm that you agree with its contents. Agreeing with this privacy policy is a prerequisite of entering any kind of association with Firescape and before volunteering any personal data to Ourselves. If you disagree with any section of this Privacy Policy, you should not attempt to use our services.

If at any time you wish to withdraw your consent for us to process your data in the manner explained in this Privacy Policy, please notify the Data Protection Officer through the process outlined in Section 1. The Data Protection Officer will action your request for no further processing to take place, but please be advised that some data may be retained if there is a legal basis for doing so, and that withdrawal of consent will not have any effect on the lawfulness of any processing completed with your consent prior to the withdrawal of that consent.

Section 3 – Personal data which we collect from You

In the course of your relationship with Firescape, we acquire and securely store the following details;

  • First Name
  • Surname
  • Email Address
  • Address(es)
  • History of products purchased through Firescape, and records of financial transactions which have taken place in the fulfilment of those purchases.

We collect these details for the purposes of fulfilling our services to you in the best fashion, and of providing a record of financial transactions in accordance with regulatory requirements (see Section 7).

Section 4 – How do we obtain your personal data?

The personal data which we collect and store is volunteered from you to us, with the exception of any contact details which you have chosen to make publicly accessible (for example, through publishing your name and telephone number, email address etc… etc…) on your website or on a business card which we may use in the event of any potential introductory contact between You and Us (for example, Firescape calling or emailing you without your prior consent to discuss a potential business deal).

Section 5 – How and why we process your personal data

We process your personal data in the following fashions;

  • To perform essential operations in the fulfilment of any contract or sales agreement between You and Us.
  • To retain a record of financial transactions with You.
  • For the purpose of marketing communications, if you have opted-in to receiving such communications.
  • Correspondence with clients through our customer services team will be evaluated for quality by Firescape, for the purpose of monitoring compliance with this privacy notice, and for determining staff training and system requirements.
  • To notify you of any changes to our service or any agreement between You and Us through the contact details provided.

We undertake all of the above processes as a legitimate business interest for the purpose of operating our service to clients.  We also process your personal data in order to comply with any applicable statutory provision which regulates our service which we provide to you.

Section 6 – Personal data which we share with others

We only share customers personal data with external partners who have a Privacy Policy which would comply with the General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679), and adhere to the principles, however users are reminded that each of these clients will have a Privacy Policy which will differ slightly from Ours, and that users should familiarise themselves with the Privacy Policy of any clients to whom their details are referred.

These external partners are ActiveWin Media (for the provision of customer support services and marketing to customers who have opted-in to receiving marketing communications), and Belmonte Insurance Services, for the provision of any unique insurance service(s) from Belmonte Insurance which may have been agreed at the point of sale of a customer entering a purchase agreement with Firescape. Any transfers to these external parties are completed through secure file transfer protocols which are in full compliance with the previously stated GDPR requirements.

No data transfers take place to any recipients whom are outside of the EEA, or are not currently recognised by European Union statute as having an adequate level of legal protection for the rights and freedoms of data subjects.

We would be required to share your personal data with authorities in the event of any applicable legal requirement, such as fraud/crime prevention, or co-operating with regulatory authorities such as HMRC or the Information Commissioners Office.

In the event of a sale, merger, transfer of assets, entering receivership, or liquidation, Firescape may need to transfer your information to a third party. This will be communicated to you in the event, and you will be able to withdraw consent for future processing and request deletion of data in line with your rights as a data subject.

Section 7 – Deletion timeframes, and your right to deletion

Firescape will delete (or anonymise, where appropriate) all personal data which we hold about you once a period of twelve months from the date of our last contact or transaction with You has elapsed.

There is an exception to the above timeframe for the records of financial transactions, which will be retained for 6 years from the end of the financial year where the transaction took place, in order to comply with the Companies Act (2006).

If you wish for your data to be deleted at any point sooner than these stated time-frames, please contact the Data Protection Officer through the process outlined in Section 1. The Data Protection Officer will review what personal data we hold about you, and delete the data if it is possible to do so. If there is a legal basis for retaining the data, you will be contacted by the Data Protection Officer within one calendar month confirming the legal reasoning as to why the data has not been removed.

Section 8 – Your rights as a data subject

On request, Firescape will inform you as to what (if any) personal data We hold regarding You. In accordance with the Data Protection Act (2018) and subsequent amendments and associated legislation as defined in the Act. You have the right to access the information which we hold about you as well as details of how we process this data through the submission of a Subject Access Request (SAR). In order to submit an SAR, please contact the Data Protection Officer through the process outlined in Section 1 of this Privacy Policy, and include your full name, address, contact telephone number, and specifics of any exact data which you wish to request.

Requested information will be provided within one calendar month from the SAR being received by Firescape. If for any reason Firescape can not meet this deadline (for example, if the requests made are numerous and complex), you will be informed of this within the initial one month window, with an explanation as to why the data has not yet been provided, along with a firm estimation of when the data will be collated and prepared for sending to you.

No charge is applied to an SAR, however in the event of requests being manifestly unfounded, excessive, or repetitive in nature, Firescape may charge a reasonable fee to complete the SAR. This fee will be based purely on the administrative costs incurred in providing the requested information, and will never exceed £10.

If you are in any way dissatisfied with how Firescape has handled your personal data, and are dissatisfied with your response from ourselves after raising an SAR or any other concern with ourselves through, you have the right to make a complaint to the Information Commissioners Office (ICO), with whom we comply in any enquiry or investigation which they may make.

Section 9 – Automated decision making and profiling

Firescape do not use any automated systems in order to make decisions, nor complete any profiling, which would have any legal effect on the user. The only profiling techniques used are in the segmentation of the client database in order for the creation of marketing lists for marketing communications to opted-in customers.

Section 10 – How we store and protect your data

The personal data which you submit to Firescape is stored on a secure server, based in the United Kingdom, and in compliance with the standard outlined in the information security standards of ISO/IEC 27001. This service is provided by XXXXXX

All Firescape employees are also trained in good practice in regards to data protection, in order to minimise risk of accidental data loss, or the risk of unwittingly granting unauthorised access. For details of the layers of protection used when transferring data externally to approved third parties, please refer to Section 6 of this privacy policy.

Section 11 – Cookie Policy

When you visit our website, we use small text files (“cookies”) to increase the performance of the website, offer a more personalised service to you, and analyse user behaviour for the sole purpose of improving website functionality. The cookies which we use on our site fulfil the following purposes;

  • Allowing visitors to use certain functions of the website and set preferences.
  • To improve user experience and increase functionality (for example, to stop users from being shown the same message on more than one occasion)
  • To monitor and collect information about user behaviour on the website, for the purpose of analysis and tracking.

We also use Google Analytics cookies in order to track and report on website traffic.

Please be aware that if you follow any links through the Firescape website onto a third-party website, these websites will have their own cookie policy which will govern any information you may later submit.

We do not use cookies to gather any personal information about you.

Using our site will constitute acceptance of our cookie policy. If you wish to delete any cookies already stored on your device, or stop cookies that keep track of your browsing patterns on the website, you can do so by deleting your existing cookies or by altering your browser’s privacy settings.

Section 12 – Status of this privacy policy, and changes to this privacy policy

This Privacy Policy is kept under continued review by Firescape, and can be amended by Firescape at any time, and without notice to you. Whenever a change is made to the privacy policy which will affect your rights as a data subject, or change the intended processing purposes, then you will be notified directly and asked to agree to the new privacy policy. If you disagree with the changes made to the privacy policy, you retain the right to withdraw consent for future processing (see Section 2 of this policy).

This version of the Privacy Policy is effective as of December 6th 2018.