Privacy Policy for Website Users

The Data Controller in respect of our website is Courtel Communications Ltd (company registration number: 3725998) of 9 High Street, Egham, Surrey TW20 9EA.

Courtel Communications Ltd is registered as a Data Controller with the Information Commissioner's Office (ICO) - Registration number: Z772260X.

You can contact the Data Controller by writing to the above address or sending an email to:
admin@courtel.co.uk

If you have any questions about this Privacy Policy, please contact the Data Controller.

We use a server to host our website. Our website server automatically logs the IP address you use to access our website as well as other information about your visit such as the pages accessed, information requested and the date and time of the request.

Our servers are located in the United Kingdom.

Use of website server log information for IT security purposes

We collect and store server logs to ensure network and IT security and so that the server and website remain uncompromised. This includes analysing log files to help identify and prevent unauthorised access to our network, the distribution of malicious code, denial of services attacks and other cyber-attacks, by detecting unusual or suspicious activity.

Unless we are investigating suspicious or potential criminal activity, we do not make, nor do we allow our hosting provider to make, any attempt to identify you from the information collected via server logs.

• Legal basis for processing: compliance with a legal obligation to which we are subject (Article 6(1)(c) of the General Data Protection Regulation).
• Legal obligation: responding to enquiries and messages we receive and keeping records of correspondence.


• Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
• Legitimate interests: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).

Use of website server log information to analyse website use and improve our website

We use the information collected by our website server logs to analyse how our website users interact with our website and its features. For example, we analyse the number of visits and unique visitors we receive and the time and date of the visit.

We use the information gathered from the analysis of this information to improve our website. For example, we use the information gathered to change the information, content and structure of our website and individual pages based according to what users are engaging most with and the duration of time spent on particular pages on our website.

• Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
• Legitimate interest: improving our website for our website users and getting to know our website users'

Cookies are data files which are sent from a website to a browser to record information about users for various purposes.

We use cookies on our website, including essential, functional and analytical cookies. For further information on how we use cookies, please see our Cookies Policy.

You can reject some or all of the cookies we use on or via our website by changing your browser settings, but doing so can impair your ability to use our website or some or all of its features. For further information about cookies, including how to change your browser settings, please visit www.allaboutcookies.org or see our Cookies Policy.

When you send an email to the email address displayed on our website we collect your email address and any other information you provide in that email (such as your name, telephone number and the information contained in any signature block in your email).

• Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
• Legitimate interests: responding to enquiries and messages we receive and keeping records of correspondence.


• Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
• Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).

Transfer and storage of your information

We use a third party email provider to store emails you send us. Our third party email provider is Microsoft. Their privacy policy is available here: https://privacy.microsoft.com/en-gb/privacystatement

Emails you send us will be stored within the European Economic Area on our third party email provider's servers.

When you contact us using our contact form, we collect the following information: your name, email address and any information you include in the message field. We also collect your company name if you provide it.

If you do not provide the mandatory information required by our contact form, you will not be able to submit the contact form and we will not receive your enquiry.

• Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
• Legitimate interests: responding to enquiries and messages we receive and keeping records of correspondence.


• Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
• Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).

Transfer and storage of your information

Messages you send us via our contact form will be stored within the European Economic Area on our third party email provider's servers. Our third party email provider is Microsoft. Their privacy policy is available here: https://privacy.microsoft.com/en-gb/privacystatement

When you contact us by phone, we collect your phone number and any information provided to us during your conversation with us. We do not record phone calls.

• Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
• Legitimate interests: responding to enquiries and messages we receive and keeping records of correspondence.


• Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
• Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).

Transfer and storage of your information

Information about your call, such as your phone number and the date and time of your call, is processed by our third party telephone service provider and stored in the United Kingdom.

If you contact us by post, we will collect any information you provide to us in any postal communications you send us.

• Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
• Legitimate interests: responding to enquiries and messages we receive and keeping records of correspondence.


• Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
• Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).

Transfer and storage of your information

Information you send us by post is stored in the United Kingdom.

When you register and create an account on our website, we collect the following information: your e-mail address, your occupation, your name and any other information you provide to us when you complete the registration form, including any optional information, such as company name and address and telephone number.

If you do not provide the mandatory information required by the registration form, you will not be able to register or create an account on our website.

• Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
• Legitimate interests: registering and administering accounts on our website to provide access to content and facilitate the running and operation of our business.

Transfer and storage of your information

Information you submit to us via the registration form on our website will be stored within the European Economic Area on our third party hosting provider's servers in the United Kingdom.

When you place an order for goods or services on our website, we collect your name, company name, occupation, address, telephone number, billing email address, delivery email address. If you do not provide this information, you will not be able to purchase goods or services from us on our website or enter into a contract with us.

• Legal basis for processing: necessary to perform a contract (Article 6(1)(b) of the General Data Protection Regulation).
• Reason why necessary to perform a contract: we need the mandatory information collected by our checkout form to establish who the contract is with and to contact you to fulfil our obligations under the contract, including sending you receipts and order confirmations.


• Legal basis for processing: compliance with a legal obligation (Article 6(1)(c) of the General Data Protection Regulation).
• Legal obligation: we have a legal obligation to issue you with an invoice for the goods and services you purchase from us where you are VAT registered and we require the mandatory information collected by our checkout form for this purpose. We also have a legal obligation to keep accounting records, including records of transactions.

Transfer and storage of your information

Information you submit to us via the registration form on our website will be stored within the European Economic Area on our third party hosting provider's servers in the United Kingdom.

After you place an order on our website you will need to make payment for the goods or services you have ordered. In order to process your payment, we use a third party payment processor. Your payment will be processed by WorldPay Ltd.

WorldPay Ltd collects, uses and processes your information, including payment information, in accordance with their privacy policies. You can access their privacy policy via the following link: https://www.worldpay.com/uk/privacy-policy

Transfer and storage of your information

WorldPay Ltd is located in the United Kingdom. Information relating to the processing of your payment may be transferred outside the European Economic Area. Where they do so, they will take all steps reasonably necessary to ensure that your data is treated securely.

For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.

• Legal basis for processing: necessary to perform a contract (Article 6(1)(b) of the General Data Protection Regulation).
• Reason why necessary to perform a contract: to fulfil your contractual obligation to pay for the goods or services you have ordered from us.

Generally, we do not receive information about you from third parties. The third parties from which we receive information about you will generally include other businesses and clients we work with from time to time who may recommend our services to you. These could be businesses in any industry, sector, sub-sector or location.

It is also possible that third parties with whom we have had no prior contact may provide us with information about you.

Information we obtain from third parties will generally be your name and contact details, but will include any additional information about you which they provide to us.

• Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
• Reason why necessary to perform a contract: where a third party has passed on information about you to us (such as your name and email address) in order for us to provide services to you, we will process your information in order to take steps at your request to enter into a contract with you and perform a contract with you (as the case may be).


• Legal basis for processing: consent (Article 6(1)(a) of the General Data Protection Regulation).
• Consent: where you have asked that a third party to share information about you with us and the purpose of sharing that information is not related to the performance of a contract or services by us to you, we will process your information on the basis of your consent, which you give by asking the third party in question to pass on your information to us.


• Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
• Legitimate interests: where a third party has shared information about you with us and you have not consented to the sharing of that information, we will have a legitimate interest in processing that information in certain circumstances.

For example, we would have a legitimate interest in processing your information to perform our obligations under a sub-contract with the third party, where the third party has the main contract with you. Our legitimate interest is the performance of our obligations under our sub-contract.

Similarly, third parties may pass on information about you to us if you have infringed or potentially infringed any of our legal rights. In this case, we will have a legitimate interest in processing that information to investigate and pursue any such potential infringement.

Where we receive information about you in error

If we receive information about you from a third party in error and/or we do not have a legal basis for processing that information, we will delete your information.

In certain circumstances (for example, to verify the information we hold about you or obtain missing information we require to provide you with a service) we will obtain information about you from certain publicly accessible sources, both EU and non-EU, such as your own website, if you have one.

• Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
• Reason why necessary to perform a contract: where you have entered into a contract or requested that we enter into a contract with you, in certain circumstances, we will obtain information about you from public sources in order to enable us to understand your business and provide services to you or services to a sufficient standard.

For example, we would obtain and/or verify your email address from your website or from a directory where you ask us to send you information by email but we do not possess the information or we need to confirm that we have recorded your email address correctly.

• Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
• Legitimate interests: in certain circumstances, we will have a legitimate interest in obtaining information about you from public and private sources. For example, if you have infringed or we suspect that you have infringed any of our legal rights, we will have a legitimate interest in obtaining and processing information about you from such sources in order to investigate and pursue any suspected or potential infringement.

Use of profiling for web analytics

Our web analytics service, Google Analytics collects information such as your location (based on your IP address) and your behaviour (based on cookies) when you access our website (such as the pages you visit and what you click on. We will only process information from cookies if you have consented to us setting cookies on your computer in accordance with our Cookies Policy. Information collected about you, once collected is anonymised and stored on an aggregate basis.

• Logic involved: by automatically analysing and categorising information such as the location (based on IP address) as well as the behaviour and devices of visitors to our website (using cookies), we are able to gain a better understanding of what our website visitors want (in terms of the content of our website and our products), how to improve our website and how to advertise and market our services to them.
• Significance and envisaged consequences: cookies will be used to track and store information about your behaviour and device on our website (unless you have opted out from receiving such cookies by installing the Google browser plugin (https://tools.google.com/dlpage/gaoptout) and your location will be analysed based on your IP address.

• Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
• Legitimate interests: We use the information to compile aggregated anonymised reports and to help us improve the site.

We use a number of third parties to provide us with services which are necessary to run our business or to assist us with running our business and who process your information for us on our behalf. These include the following:

• Telephone providers (UK)
• Email service provider (Microsoft)
• IT service providers (UK)
• Web developers (UK)
• Hosting providers (UK)

Our third party service providers are located in the United Kingdom apart from our email service provider (Microsoft) whose servers are located in the European Economic Area (EEA). Their privacy policy is available here: https://privacy.microsoft.com/en-gb/privacystatement

Your information will be shared with these service providers where necessary to provide you with the service you have requested, whether that is accessing our website or ordering services from us.

We do not display the identities of all our service providers publicly by name for security and competitive reasons. If you would like further information about the identities of our service providers, however, please contact us directly by email and we will provide you with such information where you have a legitimate reason for requesting it (where we have shared your information with such service providers, for example).

• Legal basis for processing: legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
• Legitimate interest: where we share your information with these third parties in a context other than where is necessary to perform a contract (or take steps at your request to do so), we will share your information with such third parties in order to allow us to run and manage our business efficiently.

• Legal basis for processing: necessary to perform a contract and/or to take steps at your request prior to entering into a contract (Article 6(1)(b) of the General Data Protection Regulation).
• Reason why necessary to perform a contract: we may need to share information with our service providers to enable us to perform our obligations under that contract or to take the steps you have requested before we enter into a contract with you.

We disclose your information to other third parties in specific circumstances, as set out below.

Providing information to Google Inc.

Google collects information through our use of Google Analytics on our website. Google uses this information, including IP addresses and information from cookies, for a number of purposes, such as improving its Google Analytics service. Information is shared with Google on an aggregated and anonymised basis. To find out more about what information Google collects, how it uses this information and how to control the information sent to Google, please see the partners page of their privacy policy: https://www.google.com/policies/privacy/partners/

• Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
• Legitimate interest(s): meeting our contractual obligations to Google under our Google Analytics Terms of Service (https://www.google.com/analytics/terms/us.html)

You can opt out of Google Analytics by installing the browser plugin here:https://tools.google.com/dlpage/gaoptout

Transfer and storage of your information

Information collected by Google Analytics is stored outside the European Economic Area on Google's servers in the United States of America.

For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.

Sharing your information with third parties, which are either related to or associated with the running of our business, where it is necessary for us to do so. These third parties include our accountants, advisors, independent contractors and insurers.

• Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
• Legitimate interest: running and managing our business efficiently.

Accountants

We share information with our accountants for tax purposes. For example, we share invoices we issue and receive with our accountants for the purpose of completing tax returns and our end of year accounts.

Our accountants are located in the United Kingdom.

Advisors

Occasionally, we obtain advice from advisors, such as accountants and lawyers. We will share your information with these third parties only where it is necessary to enable these third parties to be able to provide us with the relevant advice.

Business partners

Business partners are businesses we work with which provide goods and services which are complementary to our own or which allow us to provide goods or services which we could not provide on our own. We share information with our business partners where you have requested services which they provide whether independently from, or in connection with or own services.

Our business partners are located in the United Kingdom.

Independent contractors

Occasionally, we use independent contractors in our business. Your information will be shared with independent contractors only where it is necessary for them to perform the function we have hired them to perform in relation to our business.

Our independent contractors are located in the United Kingdom.

Insurers

We will share your information with our insurers where it is necessary to do so, for example in relation to a claim or potential claim we receive or make or under our general disclosure obligations under our insurance contract with them.

Our insurers are located in the United Kingdom.

Sharing your information with a prospective or actual purchaser or seller in the context of a business or asset sale or acquisition by us, a merger or similar business combination event, whether actual or potential.

• Legal basis for processing: legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
• Legitimate interest(s): sharing your information with a prospective purchaser, seller or similar person in order to allow such a transaction to take place.

Indicating possible criminal acts or threats to public security to a competent authority

If we suspect that criminal or potential criminal conduct has been occurred, we will in certain circumstances need to contact an appropriate authority, such as the police. This could be the case, for instance, if we suspect that a fraud or a cyber-crime has been committed or if we receive threats or malicious communications towards us or third parties.

We will generally only need to process your information for this purpose if you were involved or affected by such an incident in some way.

• Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
• Legitimate interests: preventing crime or suspected criminal activity (such as fraud).

In connection with the enforcement or potential enforcement of our legal rights

We will use your information in connection with the enforcement or potential enforcement of our legal rights, including, for example, sharing information with debt collection agencies if you do not pay amounts owed to us when you are contractually obliged to do so. Our legal rights may be contractual (where we have entered into a contract with you) or non-contractual (such as legal rights that we have under copyright law or tort law).

• Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
• Legitimate interest(s): resolving disputes and potential disputes.

In connection with a legal or potential legal dispute or proceedings

We may need to use your information if we are involved in a dispute with you or a third party for example, either to resolve the dispute or as part of any mediation, arbitration or court resolution or similar process.

• Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
• Legitimate interest(s): resolving disputes and potential disputes.

Server log information: we retain information on our server logs for 6 months.

Inactive User Accounts: we automatically delete inactive user accounts according to the following criteria:

• any user that has been registered for 6 months but never subsequently signed-in;
• users who have registered as members of the public and have not signed-in for 1 year; and
• all other users who have not signed in for 3 years.

In any other circumstances, we will retain your information for no longer than necessary, taking into account the following:

• the purpose(s) and use of your information both now and in the future (such as whether it is necessary to continue to store that information in order to continue to perform our obligations under a contract with you or to contact you in the future);
• whether we have any legal obligation to continue to process your information (such as any record-keeping obligations imposed by relevant law or regulation);
• whether we have any legal basis to continue to process your information (such as your consent);
• how valuable your information is (both now and in the future);
• any relevant agreed industry practices on how long information should be retained;
• the levels of risk, cost and liability involved with us continuing to hold the information;
• how hard it is to ensure that the information can be kept up to date and accurate; and
• any relevant surrounding circumstances (such as the nature and status of our relationship with you).

We take appropriate technical and organisational measures to secure your information and to protect it against unauthorised or unlawful use and accidental loss or destruction, including:

• only sharing and providing access to your information to the minimum extent necessary, subject to confidentiality restrictions where appropriate, and on an anonymised basis wherever possible;
• using secure servers to store your information;
• verifying the identity of any individual who requests access to information prior to granting them access to information; and
• using Secure Sockets Layer (SSL) software to encrypt any information you submit to us via any forms on our website and any payment transactions you make on or via our website.

Transmission of information over the internet is not entirely secure, and if you submit any information to us over the internet (whether by email, via our website or any other means), you do so entirely at your own risk.

We cannot be responsible for any costs, expenses, loss of profits, harm to reputation, damages, liabilities or any other form of loss or damage suffered by you as a result of your decision to transmit information to us by such means.

We use a third party payment processor (WorldPay Ltd) to process the payment for orders that you may make via the website. WorldPay Ltd is located in the United Kingdom. Information relating to the processing of your payment may be transferred outside the European Economic Area. Where they do so, they will take all steps reasonably necessary to ensure that your data is treated securely.

WorldPay Ltd collects, uses and processes your information, including payment information, in accordance with their privacy policies. You can access their privacy policy via the following link: https://www.worldpay.com/uk/privacy-policy

Information collected by Google Analytics (your IP address and actions you take in relation to our website) is transferred outside the EEA and stored on Google's servers. You can access Google's privacy policy here:https://www.google.com/policies/privacy/

Country of storage: United States of America. This country is not subject to an adequacy decision by the European Commission.

Safeguard(s) used: Google has self-certified its compliance with the EU-U.S. Privacy Shield which is available here: https://www.privacyshield.gov/welcome. The EU-U.S. Privacy Shield is an approved certification mechanism under Article 42 of the General Data Protection Regulation, which is permitted under Article 46(2)(f) of the General Data Protection Regulation. You can access the European Commission decision on the adequacy of the EU-U.S. Privacy Shield here: https://gdpr-info.eu/issues/third-countries/

We will also transfer your information outside the EEA or to an international organisation in order to comply with legal obligations to which we are subject (compliance with a court order, for example). Where we are required to do so, we will ensure appropriate safeguards and protections are in place.

Subject to certain limitations on certain rights, you have the following rights in relation to your information, which you can exercise by contacting us by email at admin@courtel.co.uk , by post or by phone:

• to request access to your information and information related to our use and processing of your information;
• to request the correction or deletion of your information;
• to request that we restrict our use of your information;
• to receive information which you have provided to us in a structured, commonly used and machine-readable format (e.g. a CSV file) and the right to have that information transferred to another Data Controller (including a third party Data Controller);
• to object to the processing of your information for certain purposes (for further information, see the section below entitled Your right to object to the processing of your information for certain purposes); and
• to withdraw your consent to our use of your information at any time where we rely on your consent to use or process that information. Please note that if you withdraw your consent, this will not affect the lawfulness of our use and processing of your information on the basis of your consent before the point in time when you withdraw your consent.

In accordance with Article 77 of the General Data Protection Regulation, you also have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or of an alleged infringement of the General Data Protection Regulation.

For the purposes of the UK, the supervisory authority is the Information Commissioner's Office (ICO), the contact details of which are available here: https://ico.org.uk/global/contact-us/

The above rights are provided in summary form only and certain limitations apply to many of these rights. For further information about your rights in relation to your information, including any limitations which apply, please visit the following pages on the ICO's website:

• https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/; and
• https://ico.org.uk/for-the-public/is-my-information-being-handled-correctly/

You can also find out further information about your rights, as well as information on any limitations which apply to those rights, by reading the underlying legislation contained in Articles 12 to 22 and 34 of the General Data Protection Regulation, which is available here: https://gdpr-info.eu/

Where you request access to your information, we are required by law to use all reasonable measures to verify your identity before doing so.

These measures are designed to protect your information and to reduce the risk of identity fraud, identity theft or general unauthorised access to your information.

How we verify your identity

Where we possess appropriate information about you on file, we will attempt to verify your identity using that information.

If it is not possible to identity you from such information, or if we have insufficient information about you, we may require original or certified copies of certain documentation in order to be able to verify your identity before we are able to provide you with access to your information.

We will be able to confirm the information we require to verify your identity in your specific circumstances if and when you make such a request.

You have the following rights in relation to your information, which you can exercise by contacting us by email at admin@courtel.co.uk , by post or by phone:

• to object to us using or processing your information where we use or process it in order to carry out a task in the public interest or for our legitimate interests, including 'profiling' (i.e. analysing or predicting your behaviour based on your information) based on any of these purposes; and
• to object to us using or processing your information for direct marketing purposes (including any profiling we engage in that is related to such direct marketing).

You may also exercise your right to object to us using or processing your information for direct marketing purposes by:

• clicking the unsubscribe link contained at the bottom of any marketing email we send to you and following the instructions which appear in your browser following your clicking on that link;
• updating your marketing preferences by signing in and clicking "My Account" and unchecking the marketing emails box; or

• sending an email to admin@courtel.co.uk asking that we stop sending you marketing communications or by including the words "OPT OUT".

For more information on how to object to our use of information collected from cookies and similar technologies, please see the section entitled How to accept or reject cookies in our cookies policy, which is available here: www.allaboutcookies.org or see our Cookies Policy

'Sensitive personal information' is information about an individual that reveals their racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic information, biometric information for the purpose of uniquely identifying an individual, information concerning health or information concerning a natural person's sex life or sexual orientation.

We do not knowingly or intentionally collect sensitive personal information from individuals, and you must not submit sensitive personal information to us.

If, however, you inadvertently or intentionally transmit sensitive personal information to us, you will be considered to have explicitly consented to us processing that sensitive personal information under Article 9(2)(a) of the General Data Protection Regulation. We will use and process your sensitive personal information for the purposes of deleting it.

We do not knowingly contact or collect information from persons under the age of 18. The website is not intended to solicit information of any kind from persons under the age of 18.

It is possible that we could receive information pertaining to persons under the age of 18 by the fraud or deception of a third party. If we are notified of this, as soon as we verify the information, we will, where required by law to do so, immediately obtain the appropriate parental consent to use that information or, if we are unable to obtain such parental consent, we will delete the information from our servers. If you would like to notify us of our receipt of information about persons under the age of 18, please do so by sending an email to admin@courtel.co.uk

Where we make minor changes to our Privacy Policy, we will update our Privacy Policy with a new effective date stated at the beginning of it. Our processing of your information will be governed by the practices set out in that new version of the Privacy Policy from its effective date onwards.

Where we make major changes to our Privacy Policy or intend to use your information for a new purpose or a different purpose than the purposes for which we originally collected it, we will notify you by email (where possible) or by posting a notice on our website.

We will provide you with the information about the change in question and the purpose and any other relevant information before we use your information for that new purpose.

Wherever required, we will obtain your prior consent before using your information for a purpose that is different from the purposes for which we originally collected it.

This Privacy Policy is based on a General Data Protection Regulation (Regulation (EU) 2016/769) (GDPR) compliant template provided by GDPR Privacy Policy. For further information, please visit https://gdprprivacypolicy.org

The copyright in this Privacy Policy is either owned by, or licensed to, us and is protected by copyright laws around the world and copyright protection software. All intellectual property rights in this document are reserved.

Where we display the GDPR Privacy Policy logo on our website, this is used to indicate that we have adopted a privacy policy template provided by GDPR Privacy Policy as the basis for this Privacy Policy.