Privacy Policy

ABOUT THIS PRIVACY NOTICE

This Policy explains how WTS Plus, UIC 251 9523 05, Registered Office: 129 Victoria Drive, Eastbourne, East Sussex BN20 8LJ (referred to as “We”, “Us” or “Our”) processes your personal data. “Personal Information” or “Personal data” means any information that allows someone to identify, or reasonably link to, you directly or indirectly. When we describe “processing” of Personal Information, we mean how we collect, use, share, and retain Personal Information.

 

PERSONAL INFORMATION WE COLLECT

We process the personal data of the following data subject categories:

Customers   Customers are all individuals who are using our services.

We process the following categories of personal data:

CCTV data     CCTV footage: The personal data is collected with the purpose to record potential fraudulent or in any other way harmful behaviour.

Communication data     Exchanged email or other messages and files; The personal data is collected with the purpose to communicate with the data subject and respond to their inquiry.

Email Subscriber’s data  Email and/or name; The personal data is collected with the purpose of sending emails to subscribers. Email subscribers can unsubscribe at any time using the              “unsubscribe” button.

Payment information   Due or completed payment amount, billing address, date of payment and payer; The personal data is collected to track due and completed payments.

 

PURPOSE AND LEGAL BASES OF THE PROCESSING

We process personal data only where there is one or more of the following legal bases:

Consent from the data subject    The data subject has given consent to the processing of his or her personal data for one or more specific purposes:

Performance of contract Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering   into a contract.

Legal Obligations      Processing is necessary for compliance with a legal obligation to which the controller is subject.

Vital Interests             Processing is necessary in order to protect the vital interests of the data subject or of another natural person.

Legitimate Interest    Processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the interests or          fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.

Wheelchair user transport    We process your personal data for the following purposes:

Purpose    Legal basis and notes

Customer Support      Performance of a contract We process personal data to provide support to our customers Personal data is processed so we can fulfil our contractual obligations and         provide our services.

Email Marketing Consent    We process personal data to send our email newsletter to the email subscribers.

Website Analytics Consent  We analyse the behaviour of the website visitors to improve the user experience and our services.

 

HOW LONG WE KEEP YOUR PERSONAL INFORMATION

We keep your personal data only as long as necessary to achieve the purpose it is processed for. A full list of the purposes for which we process personal data can be found above.

We determine the appropriate retention period for personal information on the basis of the amount, nature and sensitivity of your personal information processed, the potential risk of harm from unauthorized use or disclosure of your personal information and whether we can achieve the purposes of the processing through other means, as well as on the basis of applicable legal requirements (such as applicable statutes of limitation).

Here are some of the categories of our retention periods:

Retention or deletion under a legal obligation   We may be subject to a legal obligation to keep or delete the data. Examples include mandatory data retention laws, government orders to preserve data relevant to an investigation or data kept for the purposes of litigation. Conversely, we will remove unlawful content if the law requires us to do so.

Establishment, exercise or defence of legal claims    We may retain information where necessary for the establishment, exercise or defence of legal claims.

Upon Request for Removal    We delete the personal data upon a request for removal from the data subject when there is no other legal ground for the retention of the data.

Automatic expiration after a period of time      We have set certain retention periods so that some data expires automatically after a specific period of time. After expiration of the applicable retention periods, we  will delete your personal information.

 

HOW WE SHARE YOUR DATA

We share personal data with the following 3rd parties:

Accounting Service Providers    We may share personal data with Accounting Service Providers to fulfil our legal obligations to maintain diligent accounting and comply with legal and tax        requirements.

Analytics Service Providers   We share information with Analytics Service Providers to be able to analyse the data we have collected.

Software Developers   We share information with software developers when this is necessary for the development of our services.

 

YOUR CHOICES AND RIGHTS

Here are your rights as a data subject:

Be informed  Be informed of the personal data we process about you and how we process it. We inform you:

  • Through this Policy
  • Through information provided to you as you use our Service
  • By answering your specific questions and requests when you contact us.

Know/ Access  Request to know and access the personal data we process about you. To request a copy of your personal data you can contact us.

Correction   Request that we amend or update your personal data where it’s inaccurate or incomplete. You can edit your User Data by contacting us.

Deletion   Request that we delete certain of your personal data. For example, you can ask us to delete your personal data:

  • That we no longer need for the purpose it was collected for
  • That we process based on the legal basis of consent, and you withdraw your consent.
  • When you object (see section ‘Object’ below) and
  • You make a justified objection, or
  • You object to direct marketing

There are situations where We are unable to delete your data, for example, when:

  • It is still necessary to process the data for the purpose we collected it for
  • Our interest in using the data overrides your interest in having it deleted. For example, where we need the data to protect our services from fraud.
  • We have a legal obligation to keep the data, or
  • We need the data to establish, exercise or defend legal claims. For example, if there’s an unresolved issue relating to your account

To delete your personal data you can contact us. You can also see more details in the section “HOW LONG WE KEEP YOUR PERSONAL INFORMATION”

Restriction    Request that we stop processing all or some of your personal data. You can do this if:

  • Your personal data is inaccurate
  • Our processing is unlawful
  • We do not need your information for a specific purpose, or
  • You object to our processing and we are assessing your objection request. See section ‘Object’ below.

You can request that we stop this processing temporarily or permanently.

You can exercise your right to restriction by contacting us.

Object   Object to us processing your personal data. You can do this if:

  • We are processing your personal data on the legal basis of legitimate interests, or
  • We are processing your personal data for tailored advertising.

To exercise your right to object, you can contact us.

Data portability    Request a copy of your personal data in electronic format and the right to transmit that personal data for use in another party’s service. You can request us to transmit your data when we are processing your personal data on the legal bases of consent or performance of a contract. However, we will try to honour any request to the extent possible.

For information about how to exercise the right to portability, see ‘Access’ above.

Not be subject to decision automated making        Not be subject to a decision based solely on automated decision making (decisions without human involvement), including profiling, where the decision would have a legal effect on you or produce a similarly significant effect.

We don’t perform automated decision making including profiling.

Withdrawal of consent    Withdraw your consent to us collecting or using your personal data.

You can do this if We are processing your personal data on the legal basis of consent.

To withdraw your consent, you can:

  • Adjust the relevant control
  • Contact us

Lodge a complaint with a supervisory authority    You have the right to lodge a complaint with a supervisory authority if you believe any of your rights have been violated. See the contact details of the data protection authorities here.

Verification process     We may request that you provide additional information reasonably necessary to verify you and your consumer’s request. If you submit the request through an                 authorized agent, we may need to collect additional information to verify your identity before processing your request.

Our response time    Upon receiving your request, we will respond without undue delay, but in all cases, within forty-five (45) days of receipt. The response period may be extended once by forty-five (45) additional days when reasonably necessary. We will inform you of any such extension within the initial 45-day response period, together with the reason                                                    for the extension.

 

HOW WE PROTECT YOUR DATA

We take the privacy and security of your Personal Information, including information considered sensitive, seriously. Our cybersecurity team actively works to maintain the integrity, confidentiality and availability of our Services and our policies and protocols are focused on protecting your Personal Information. We consistently strive to improve our defences in the ongoing battle against threat actors. That said, no method of transmission over the Internet, or method of electronic storage, is fully secure, and We cannot guarantee the security of your Personal Information. Our security, safety, and privacy features are provided on an “as-is” basis. As such, their effectiveness and error-free operation cannot be guaranteed, and we cannot ensure absolute confidentiality, anonymity, or personal safety. In the event that we are required by law to inform you of any unauthorized access to your Personal Information, we may notify you electronically or in writing in accordance with applicable law.

 

DATA PROTECTION AUTHORITY

Authority: The Information Commissioner’s Office
Phone number: 0303 123 1113
Email: international.team@ico.org.uk
Address: Water Lane, Wycliffe House Wilmslow – Cheshire SK9 5AF, United Kingdom
Website: https://ico.org.uk

 

HOW TO CONTACT US

We welcome your comments, questions, or complaints regarding this Privacy Notice, our use of your Personal Information, or our response to your requests regarding your Personal Information. Please contact us using markxlester@gmail.com or contact us by post at 129 Victoria Drive, Eastbourne, East Sussex BN20 8LJ

 

CHANGES TO THIS PRIVACY NOTICE

The latest version of the policy will govern our use of your Personal Information. We may revise this policy from time to time. If we determine, in our sole discretion, that the changes we make to this policy are material, we will notify you in advance.