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  1. Introduction

1.1   We are committed to safeguarding the privacy of our website visitors and those who contact us through the website or by email.

1.2   This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and users; in other words, where we determine the purposes and means of the processing of that personal data.

1.3   We will ask you to consent to our use of cookies in accordance with the terms of this policy when you first visit our website.

1.4   Our website incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can specify whether you would like to receive direct marketing communications and limit the publication of your information.

1.5   In this policy, “we”, “us” and “our” refer to DeSouza Associates.

  1. Credit

2.1   This document was created using a template from SEQ Legal (https://seqlegal.com).

  1. How we use your personal data

3.1   In this Section 3 we have set out:

  • the general categories of personal data that we may process;
  • the purposes for which we may process personal data; and the legal bases of the processing.

3.2   We may process data about your use of 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 our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.

3.3   We may process your account data (“account data“). The account data may include your name and email address. The source of the account data is you. The account data may be processed for the purposes of operating 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 our legitimate interests, namely the proper administration of our website, services and organisation.

3.4   We may process your information included in your personal profile on our website (“profile data“). The profile data may include your name, address, telephone number, email address, profile pictures, gender, date of birth, relationship status, interests and hobbies, educational details and employment details. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services. The legal basis for this processing is our legitimate interests, namely the proper administration of our website, services and organisation.

3.5   We may process your personal data that are provided in the course of the use of our services (“service data“). The service data may include any of the following your name, address, telephone number, email address, profile pictures, gender, date of birth, relationship status, interests and hobbies, educational details and employment details. The source of the service data is you. The service data may be processed for the purposes of operating 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 our legitimate interests, namely the proper administration of our website, services and organisation.

3.6   We may process information that you post for publication on our website or through our services (“publication data“). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is our legitimate interests, namely the proper administration of our website, services and organisation.

3.7   We may process information contained in any enquiry you submit to us regarding our services (“enquiry data“). The enquiry data may be processed for the purposes of offering our services to you. The legal basis for this processing is implied consent from your initial enquiry.

3.8   We may process information relating to any transactions, including purchases of goods and services, that you enter into with us or through our website (“transaction data“). The transaction data may include your contact details, your card details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us.

3.9   We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data“). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent.

3.10 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 for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website, services and organisation. and communications with users.

3.11 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of 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 the protection and assertion of our legal rights, your legal rights and the legal rights of others.

3.12 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our organisation against risks.

3.13 In addition to the specific purposes for which we may process your personal data set out in this Section 3, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

3.14 Please do not supply any other person’s personal data to us, unless we prompt you to do so.

  1. Providing your personal data to others

4.1   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.

4.2   In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order 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 for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

  1. International transfers of your personal data

5.1   In this Section 5, we provide information about the circumstances in which your personal data may be transferred to countries outside the UK.

5.2   We have an office only in the UK and our policy complies with UK law accordingly implemented, including that required by the Data Protection Act 2018 and the UK GDPR, as it came into effect on 1st January 2021.

5.3  In order to carry out our business as an Event Agent,  acting on behalf of a UK client who wishes to book event services in the EU, we will on those occasions share data with our EU suppliers (such as a Destination Management Companies) in a confirmation document, sent via a secure web portal.    If you have any queries regarding the subsequent use of your personal data by our EU supplier, you will need to view their Privacy Policy.

5.4   You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

  1. Retaining and deleting personal data

6.1   This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

6.2   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.

6.3   We will retain your personal data as follows:

(a)   Personal data will be retained for a minimum period of three years following initial contact, and for a maximum period of seven years following contact.

(b)   Photographs will be retained for a minimum period of three years following initial contact, and for a maximum period of seven years following contact.

6.4   Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

  1. Amendments

7.1   We may update this policy from time to time by publishing a new version on our website.

7.2   You should check this page occasionally to ensure you are happy with any changes to this policy.

7.3   We may notify you of changes to this policy by email or through the private messaging system on our website.

  1. Your rights

8.1   You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to:

(a)   the payment of a fee (currently fixed at GBP 10); and

(b)   the supply of appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address) .

8.2   We may withhold personal information that you request to the extent permitted by law.

8.3   You may instruct us at any time not to process your personal information for marketing purposes.

8.4   In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.

  1. About cookies

9.1   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.

9.2   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.

9.3   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.

  1. Cookies that we use

10.1 We use cookies for the following purposes:

(a)   authentication – we use cookies to identify you when you visit our website and as you navigate our website (cookies used for this purpose are as supplied by Google Analytics)

(b)   analysis – we use cookies to help us to analyse the use and performance of our website and services (cookies used for this purpose are as supplied by Google Analytics)

  1. Cookies used by our service providers

11.1 Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

11.2 We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of 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/.

  1. Managing cookies

12.1 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/Ph31411 (Safari); and

(f)    https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).

12.2 Blocking all cookies will have a negative impact upon the usability of many websites.

12.3 If you block cookies, you will not be able to use all the features on our website.

  1. Our details

13.1 This website is owned and operated by DeSouza Associates.

13.2 We are registered in England and Wales under registration number 8665303, our registered address is 70a Castle Street, Farnham, Surrey GU9 7LP.

13.3 Our principal place of organisation is at 70a Castle Street, Farnham, Surrey GU9 7LP.

13.4 You can contact us:

  • by email at events@desouza-associates.com

(b)   by post, to the postal address given above

  1. Data protection officer

14.1 Our data protection officer’s contact details are: Lida DeSouza 01252 722185

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