Context & Overview
Policy prepared by: Data Protection Officer
Approved by board / management on: 24th April 2020
Policy became operational on: 1st May 2020
Next review date: 1st April 2021
Welcm Limited (“the Company”) needs to gather and use certain information about individuals. These individuals can include customers, suppliers, business contacts, employees and other people the organisation has a relationship with or may need to contact.
This policy describes how this personal data must be collected, handled and stored to meet the Company’s data protection standards and to comply with the law.
Why this policy exists
This data protection policy ensures Welcm Limited:
- Complies with data protection law and follow good practice
- Protects the rights of staff, customers and partners
- Is open about how it stores and processes individuals’ data
- Protects itself from the risks of a data breach
Data protection law
The General Data Protection Regulation (GDPR) describes how organisations — including Welcm Limited— must collect, handle and store personal information. These rules apply regardless of whether data is stored electronically, on paper or on other materials. To comply with the law, personal information must be collected and used fairly, stored safely and not disclosed unlawfully.
The General Data Protection Regulation (GDPR) is underpinned by eight important principles. These say that personal data must:
- Be processed fairly and lawfully
- Be obtained only for specific, lawful purposes
- Be adequate, relevant and not excessive
- Be accurate and kept up to date
- Not be held for any longer than necessary
- Processed in accordance with the rights of data subjects
- Be protected in appropriate ways
- Not be transferred outside the European Economic Area (EEA), unless that country or territory also ensures an adequate level of protection
People, Risks & Responsibilities
This policy applies to:
- The head office of Welcm Limited
- All branches of Welcm Limited
- All staff and volunteers of Welcm Limited
- All contractors, suppliers and other people working on behalf of Welcm Limited
It applies to all data that the Company holds relating to identifiable individuals, even if that information technically falls outside of the General Data Protection Regulation (GDPR). This can include:
- Names of individuals
- Postal addresses
- Email addresses
- Telephone numbers
- Any other information relating to individuals
Data protection risks
This policy helps to protect Welcm Limited from some very real data security risks, including:
- Breaches of confidentiality. For instance, information being given out inappropriately.
- Failing to offer choice. For instance, all individuals should be free to choose how the Company uses data relating to them.
- Damage to reputation. For instance, the Company could suffer if hackers successfully gained access to sensitive data.
Everyone who works for or with Welcm Limited has some responsibility for ensuring data is collected, stored and handled appropriately. Each team that handles personal data must ensure that it is handled and processed in line with this policy and data protection principles. However, these people have key areas of responsibility:
- The Board of Directors is ultimately responsible for ensuring that Welcm Limited meets its legal obligations.
- The Data Protection Officer is responsible for:
- Keeping the board updated about data protection responsibilities, risks and issues.
- Reviewing all data protection procedures and related policies, in line with an agreed schedule.
- Arranging data protection training and advice for the people covered by this policy.
- Handling data protection questions from staff and anyone else covered by this policy.
- Dealing with requests from individuals to see the data Welcm Limited holds about them (also called ‘subject access requests’).
- Checking and approving any contracts or agreements with third parties that may handle the Company’s sensitive data.
- The Head of IT is responsible for:
- Ensuring all systems, services and equipment used for storing data meet acceptable security standards.
- Performing regular checks and scans to ensure security hardware and software is functioning properly.
- Evaluating any third-party services the Company is considering using to store or process data. For instance, cloud computing services.
- The Marketing Manager is responsible for:
- Approving any data protection statements attached to communications such as emails and letters.
- Addressing any data protection queries from journalists or media outlets like newspapers.
- Where necessary, working with other staff to ensure marketing initiatives abide by data protection principles.
General Staff Guidelines
- The only people able to access data covered by this policy should be those who need it for their work.
- Data should not be shared informally. When access to confidential information is required, employees can request it from their line managers.
- Welcm Limited will provide training to all employees to help them understand their responsibilities when handling data.
- Employees should keep all data secure, by taking sensible precautions and following the guidelines below.
- In particular, strong passwords must be used and they should never be shared.
- Personal data should not be disclosed to unauthorised people, either within the Company or externally.
- Data should be regularly reviewed and updated if it is found to be out of date. If no longer required, it should be deleted and disposed of.
- Employees should request help from their line manager or the Data Protection Officer if they are unsure about any aspect of data protection.
These rules describe how and where data should be safely stored. Questions about storing data safely can be directed to the Head of IT or Data Protection Officer.
When data is stored on paper, it should be kept in a secure place where unauthorised people cannot see it.
These guidelines also apply to data that is usually stored electronically but has been printed out for some reason:
- When not required, the paper or files should be kept in a locked drawer or filing cabinet.
- Employees should make sure paper and printouts are not left where unauthorised people could see them. For example, on a printer.
- Data printouts should be shredded and disposed of securely when no longer required.
When data is stored electronically, it must be protected from unauthorised access, accidental deletion and malicious hacking attempts:
- Data should be protected by strong passwords that are changed regularly and never shared between employees.
- If data is stored on removable media (e.g. CD or DVD), these should be kept locked away securely when not being used.
- Data should only be stored on designated drives and servers, and should only be uploaded to an approved cloud computing services.
- Servers containing personal data should be sited in a secure location, away from general office space.
- Data should be backed up frequently. Those backups should be tested regularly, in line with the Company’s standard backup procedures.
- Data should never be saved directly to laptops or other mobile devices like tablets or smart phones.
- All servers and computers containing data should be protected by approved security software and a firewall.
Personal data is of no value to Welcm Limited unless the Company can make use of it. However, it is when personal data is accessed and used that it can be at the greatest risk of loss, corruption or theft:
- When working with personal data, employees should ensure the screens of their computers are always locked when left unattended.
- Personal data should not be shared informally. In particular, it should never be sent by email, as this form of communication is not secure.
- Data must be encrypted before being transferred electronically. The Head of IT can explain how to send data to authorised external contacts.
- Personal data should never be transferred outside of the European Economic Area.
- Employees should not save copies of personal data to their own computers. Always access and update the central copy of any data.
The law requires Welcm Limited to take reasonable steps to ensure data is kept accurate and up to date. The more important it is that the personal data is accurate, the greater the effort Welcm Limited should put into ensuring its accuracy. It is the responsibility of all employees who work with data to take reasonable steps to ensure it is kept as accurate and up to date as possible.
- Data will be held in as few places as necessary. Staff should not create any unnecessary additional data sets.
- Staff should take every opportunity to ensure data is updated. For instance, by confirming a customer’s details when they call.
- Welcm Limited will make it easy for data subjects to update the information the Company holds about them. For instance, via the Company website.
- Data should be updated as inaccuracies are discovered. For instance, if a customer can no longer be reached on their stored telephone number, it should be removed from the database.
- It is the Marketing Manager’s responsibility to ensure marketing databases are checked against industry suppression files every six months.
Subject Access Requests
All individuals who are the subject of personal data held by Welcm Limited are entitled to:
- Ask what information the Company holds about them and why.
- Ask how to gain access to it.
- Be informed how to keep it up to date.
- Be informed how the Company is meeting its data protection obligations.
If an individual contacts the Company requesting this information, this is called a Subject Access Request. Subject access requests from individuals should be made by email, addressed to the Data Protection Officer at firstname.lastname@example.org. The Data Protection Officer can supply a standard request form, although individuals do not have to use this. Individuals will be charged £10 per subject access request. The Data Protection Officer will aim to provide the relevant data within 14 days. The Data Protection Officer will always verify the identity of anyone making a subject access request before handing over any information.
Disclosing Data For Other Reasons
In certain circumstances, the General Data Protection Regulation (GDPR) allows personal data to be disclosed to law enforcement agencies without the consent of the data subject. Under these circumstances, Welcm Limited will disclose the requested data. However, the Data Protection Officer will ensure the request is legitimate, seeking assistance from the Board of Directors and from the Company’s legal advisers where necessary.
Welcm Limited aims to ensure that individuals are aware that their data is being processed, and that they understand:
- How the data is being used
- How to exercise their rights
To these ends, the company has a privacy statement, setting out how data relating to individuals is used by the Company. This is available on request. A version of this statement is also available on the Company’s website.
Context & Overview
We gather and use certain information about individuals in order to provide products and services and to enable certain functions on this website. We also collect information to better understand how visitors use this website and present timely, relevant information to them.
What data we gather
We may collect the following information:
- Contact information including email address
- Demographic information, such as postcode, preferences and interests
- Website usage data
- Other information relevant to client enquiries
- Other information pertaining to special offers and surveys
How we use the data
Collecting this data helps us understand what you are looking for from the Company, enabling us to deliver improved products and services. Specifically, we may use data:
- For our own internal records
- To improve the products and services we provide
- To contact you in response to a specific enquiry
- To customise the website for you
- To contact you about products, services, offers and other things we think might be relevant to you
- To contact you via email, telephone or mail for market research reasons
Cookies and how we use them
What is a cookie?
A cookie is a small file placed on your computer’s hard drive. It enables our website to identify your computer as you view different pages on our website. Cookies allow websites and applications to store your preferences in order to present content, options or functions that are specific to you. They also enable us to see information like how many people use the website and what pages they tend to visit.
- Analyse our web traffic using an analytics package. Aggregated usage data helps us improve the website structure, design, content and functions.
- Identify whether you are signed in to our website. A cookie allows us to check whether you are signed in to the site.
- Test content on our website. For example, 50% of our users might see one piece of content, the other 50% a different piece of content.
- Store information about your preferences. The website can then present you with information you will find more relevant and interesting.
- To recognise when you return to our website. We may show your relevant content, or provide functionality you used previously.
Cookies do not provide us with access to your computer or any information about you, other than that which you choose to share with us.
Controlling information about you
We will never lease, distribute or sell your personal information to third parties unless we have your permission or the law requires us to. Any personal information we hold about you is stored and processed under our data protection policy, in line with the General Data Protection Regulation (GDPR).
We will always hold your information securely. To prevent unauthorised disclosure or access to your information, we have implemented strong physical and electronic security safeguards. We also follow stringent procedures to ensure we work with all personal data in line with the General Data Protection Regulation (GDPR).
Links from our site
Our website may contain links to other websites. Please note that we have no control of websites outside the welcm.ly domain. If you provide information to a website to which we link, we are not responsible for its protection and privacy. Always be wary when submitting data to websites. Read the site’s data protection and privacy policies fully.
Context & Overview
Introduction & Key Details
Last Updated: 1st May 2020
Welcm’s premium features are available as a monthly or yearly subscription. Payment for Welcm All-in-One will be charged to your iTunes Account at confirmation of purchase. Payment for Welcm is charged to your credit / debit card via the billing section in your online dashboard. Subscription automatically renews unless auto-renew is turned off at least 24-hours before the end of the current period. Your account will be charged for renewal within 24 hours prior to the end of the current period. There is no increase in price when renewing.
There are no refunds or credits for partial months of service, upgrade/downgrade refunds, or refunds for months unused. Any unused portion of the free trial period will be forfeited when the user purchases a subscription.
Cancellation & Termination
Subscriptions may be managed by the user and auto-renewal may be turned off by going to the user’s Account Settings after purchase. Any unused portion of the free trial period will be forfeited when the user purchases a subscription.
You are responsible for properly cancelling Your account. Subscriptions may be managed by the account owner and auto-renewal may be turned off by going to the user’s Account Settings after purchase. There are no other means of cancelling Your account. All of Your Content stored by the Company will be deleted from the Service within one (1) hour upon cancellation. This information cannot be recovered once Your account is cancelled. If You hold a paid subscription to Welcm and You cancel the Service, Your cancellation will take effect immediately and You will not be charged again.
Welcm Limited reserves the right to (i) modify or discontinue, temporarily or permanently, the Service (or any part thereof) and (ii) refuse any and all current and future use of the Service, suspend or terminate Your account (any part thereof) or use of the Service and remove and discard any of Your content in the Service, for any reason, including, if Welcm Limited believes that You have violated these Terms. Welcm Limited will use diligent efforts to publish on the Site or notify You about any planned downtime of the Service, and will use all reasonable efforts to contact You directly via email to warn You prior to suspension or termination of Your account. Any suspected fraudulent, abusive, or illegal activity that may be grounds for termination of Your use of Service, may be referred to appropriate law enforcement authorities. Welcm Limited shall not be liable to You or any third party for any modification, suspension or discontinuation of the Service.
All hardware enquiries and purchases made via the Website are wholly managed by Rosendahl Conceptkiosk Ltd (the “Hardware Provider”). Any enquiries to, purchases from or information supplied to the Hardware Provider are subject to their policies and terms. Welcm Limited has no control over, and assumes no responsibility for, the content, terms, privacy policies, or practices of the Hardware Provider. You further acknowledge and agree that Welcm Limited shall not be legally or morally responsible or liable, directly or indirectly, for any damage or loss caused or alleged to be caused by or in connection with use of or reliance on the Hardware Provider, its goods or services.
Our Service allows you to make available certain information, text, graphics, videos, or other material (“Content”). You are responsible for the appropriateness and accuracy of the Content and ensuring You have permission to use the Content.
“Welcm”, the Welcm logo and all associated names and designs are trademarks of Welcm Limited. You may make use of these trademarks without permission under certain circumstances. You must not make use of these trademarks if their use will confuse customers / visitors / users of any website / document / event etc. The use of Welcm or Welcm All-in-One beyond the free trial period (sign up date + 15 days) constitutes your written permission for Welcm Limited to display your corporate logo on our websites (https://welcm.ly and https://welcm.uk). This use is exclusively to educate visitors to our website. Logos will be displayed in greyscale but will be unaltered in every other way. Logos will not be linked to any website however we will happily add links within the logos at your request. If you have any questions regarding any points here please contact email@example.com
Links To Third Parties
Our Service may contain links to third-party websites or services that are not owned or controlled by Welcm Limited. Welcm Limited has no control over, and assumes no responsibility for, the content, privacy policies, or practices of any third party web sites or services. You further acknowledge and agree that Welcm Limited shall not be legally or morally responsible or liable, directly or indirectly, for any damage or loss caused or alleged to be caused by or in connection with use of or reliance on any such content, goods or services available on or through any such websites or services.
Disclaimer of Warranties
THE SERVICE, INCLUDING THE SITE AND CONTENT, AND ALL SERVER AND NETWORK COMPONENTS ARE PROVIDED ON AN “AS IS” AND “AS AVAILABLE” BASIS WITHOUT ANY WARRANTIES OF ANY KIND, TO THE FULLEST EXTENT PERMITTED BY LAW AND Welcm Limited EXPRESSLY DISCLAIMS ANY AND ALL WARRANTIES, WHETHER EXPRESS OR IMPLIED, INCLUDING, BUT NOT LIMITED TO, THE IMPLIED WARRANTIES OF MERCHANTABILITY, TITLE, FITNESS FOR A PARTICULAR PURPOSE, AND NON-INFRINGEMENT. YOU ACKNOWLEDGE THAT Welcm Limited DOES NOT WARRANT THAT THE SERVICE WILL BE UNINTERRUPTED, TIMELY, SECURE, ERROR-FREE OR VIRUS-FREE AND NO INFORMATION OR ADVICE OBTAINED BY YOU FROM Welcm Limited OR THROUGH THE SERVICE SHALL CREATE ANY WARRANTY NOT EXPRESSLY STATED IN THESE TERMS.
You will indemnify and hold harmless Welcm Limited and its officers, directors, employees and agents, from and against any claims, disputes, demands, liabilities, damages, losses, and costs and expenses, including, without limitation, reasonable legal and accounting fees arising out of or in any way connected with (i) Your access to or use of the Service or Content and (ii) Your violation of these Terms.
Limitation of Liability
UNDER NO CIRCUMSTANCES AND UNDER NO LEGAL THEORY (WHETHER IN CONTRACT, TORT, OR OTHERWISE) SHALL Welcm Limited BE LIABLE TO YOU OR ANY THIRD PARTY FOR ANY INDIRECT, INCIDENTAL, SPECIAL, EXEMPLARY, CONSEQUENTIAL OR PUNITIVE DAMAGES, INCLUDING LOST PROFITS, LOST SALES OR BUSINESS, LOST DATA OR BUSINESS INTERRUPTION. IN ADDITION, Welcm Limited SHALL NOT BE LIABLE FOR ANY DIRECT DAMAGES, COSTS, LOSSES OR LIABILITIES IN EXCESS OF THE MONTHLY SERVICE FEE PAID OR PAYABLE BY YOU FOR THE ONE MONTH PRECEDING THE TIME OF ANY CLAIM FOR MONETARY DAMAGES OR ONE HUNDRED (£100) GBP STERLING. THE PROVISIONS OF THIS SECTION ALLOCATE THE RISKS UNDER THESE TERMS BETWEEN THE PARTIES, AND THE PARTIES HAVE RELIED ON THESE LIMITATIONS IN DETERMINING WHETHER TO ENTER INTO THESE TERMS.
Some locations do not allow the exclusion of implied warranties or limitation of liability for incidental or consequential damages, which means that some of the above limitations may not apply to You. IN THESE LOCATIONS, Welcm Limited’s LIABILITY WILL BE LIMITED TO THE GREATEST EXTENT PERMITTED BY LAW.
Welcm Limited may assign or transfer these Terms, in whole or in part, without restriction.
You are responsible for complying with any applicable laws, rules, or regulations governing the export of the Service or any of its components.
These Terms shall be governed by and construed in accordance with the laws of England and Wales. You hereby expressly agree to submit to the exclusive personal jurisdiction of the courts of England and Wales for the purpose of resolving any dispute relating to Your access to or use of the Service.
We reserve the right, at our sole discretion, to modify or replace these Terms at any time. If a revision is material we will try to provide notice prior to any new terms taking effect. What constitutes a material change will be determined at our sole discretion.