Who we are
Nefolo understands that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who visits this website, https://nefolo.co.uk (“Our Site”) and will only collect and use personal data in ways that are described here, and in a manner that is consistent with our obligations and your rights under the law.
1. Definitions and Interpretation
In this Policy, the following terms shall have the following meanings:
“Account” – means an account required to access and/or use certain areas and features of Our Site.
“Cookie” – means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in Part 14 below.
“Cookie Law” – means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003.
“We/Us/Our” – means Nefolo, a limited company registered in England under company number 13481798, whose registered address is 22 Manor Grove, Fifield, Berkshire, SL6 2PQ
2. Information About Us
- Our Site is owned and operated by Nefolo Ltd , a limited company registered in England under company number 13481798, whose registered address is 22 Manor Grove, Fifield, Berkshire, SL6 2PQ
- Nefolo Ltd is the data controller and We are responsible for your personal data.
3. What Does This Policy Cover?
4. What is Personal Data?
Personal data is defined by the UK GDPR and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
5. What Are My Rights?
Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:
- The right to access the personal data we hold about you. Part 13 will tell you how to do this.
- The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 17 to find out more.
- The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Part 17 to find out more.
- The right to restrict (i.e. prevent) the processing of your personal data.
- The right to object to us using your personal data for a particular purpose or purposes.
- The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
- The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
- Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 17.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 15.
6. What Data Do We Collect and How?
|Data Collected||How We Collect The Data|
|Identity information including name, title||User submissions via our website, support and project management systems , internet search, email and other personal communication|
|Contact information including address, email, telephone number||User submissions via our website, support and project management systems, internet search, email and other personal communication|
|Business information including business name and job title||User submissions via our website, support and project management systems, internet search, email and other personal communication|
|Payment information including credit/debit card details and bank account details||Website eCommerce facility and manual invoicing|
|Profile information including login details and purchase history||Website membership, eCommerce and support pages|
|Technical information including IP address, browser type / version and operating system||User submissions made via our support system|
|Website visits including referring site, activity and time spent on page||Website analytics|
7. How Do You Use My Personal Data?
Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes how we may use your personal data, and our lawful bases for doing so:
|What We Do||What Data We Use||Our Lawful Basis|
|Registering you on our site||Name, email address||Contract|
|Providing and managing your account||Name, email address, phone number, website and information about your business||Contract|
|Providing and managing your access to our site||Name, email address, phone number||Contract|
|Personalising and tailoring your experience on our site||Cookies||Consent|
|Administering our business||Name, email address, phone number, payment information and other information about your business||Contract|
|Supplying our services to you||Name, email address, phone number, payment information and other information about your business||Contract|
|Managing payments for our services||Card and bank account details||Contract|
|Personalising and tailoring our services for you||Name, email address, phone number, payment information and other information about your business||Contract|
|Communicating with you about current or related services||Name, email address, phone number, business address||Contract|
|Supplying you with information by email that you have opted-in to (you may opt-out at any time by unsubscribing)||Name, email address||Consent|
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email and telephone with information, news, and offers on our services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.
We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 15.
8. How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):
|Type of Data||Retention Time|
|Identity information including name, title||3 years from client exit or initial communication of service requirement ends|
|Contact information including address, email, telephone number||3 years from client exit or initial communication of service requirement ends|
|Business information including business name, job title||3 years from client exit or initial communication of service requirement ends|
|Payment information including credit/debit card details and bank account details||7 years from client exit|
|Profile information including login details and purchase history||3 years from client exit|
|Technical information including IP address, browser type / version and operating system||3 years from client exit|
|Website visits including referring site, activity and time spent on page||Indefinitely. No PII recorded, only anonymised visit data|
9. How and Where Do You Store or Transfer My Personal Data?
We will store some of your personal data in the UK. This means that it will be fully protected under the Data Protection Legislation.
We store some of your personal data within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the EU GDPR and/or to equivalent standards by law. Transfers of personal data to the EEA from the UK are permitted without additional safeguards.
We may store some or all of your personal data in countries outside of the UK. These are known as “third countries”. We will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation as follows:
We ensure that your personal data is protected under binding corporate rules. Binding corporate rules are a set of common rules which all our group companies are required to follow when processing personal data. For further information, please refer to the Information Commissioner’s Office.
We will use specific approved contracts which ensure the same levels of personal data protection that apply under the Data Protection Legislation. For further information, please refer to the Information Commissioner’s Office.
Please contact us using the details below in Part 15 for further information about the particular data protection safeguard used by us when transferring your personal data to a third country.
The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:
- Limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality.
- Procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so.
10. Do You Share My Personal Data?
We may share your personal data for the purposes of fulfilling our contractual obligations with you, namely, building and supporting your websites. This may provide access you your data to our developers and technical staff working on the live site, staging copies and any backups.
We may sometimes contract with the following external third parties to supply certain tools and services. These may include payment processing, delivery, and marketing. In some cases, those third parties may require access to some or all of your personal data that we hold.
We list all external 3rd parties that may have access to your data:
|Amazon Web Services||Website Backup||Link|
|Google Cloud Platform||Website Hosting||Link|
|Microsoft||Office Suite, Communication & Document Storage||Link|
If any of your personal data is required by a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 9.
If any personal data is transferred outside of the UK, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation, as explained above in Part 9.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
11. How Can I Control My Personal Data?
In addition to your rights under the GDPR, set out in Part 5, when you submit personal data via Our Site, you may be given options to restrict our use of your personal data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails and at the point of providing your details.
You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
12. Can I Withhold Information?
13. How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 15.
We may need to request additional information for the purposes of establishing identity and ensure your right to access (or exercise any other rights) to your personal data. This is a security measure to prevent disclosure to any person who has no right to receive it.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our OR administrative costs in responding.
We will try to respond to your subject access request within one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time.
In some cases, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
All Cookies used by and on Our Site are used in accordance with current Cookie Law.
Before Cookies are placed on your computer or device, you will be shown a pop-up requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended. You will be given the opportunity to allow only first-party Cookies and block third-party Cookies.
Certain features of Our Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown in the table below. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below, but please be aware that Our Site may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.
Our Site uses analytics services provided by Google. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling us to better understand how Our Site is used. This, in turn, enables us to improve Our Site and the services offered through it.
The analytics service(s) used by Our Site use(s) Cookies to gather the required information. You do not have to allow us to use these Cookies, however whilst our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable us to continually improve Our Site, making it a better and more useful experience for you.
You can at any time change or withdraw your consent from the Cookie Declaration on our website. Your consent applies to the following domains: Nefolo.co.uk
In addition to the controls that we provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.
It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
15. How Can I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details:
- Email: firstname.lastname@example.org
- Phone: +44 (0) 1628 957507
- Post: 22 Manor Grove, Fifield, Berkshire, SL6 2PQ
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.
Policy Updated: 18th December 2022