Privacy Statement
At Total Web Solutions we take your privacy seriously and our privacy statement is detailed below. This statement takes into account the possibility that you may sign up and order our EcomMerchant service with us:
Who We Are
Total Web Solutions (‘we’ or ‘us’ or ‘our’) gather and process your personal information in accordance with this privacy notice and in compliance with the relevant data protection Regulation and laws. This notice provides you with the necessary information regarding your rights and our obligations, and explains how, why and when we process your personal data.
Total Web Solutions registered office is at 7 Bell Yard, London, WC2A 2JR, United Kingdom and we are a company registered in England and Wales under company number 3120571. We are registered on the Information Commissioner’s Office Register registration number Z477168 and act as the data controller and data processor depending on the service being provided. We have a designated Data Protection Officer/Appointed Person (DPO) for the organisation and the DPO can be contacted at [email protected].
Information That We Collect
Total Web Solutions processes your personal information to meet our legal, statutory and contractual obligations and to provide you with our products and services. We will never collect any unnecessary personal data from you and do not process your information in any way, other than as specified in this notice.
The personal data that we collect is dependent on the service we provide to you. Below is a list of services where we obtain personal data for the purpose of providing a service to you:
Common to all services:
- Contact Name;
- Contact Phone Number;
- Contact Email Address;
- Business Name;
- Business Address & Post Code;
- Username;
- Password;
- Unique customer identifier(s) that tie you to customer account(s) on our systems;
- IP Address;
- VAT Number.
Domain Name Registration:
- Domain Name;
- Various contact information as in “Common to all services” above for Registrant, Admin, Tech and Billing contacts;
- Domain specific password(s) for change control;
- Various handle identifiers for represent specific contact information for Registrant, Admin, Tech and Billing contacts.
Hosting:
- Domain Name;
- Business Location (City);
- Business Location (County).
Payment Processing:
- Domain Name;
- Business Location (City);
- Business Finances (Profit/Loss, Balance Sheet, Management Accounts & Projections).
Connectivity/Broadband/Lines & Calls:
- Installation Phone Number;
- Installation Post Code;
- IP Address.
We collect information in the following ways – Online using web forms for applying for services or via email for applications of employment. Should we collect your personal information during an enquiry we shall remove your personal data within 12 months of us recording it unless you subsequently become a customer.
How We Use Your Personal Data (Legal Basis for Processing)
Total Web Solutions takes your privacy very seriously and will never disclose, share or sell your data without your consent; unless required to do so by law. We only retain your data for as long as is necessary and for the purposes specified in this notice. Where you have consented to us providing you with promotional offers and marketing, you are free to withdraw this consent at any time using your web control panel provided at time of service activation. The purposes and reasons for processing your personal data are detailed below but may depend on the service:
As necessary to perform our contract with you for the relevant service:
- To ascertain the suitability for a contract to provide a service;
- To ensure that orders are completed and can be delivered to you as expected in the course of a contract;
- To manage and perform that contract;
- To trace your whereabouts to contact you about the contract we provide you with and in recovering debt.
As necessary for our own legitimate interests or those of other persons and organizations:
- For good governance, accounting, managing and auditing our business operations;
- To monitor emails, calls and other communications on your account;
- For market research, analysis and developing statistics;
- To send you marketing information where we have assessed that it is beneficial to you as a customer and in our interests. Such information will be non-intrusive and we send these infrequently;
- To send you service communications, in particular scheduled down time or service interruption notifications.
As necessary to comply with legal obligations:
- In the collection and storage of your personal data for business accounting and tax purposes in-line with UK law;
- For compliance with legal and regulatory requirements, e.g. to meet the requirements laid down by ICANN for the registration and supply of domain names;
- For the prevention, detection and investigation of fraud.
Based on your consent:
To send you marketing information where we have asked for your consent to do so. Specifically promotion of new services or product promotions. These are typically infrequent and likely to be a handful a year.
You are free to withdraw your consent at any time, the consequences of which may mean we are unable to provide certain services to you.
Data Subjects Rights (Your Rights)
You have the right to access any personal information that Total Web Solutions processes about you and to request information about:
- What personal data we hold about you;
- The purposes of the processing;
- The categories of personal data concerned;
The recipients to whom the personal data has/will be disclosed;
- How long we intend to store your personal data for;
If we did not collect the data directly from you, information about the source.
If you believe that we hold any incomplete or inaccurate data about you, you have the right to ask us to correct and/or complete the information and we will strive to update/correct it as quickly as possible; unless there is a valid reason for not doing so, at which point you will be notified.
You also have the right to request erasure of your personal data or to restrict processing (where applicable) in accordance with data protection laws, as well as to object to any direct marketing from us, to exercise your data portability rights and to be informed about any automated decision-making we may use.
If we receive a request from you to exercise any of the above rights, we may ask you to verify your identity before acting on the request; this is to ensure that your data is protected and kept secure.
Sharing and Disclosing Your Personal Information
We do not share or disclose any of your personal information without your consent, other than for the purposes specified in this notice or where there is a legal requirement. Total Web Solutions uses several third-parties to provide the below services and business functions. However, all processors acting on our behalf only process your data in accordance with instructions from us and comply fully with this privacy notice, the data protection laws and any other appropriate confidentiality and security measures.
Depending on the service we provide you, will depend on whether we disclose your personal data to third-parties. Below is a list of services where we disclose your personal data in the form of your contact information, to third-parties and who those third-parties might be:
Common to all services:
- Credit reference agencies, debt collection agencies such as Thomas Higgins (To verify a Company’s or individuals credibility and in the pursuit of debt collection). Acting in the capacity of Data Processor;
- Government bodies, such as regulators, e.g. The Information Commissioners Office;
- The Courts of England & Wales (To comply with legal requirements, and for the administration of justice). Acting in the capacity of Data Processor;
- Data Backup And Recovery Services to provide continuity in the event of Total Web Solutions ceasing to trade or it experiences a disaster where it is unable to continue doing business. DRS currently handle this service in the capacity of Data Processor.
Domain Name Registration:
- Registry and Registrar organisations depending on your choice of domain name at time of purchase, e.g. Verisign, Afilias, Nominet, Neustar, etc… (To provide Domain Name Registration and Management services). They can act in the capacity of either Data Processor or Data Controller depending on whether they are a thin or thick (Thin being where they do not store the personal data and Thick being where they do) registry.
Hosting:
- Ripe the IP Address governing body for Europe (To provide services using Internet assigned numbers). Acting in the capacity of Data Processor.
Payment Processing:
- Acquiring Banks depending on your choice of acquirer, e.g. Barclaycard, WorldPay, FirstData, etc… (To Provide Merchant Services to facilitate card processing). Acting in the capacity of Data Processor;
- Fraud prevention companies (To provide an anti-fraud mechanism to help protect you from fraud on your merchant account). Acting in the capacity of Data Processor.
Connectivity/Broadband/Lines & Calls:
- Ripe the IP Address governing body for Europe (To provide services using Internet assigned numbers). Acting in the capacity of Data Processor;
- Hardware suppliers, various (To provide hardware to enable to use of a given service, e.g. Hardware Router to enable Broadband connectivity). Acting in the capacity of Data Processor;
- Upstream Services Providers, e.g. British Telecom, Virgin Media, etc… (To provide connectivity solutions in the form of Leased Lines, Telephone Lines, and network connectivity solutions). Acting in the capacity of Data Processor.
Safeguarding Measures
Total Web Solutions takes your privacy seriously and takes every reasonable measure and precaution to protect and secure your personal data. We work hard to protect you and your information from unauthorised access, alteration, disclosure or destruction and have several layers of security measures in place, including but not limited to:
- Secure Socket Layer (to latest TLS standard);
- Encryption of sensitive data;
- Software & Hardware Firewalls;
- Anti-Virus software;
- Intrusion Detection and Prevention Systems;
- Regular Penetration Tests;
- Regular software security reviews and updates;
- Password protection and authentication;
- Regular Vulnerability Scans;
- DDOS Protection.
Transfers Outside the EU
Total Web Solutions utilise some products or services (or parts of them) that may be hosted/stored in Australia, Canada & USA, which means that we may transfer any information which is submitted by you through the website outside the European Economic Area (“EEA”) for the below purposes:
- Domain Name Registration;
- Email Management.
Therefore, when you register a domain or use our email services, the personal information you submit may be stored on servers which are hosted in Australia, Canada or the USA. Where this is the case, we will take steps to ensure that those providers use the necessary level of protection for your information and abide by strict agreements and measures set out by the ICO to protect your data and comply with the relevant data protection laws.</retractable,scalable, and reportable.
Consequences of Not Providing Your Data
You are not obligated to provide your personal information to Total Web Solutions, however, as this information is required for us to provide you with our services, we will not be able to offer some/all of our products or services without it.
Legitimate Interests
As noted in the ‘How We Use Your Personal Data’ section of this notice, we occasionally process your personal information under the legitimate interests’ legal basis. Where this is the case, we have carried out a thorough Legitimate Interests’ Assessment (LIA) to ensure that we have weighed your interests and any risk posed to you against our own and that such interests are proportionate and appropriate.
- Your email address to send you service communications to keep you informed of scheduled and unscheduled service interruption;
- Your contact information to inform you of a change to service provision i.e. No longer provide a particular service;
- Your contact information to undertake market research and analysis to determine whether a given service is beneficial to you and whether the service is cost effective;
- Your contact information to send you marketing information where we believe a particular service maybe of interest to you or have now become eligible for a service where once you were not. i.e. Broadband fiber is now available in your area;
- Your account information, in particular invoices, where we can examine your purchases and payments to ensure good accounting practices has been applied;
- Your emails, calls and other communications where we can examine the practice of good corporate governance and for training and quality improvements.
How Long We Keep Your Data
Total Web Solutions only ever retains personal information for as long as is necessary and we have strict review and retention policies in place to meet these obligations. We are required under UK tax law to keep your basic personal data (name, address, contact details) for a minimum of 6 years after which time it will be destroyed. Where your personal data has been obtained pre-contract we will remove your data from our systems within 12 months unless during this time you have become a customer. We shall retain your personal data even after you no longer are in contract with Total Web Solutions for a period of 12 months except where a domain name has been registered in which case retention periods are in accordance with ICANN’s (www.icann.org) policies on retention.
Your Right To Complain
Total Web Solutions only processes your personal information in compliance with this privacy notice and in accordance with the relevant data protection laws. If, however you wish to raise a complaint regarding the processing of your personal data or are unsatisfied with how we have handled your information, you have the right to lodge a complaint with the supervisory authority.
Contact Information:
- Phone: 0844 856 0681
- Email: [email protected]
- Information Commissioner’s Office Address:
- Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
- ICO Phone: 0303 123 1113
Cookie Notice
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