This is the privacy policy for 1858 Ltd, registered at Harben House, Harben Parade, Finchley Road, London, NW3 6LH with company number 05077040. Our office address is 1858 Ltd, 64 Knightsbridge, London, SW1X 7JF, United Kingdom.
The purpose of this policy is to explain to you how we control, process, handle and protect your personal information while browsing or using this website, including your rights under current laws and regulations. If you do not agree to the following policy you may wish to cease viewing/using this website.
Policy key definitions:
- “I”, “our”, “us”, or “we” refer to the business, 1858 Ltd.
- “you”, “the user” refer to the person(s) using this website.
- GDPR means General Data Protection Act.
- PECR means Privacy & Electronic Communications Regulation.
- ICO means Information Commissioner’s Office.
- Cookies mean small files stored on a users computer or device.
Processing of Your Personal Data
We do not process personal data unless you provide us with your permission to do so. We will assume permission if you choose to contact us with your personal details.
If you send us an email/message, you are sending us personal data. Under the GDPR (General Data Protection Regulation) we control and/or process any personal information about you electronically using the following lawful bases:
- Lawful basis: Consent
The reason we use this basis: If you have contacted us, we use your details to reply to your message. If you subscribe to our mailing list, we use your details to keep you updated.
We process your information in the following ways: We use any details you send us to respond to your message. We use mailing list details to keep you updated.
Data retention period: We will continue to process your information under this basis until you withdraw consent or it is determined your consent no longer exists.
Sharing your information: If you subscribe to our mailing list your information is stored by iComplete. We do not share your information with any other third party.
- Lawful basis: Legal obligation/Criminal offence data
The reason we use this basis: You may send us something which incriminates you or someone else. We have an obligation to share this information with the relavant authorities.
We process your information in the following ways: Information might be shared with the relavant authorities.
Data retention period: We will retain information for as long as requested by the relavant authorities.
Sharing your information: We share your personal information with the relavant authorities.
If, as determined by us, the lawful basis upon which we process your personal information changes, we will do our best to notify you about the change and any new lawful basis to be used if required. We shall stop processing your personal information if the lawful basis used is no longer relevant.
Your Individual Rights
Under the GDPR your rights are as follows. You can read more about your rights in details here;
- the right to be informed;
- the right of access;
- the right to rectification;
- the right to erasure;
- the right to restrict processing;
- the right to data portability;
- the right to object; and
- the right not to be subject to automated decision-making including profiling.
You also have the right to complain to the ICO [www.ico.org.uk] if you feel there is a problem with the way we are handling your data.
We handle subject access requests in accordance with the GDPR.
Internet Cookies
Cookies are small files which many web sites transfer to your hard disk. They can inform the website what pages you visit and your preferences, which enable websites to provide you with a more personalised service. You can set your browser to refuse cookies, or to warn you before accepting them. On your first arrival to our website, we will ask you for consent to allow cookies.
We might use cookies to track how you use the website, to record or log whether you have seen particular messages that we display and/or to keep you logged into the website where applicable. We do not make use of advertising/personalised advertising on our website.
Cookies are not required to use this website but they might provide you with a better user experience. You may find there are parts of the site which you cannot access if cookies are turned off. You can control which cookies are saved to your device/computer using your web browser’s privacy settings. If you accept cookies, they will be saved for varying time periods based on how long they are needed or will be useful to your browsing experience.
Data Security and Protection
We ensure the security of any personal information we hold by using secure data storage technologies and precise procedures in how we store, access and manage that information. Our methods meet the GDPR compliance requirement.
Transparent Privacy Explanations
We have provided some further explanations about user privacy and the way we use this website to help promote a transparent and honest user privacy methodology.
Sponsored Links, Affiliate Tracking & Commission
Our website does not contain adverts or sponsored/affiliate links.
Email Marketing Messages & Subscription
Under the GDPR we use the consent lawful basis for anyone subscribing to our newsletter or marketing mailing list. We only collect certain data about you, as detailed in the “Processing of your personal data” above. Any email marketing messages we send are done so through an EMS (an email marketing service provider). An EMS is a third party service provider of software/applications that allows marketers to send out email marketing campaigns to a list of users.
Email marketing messages that we send may contain tracking beacons/tracked clickable links or similar server technologies in order to track subscriber activity within email marketing messages. Where used, such marketing messages may record a range of data such as; times, dates, IP addresses, opens, clicks, forwards, geographic and demographic data. Such data, within its limitations will show the activity each subscriber made for that email campaign.
Any email marketing messages we send are in accordance with the GDPR and the PECR. We provide you with an easy method to withdraw your consent (unsubscribe) or manage your preferences/the information we hold about you at any time. See any marketing messages for instructions on how to unsubscribe or manage your preferences.
Our EMS provider is iComplete. The privacy policies for our EMS providers can be found here:
Links
Links to other web sites are provided by us in good faith and for information only. We disclaim any responsibility for the materials contained in any web site linked to this site.
We will review this policy in the light of comments we receive so please check the latest version. If you have any questions specifically about privacy please contact us.