This privacy statement is made on behalf of Guerrilla Trading.
All references to “Guerrilla”, “we”, “us” or “our” in this policy are references to Guerrilla Trading is committed to protecting your privacy and to compliance with the National Privacy Principles contained in the Privacy Act 1988 (Commonwealth). If you have any questions relating to this privacy statement or your privacy rights, please contact us.
This Privacy Statement sets out the policy of Guerrilla Trading for handling and protecting your personal information. We are committed to ensuring the privacy of your information in compliance with the new GDPR rules and recognise that you, as a customer, are concerned about your privacy and about the confidentiality and security of information that Guerrilla Trading may hold about you.
1 – What is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) 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.
2 – What Are My Rights?
Under the GDPR, you have the following rights, which we will always work to uphold:
The right to access the personal data we hold about you. Part 11 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 12 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 15 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 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 12.
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.
3 – What Data Do We Collect?
Web browser type and version;
A list of URLs starting with a referring site, your activity on our Sites, and the site you exit to;
4 – How Do You Use My Personal Data?
Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data may be used for any of the following purposes:
Providing and managing your access to our Sites;
Personalising and tailoring your experience on our Sites;
Supplying our services to you. Your personal details are required in order for us to provide these to you.
Personalising and tailoring our services for you.
Communicating with you. This may include responding to emails or calls from you.
Supplying you with information by email that you have opted-in to (you may unsubscribe or opt-out at any time by using the form at the footer of our website (Request for erasure/Remove consent).
Analysing your use of our Site and gathering feedback to enable us to continually improve our Site and your user experience.
Our policy is to only correspond with people that contact us to ask for our assistance and only on the subject matter requested (this may sometimes include news updates if relevant to your case). Should you at any time wish to stop such communication you can advise us by email, website form or phone. We do not pass any details to third parties without your express permission.
We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.
Third Parties whose content appears on our Sites may use third-party Cookies, as detailed below in Part 11. Please refer to Part 11 for more information on controlling cookies. Please note that we do not control the activities of such third parties, nor the data that they collect and use themselves, and we advise you to check the privacy policies of any such third parties.
5 – 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):
The retention of all data will be reviewed every 3 months and a decision will be made as to whether it should be retained based on the precise circumstances i.e. whether cases based on requests for assistance are ongoing and whether there is a need to retain the information for the purpose of potentially providing it to law enforcement agencies.
6 – How and Where Do You Store or Transfer My Personal Data?
We will only store or transfer 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 GDPR or to equivalent standards by law.
Should we need to share your data with a third party (regardless of where they are based) i.e. in order to carry out a service you have requested such as assisting with a timeshare exit, we will always first seek your written permission to do so. No data is shared without this express permission. Appropriate safeguards will be applied in the sharing of any such data.
7 – Do You Share My Personal Data?
We will not share any of your personal data with any third parties (unless express written permission is given by yourselves in order for a service to be carried out) for any purposes, subject to one important exception.
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.
If you request that your data is shared with 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 EEA, 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 GDPR, as explained above in Part 9.
8 – 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 websites, 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 contacting you (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.
9 – Can I Withhold Information?
You may access most areas of our Sites without providing any personal data at all.
10 – 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 12. You may also use the form in the footer of our websites Request for erasure/Remove consent. 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 administrative costs in responding.
We will 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, however, 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.
By using Our Sites, you may also receive certain third-party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, and/or parties other than us. Third-party Cookies are used on Our Sites to enhance your experience and reduce loading times. These Cookies are not integral to the functioning of Our Sites and your use and experience of Our Site will not be impaired by refusing consent to them.
All Cookies used by and on Our Sites 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 Sites may not function fully or as intended.
Certain features of Our Sites depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. 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 Sites 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 Sites use 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 Sites are used. This, in turn, enables us to improve Our Sites and the services offered.
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 Sites 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.
12 – How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, removing consent, requests for erasure or to update information please contact us in writing using the following details (for the attention of the Data Protection Officer):
Email address: email@example.com
Postal Address: Global House, 303 Ballards Lane, North Finchley, London, N12 8NP
Or by using the form provided in the footer of our websites Request for erasure/Remove consent.
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.
14 – Contacting Us
Last Updated 03/04/2020