Privacy Policy

1. Introduction

ATR Agency (“we”, “us”, or “our”) respects your privacy and is committed to protecting your personal data. This privacy policy will inform you about how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

2. Important Information and Who We Are

Purpose of this Privacy Policy: This privacy policy aims to give you information on how ATR Agency collects and processes your personal data through your use of this website, including any data you may provide through this site when you sign up for a service or purchase a product.

Controller: ATR Agency is the controller and responsible for your personal data.

Contact Details: If you have any questions about this privacy policy or our privacy practices, please contact us at: Email: controller@atragency.co.uk

Changes to the Privacy Policy and Your Duty to Inform us of Changes: We keep our privacy policy under regular review. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes.

3. The Data We Collect About You

Personal data, or personal information, means any information about an individual from which that person can be identified. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data: includes first name, last name, username or similar identifier.
  
• Contact Data: includes billing address, delivery address, email address and telephone numbers.
  
• Transaction Data: includes details about payments to and from you and other details of products and services you have purchased from us.
  
• Technical Data: includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
  
• Profile Data: includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
  
• Usage Data: includes information about how you use our website, products and services.
  
• Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

4. How is Your Personal Data Collected?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  
  • apply for our products or services;
    
  • create an account on our website;
    
  • subscribe to our service or publications;
    
  • request marketing to be sent to you;
    
  • enter a competition, promotion or survey; or
    
  • give us feedback or contact us.

Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.

5. How We Use Your Personal Data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.
  
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  
• Where we need to comply with a legal obligation.

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

6. Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

7. Data Retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

8. Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:

• Request access to your personal data.
  
• Request correction of your personal data.
  
• Request erasure of your personal data.
  
• Object to processing of your personal data.
  
• Request restriction of processing your personal data.
  
• Request transfer of your personal data.
  
• Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us.

9. Glossary

LAWFUL BASIS

• Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience.
  
• Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
  
• Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

YOUR LEGAL RIGHTS You have the right to:

• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
  
  • If you want us to establish the data’s accuracy.
    
  • Where our use of the data is unlawful but you do not want us to erase it.
    
  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
    
  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal