TCL Management respect your privacy and are therefore in full compliance with the EU's
General Data Protection Regulation (GDPR). TCL Management will never sell, rent, lease or give away
your personal data to any third party, unless otherwise stated in this policy.
| 1.1 |
We are committed to safeguarding the privacy of our website
visitors and service users.
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| 1.2 |
This policy applies where we are acting as a data controller with
respect to the personal data of our website visitors and service
users; in other words, where we determine the purposes and means
of the processing of that personal data.
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| 1.3 |
We use cookies on our website. Insofar as those cookies are
not strictly necessary for the provision of our website and
services, we will ask you to consent to our use of cookies
when you first visit our website.
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| 1.4 |
Our website incorporates privacy controls which affect how we
will process your personal data. By using the privacy controls,
you can specify whether you would like to receive direct
marketing communications.
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| 1.5 |
In this policy, "we", "us" and "our" refer to TCL Management (South East) Limited. For
more information about us, see Section 12.
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| 2.1 |
In this Section 2 we have set out:
| (a) |
the general categories of personal data that we may process; |
| (b) |
in the case of personal data that we did not obtain directly from you, the source and specific categories of that data; |
| (c) |
the purposes for which we may process personal data; |
| (d) |
the legal bases of the processing. |
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| 2.2 |
We may process data about your use of our website and services
("usage data"). The usage data may include your IP address,
geographical location, browser type and version, operating
system, referral source, length of visit, page views and
website navigation paths, as well as information about the
timing, frequency and pattern of your service use. The
source of the usage data is our analytics tracking system.
This usage data may be processed for the purposes of
analysing the use of the website and services. The legal
basis for this processing is our legitimate interests, namely
monitoring and improving our website and services.
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| 2.3 |
We may process your account data ("account data”). The
account data may include your name and email address. The
source of the account data is you. The account data may be
processed for the purposes of operating our website, providing
our services, ensuring the security of our website and
services, maintaining back-ups of our databases and
communicating with you. The legal basis for this processing
is our legitimate interests, namely the proper administration
of our website and business.
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| 2.4 |
We may process your information included in your personal
profile on our website ("profile data"). The profile
data may include your name and email address. The profile
data may be processed for the purposes of enabling and
monitoring your use of our website and services. The legal
basis for this processing is our legitimate interests,
namely the proper administration of our website and business.
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| 2.5 |
We may process your personal data that are provided in the
course of the use of our services ("service data”). The service
data may include your name and email address. The source of
the service data is you. The service data may be processed
for the purposes of operating our website, providing our
services, ensuring the security of our website and services,
maintaining back-ups of our databases and communicating
with you. The legal basis for this processing is our
legitimate interests, namely the proper administration of
our website and business.
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| 2.6 |
We may process information that you post for publication on
our website or through our services ("publication data").
The publication data may be processed for the purposes of
enabling such publication and administering our website
and services. The legal basis for this processing is our
legitimate interests, namely the proper administration of
our website and business.
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| 2.7 |
We may process information contained in any enquiry you submit
to us regarding goods and/or services ("enquiry data"). The
enquiry data may be processed for the purposes of offering,
marketing and selling relevant goods and/or services to you.
The legal basis for this processing is consent.
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| 2.8 |
We may process information relating to our customer relationships,
including customer contact information ("customer relationship data”).
The customer relationship data may include your name, your contact
details, and information contained in communications between us
and you. The source of the customer relationship data is you.
The customer relationship data may be processed for the purposes
of managing our relationships with customers, communicating with
customers, keeping records of those communications and promoting
our products and services to customers. The legal basis for this
processing is consent.
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| 2.9 |
N/A
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| 2.10 |
We may process information that you provide to us for the purpose
of subscribing to our email notifications and/or newsletters
("notification data"). The notification data may be processed
for the purposes of sending you the relevant notifications
and/or newsletters. The legal basis for this processing is
consent.
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| 2.11 |
We may process information contained in or relating to any
communication that you send to us ("correspondence data").
The correspondence data may include the communication content
and metadata associated with the communication. The
correspondence data may be processed for the purposes of
communicating with you and record-keeping. The legal basis
for this processing is our legitimate interests, namely the
proper administration of our website and business and
communications with users.
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| 2.12 |
N/A
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| 2.13 |
We may process any of your personal data identified in this
policy where necessary for the establishment, exercise or
defence of legal claims, whether in court proceedings or in
an administrative or out-of-court procedure. The legal basis
for this processing is our legitimate interests, namely the
protection and assertion of our legal rights, your legal
rights and the legal rights of others.
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| 2.14 |
We may process any of your personal data identified in this
policy where necessary for the purposes of obtaining or
maintaining insurance coverage, managing risks, or obtaining
professional advice. The legal basis for this processing is
our legitimate interests, namely the proper protection of our
business against risks.
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| 2.15 |
In addition to the specific purposes for which we may process
your personal data set out in this Section 2, we may also process
any of your personal data where such processing is necessary in
order to protect your vital interests or the vital interests
of another natural person.
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| 2.16 |
Please do not supply any other person's personal data to us,
unless we prompt you to do so.
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| 5.1 |
This Section 5 sets out our data retention policies and procedure,
which are designed to help ensure that we comply with our legal
obligations in relation to the retention and deletion of
personal data.
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| 5.2 |
Personal data that we process for any purpose or purposes shall
not be kept for longer than is necessary for that purpose or
those purposes.
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| 5.3 |
We will retain your personal data as follows:
| (a) |
Your name and email address, submitted for the purpose of
email marketing, distributing e-newsletters or delivering
notifications, will be kept on file until your remove them
using our Unsubscribe service at
https://tclmanagement.com/unsubscribe. Links to our
unsubscribe service can also be found in our website
and e-mail footers.
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| 5.4 |
In some cases it is not possible for us to specify in advance
the periods for which your personal data will be retained. In
such cases, we will determine the period of retention based
on the following criteria:
| (a) |
We will automatically delete data that has no further use to our website and/or services.
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| 5.5 |
Notwithstanding the other provisions of this Section 5, we may
retain your personal data where such retention is necessary for
compliance with a legal obligation to which we are subject, or
in order to protect your vital interests or the vital interests
of another natural person.
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| 7.1 |
In this Section 7, we have summarised the rights that you have
under data protection law. Some of the rights are complex, and
not all of the details have been included in our summaries.
Accordingly, you should read the relevant laws and guidance
from the regulatory authorities for a full explanation of
these rights.
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| 7.2 |
Your principal rights under data protection law are:
| (a) |
the right to access; |
| (b) |
the right to rectification; |
| (c) |
the right to erasure; |
| (d) |
the right to restrict processing; |
| (e) |
the right to object to processing; |
| (f) |
the right to data portability; |
| (g) |
the right to complain to a supervisory authority; |
| (h) |
the right to withdraw consent. |
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| 7.3 |
You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
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| 7.4 |
You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
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| 7.5 |
In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
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| 7.6 |
In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
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| 7.7 |
You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
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| 7.8 |
You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
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| 7.9 |
You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
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| 7.10 |
To the extent that the legal basis for our processing of your personal data is:
| (a) |
Consent
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| (b) |
that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,
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and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
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| 7.11 |
If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
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| 7.12 |
To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
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| 7.13 |
You may exercise any of your rights in relation to your personal data by emailing us at info@tclmanagement.com.
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