Total Web Solutions

Privacy:
 
Privacy Notice
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Who We Are
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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 12 Riverview, The Embankment Business Park, Heaton Mersey, Stockport, Cheshire. SK4 3GN 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 info@totalwebsolutions.com.
 

Information That We Collect
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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 dependant of 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)
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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)
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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
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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.

Please consult the relevant third-party organisation to obtain their privacy notice.  

 

Safeguarding Measures
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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 
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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.

 

Consequences of Not Providing Your Data 
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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 
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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. 

We use the legitimate interests’ legal basis for processing:

· 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
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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.

Where you have consented to us using your details for direct marketing, we will keep such data until you notify us otherwise and/or withdraw your consent.

 

Your Right To Complain
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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. 

Data Protection Officer
 Total Web Solutions
 12 Riverview
 The Embankment Business Park
 Heaton Mersey
 Stockport
 Cheshire
 SK4 3GL
 T: 0844 856 0681 or E: info@totalwebsolutions.com


Information Commissioner's Office
 Wycliffe House
 Water Lane
 Wilmslow
 Cheshire
 SK9 5AF
 T: 0303 123 1113

 

Cookie Notice
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A ‘cookie’ is a small piece of data sent from a website and stored on the user’s computer by the user’s web browser while the user is browsing. When you visit a site that uses cookies for the first time, a cookie is downloaded onto your computer/mobile device so that the next time you visit that site, your device will remember useful information such as items added in the shopping cart, visited pages or logging in options.

Cookies are widely used in order to make websites work, or to work more efficiently, and our site relies on cookies to optimise your user experience and for features, products and services to function properly. 

Most web browsers allow some control to restrict or block cookies through the browser settings, however if you disable cookies you may find this affects your ability to use certain parts of our website or services. For more information about cookies visit  https://www.allaboutcookies.org.

Our web site operates a soft opt-in giving you an opportunity to discontinue using it before cookies are set on a first visit to our web site.  Continuing to use this web site by accepting this opt-in means you are agreeing to the use of cookies.
You agree to Total Web Solutions storing and processing your personal data for the provision of a pre-contractual agreement (i.e. a quotation) or a contract agreement (i.e. provision of service) as specified in the Privacy Notice above.
Marketing:
Occasionally, Total Web Solutions would like to contact you with new service promotions and service improvement announcements. By ticking the box here, you consent to us using your contact details for these purposes. You have the right to modify or withdraw your consent at any time by contacting the Total Web Solutions Sales Department directly or using your control panel.
If you consent to us contacting you with the above-mentioned marketing and offers, please specify your preferred method of contact:
	Telephone		Email		Post		Text Message (SMS)
Contacting You:
Please specify your preferred methods of contact for discussing your enquiry:
		Telephone		Email		Post
Total Web Solutions General Sales/Enquiry Form

Payments Service
