Privacy policy
Data Collection
UKHIGHLAND undertakes to collect Your Data by means that are:
- fair;
- legal; and
- transparent.
Please note: UKHIGHLAND does not collect
and/or store any of your financial details (credit card or debit card numbers).
All transactions will be redirected to Paypal and processed by Paypal securely.
If you visit UKHIGHLAND 's web-site, your web-browser
automatically discloses, and UKHIGHLAND's web-server automatically
logs, the following information: the date and time, the IP address from which you
issued the request, the type of browser and operating system you are using, the
URL of any page that referred you to the page, the URL you requested, and whether
your request was successful. This data may or may not be sufficient to identify
you.
Any additional data that you provide, e.g. in a web-form, may also
be logged. This data may or may not be sufficient to identify you.
Any additional data that your web-browser automatically provides
may also be logged. This will be the case, for example, if your browser has previously
been requested to store data on your computer in 'cookies'
and submits them each time you request a web-page within a particular domain (such
as dealextreme.com). This data may or may not be sufficient to identify you.
If you disclose personal data to UKHIGHLAND in conjunction with an identifier
such as your name or your contact details (such as your e-mail address), UKHIGHLAND will
collect Your Data. Moreover, any data that becomes available to UKHIGHLAND through
any of the means described in the preceding paragraphs may be able to be associated
with that identifier, and hence become Your Data.
Subject to the qualifications immediately below, UKHIGHLAND undertakes
to collect Your Data from you and not from other parties. This
undertaking is qualified as follows:
- where UKHIGHLAND reasonably considers
that the protection of its financial interests requires that it gather Your Data
from other sources, or from additional sources. This applies in particular where UKHIGHLAND has
a lending exposure to you, and seeks information about your creditworthiness;
- where UKHIGHLAND reasonably considers that
its capability to deliver quality services to you will be materially enhanced by
gathering Your Data from other sources. This applies in particular to consumer profile
data.
Where UKHIGHLAND collects Your Data from sources other than you,
it undertakes:
- to do so only by legal means;
- to do so only with your Consent; and
- to declare to you what sources it uses, and under what circumstances.
UKHIGHLAND undertakes to declare the purpose of collection
in a manner which is clear and meaningful, and to avoid vague, highly inclusive
statements such as 'to support our operations'.
Data Security
UKHIGHLAND undertakes to store Your Data
in a manner that ensures security against unauthorised access, alteration or deletion,
at a level commensurate with its sensitivity.
UKHIGHLAND undertakes to store Your Data only in jurisdictions
where data protections are at least equivalent to those required under the OECD
Guidelines.
UKHIGHLAND undertakes to transmit Your Data
in a manner that ensures security against unauthorised access, alteration or deletion,
at a level commensurate with its sensitivity.
UKHIGHLAND undertakes to implement appropriate measures
to ensure security of Your Data against inappropriate behaviour by UKHIGHLAND's
staff-members and contractors. These include:
- training for staff in relation to privacy;
- access control, to limit access to Your Data to those staff and
contractors who have legitimate reasons to access it;
- particularly in the case of sensitive data, audit trails of accesses,
including the identities of staff and contractors accessing the data;
- reminders to staff and contractors from time to time about the
importance of data privacy, and the consequences of inappropriate behaviour;
- declaration of appropriately strong sanctions that are to be applied
in the event of inappropriate behaviour
- clear communication of policies and sanctions; and
- processes to audit, to investigate and to impose sanctions.
Data Use
Use refers to the application of Your Data by any part of UKHIGHLAND,
or any staff-member or contractor of UKHIGHLAND in the course
of their work.
UKHIGHLAND undertakes to use Your Data only for:
- the purposes for which it was collected;
- such other purposes as are subsequently agreed
between UKHIGHLAND and You;
- such additional purposes as may be required by law.
In these circumstances, UKHIGHLAND will take any reasonable
steps available to it to communicate to You that the use has occurred, unless it
is precluded from doing so by law; and
- such additional purposes as are authorised by law
(in particular to protect UKHIGHLAND's interests, e.g. if it
believes on reasonable grounds that You have failed to fulfil your undertakings
to UKHIGHLAND or have committed a breach of the criminal law).
UKHIGHLAND undertakes to use Your Data only if it has
demonstrable relevance to the particular use to which it is being put.
UKHIGHLAND undertakes to use Your Data in such a manner as
to take into account the possibility that it is not of sufficient quality for
the purpose, e.g. because it is inaccurate, out-of-date, incomplete,
or out-of-context.
Data Disclosure
Disclosure refers to making Your Data available to any party other than UKHIGHLAND and
You. The term disclosure may include many different conditions of data transfer,
including selling, renting, trading, sharing and giving.
UKHIGHLAND undertakes to disclose Your Data only under the
following circumstances:
- in the course of business being conducted between You
and UKHIGHLAND, where disclosure is necessary to a contractor, such as
payment processors like PayPal and transportation companies. Where Your Data is
disclosed in this way, UKHIGHLAND undertakes to exercise control
over UKHIGHLAND's contractors to ensure that their actions
are compliant with these Terms;
- in other circumstances that are directly implied by the
purpose agreed between You and UKHIGHLAND at the time of data collection
or subsequently. Where Your Data is disclosed in this way, UKHIGHLAND undertakes
to exercise control over UKHIGHLAND 's contractors to
ensure that their actions are compliant with these Terms;
- with your consent, or at your request;
- where required by law, such as a provision of
a statute, or a court order such as a search warrant or sub poena. In these circumstances,
UKHIGHLAND will take any reasonable steps available to it
to communicate to You that the disclosure has occurred, unless it is precluded from
doing so by law;
- where permitted by law (e.g. the reporting of
suspected breach of the criminal law to a law enforcement agency; and in an emergency,
where UKHIGHLAND believes on reasonable grounds that the disclosure
of Your Data will materially assist in the protection of the life of health of some
person), provided that UKHIGHLAND will apply due diligence
to ensure that the exercise of the permission is justifiable.
In all cases, UKHIGHLAND undertakes to disclose only such
of Your Data as is necessary in the particular circumstances.
Data Retention and Destruction
Subject to the qualifications immediately below, UKHIGHLAND undertakes:
- to retain Your Data only as long as is consistent
with its purpose; and
- to destroy Your Data when its purpose has expired,
and to do so in such a manner that Your Data is not subsequently capable of being
recovered.
This undertaking is qualified as follows:
- Your Data may be retained in UKHIGHLAND 's logs,
backups and audit trails within short-term retention cycles that are devised
to protect the company's operations. In such cases, Your Data will be destroyed
in accordance with those cycles;
- Your Data may be retained beyond the expiry of its
purpose if that is required by law, such as a provision of a statute,
or a court order such as a search warrant or sub poena, or a warning by a law enforcement
agency that delivery of a court order is imminent. In these circumstances, UKHIGHLAND:
- will take any reasonable steps available to it to communicate
to You that Your Data is being retained, unless it is precluded from doing so by
law; and
- will only retain Your Data while that provision is current, and
will then destroy Your Data;
- Your Data may be retained beyond the expiry of its purpose if
it is authorised by law (in particular to protect UKHIGHLAND's
interests, e.g. if it believes on reasonable grounds that You have failed
to fulfil your undertakings to UKHIGHLAND or have committed
a breach of the criminal law). In these circumstances, UKHIGHLAND will
only retain Your Data while that situation is current, and will then destroy Your
Data.
Access by You to Your Personal Data
UKHIGHLAND undertakes to provide you with access
to Your Data, subject to only such conditions and processes as are reasonable in
the circumstances. In particular, UKHIGHLAND undertakes to
enable access:
- conveniently;
- without unreasonable delay; and
- without cost.
UKHIGHLAND undertakes to establish and operate identity
authentication protections for access to Your Data that are appropriate
to its sensitivity, but practical. This may involve some inconvenience; for example,
relatively straightforward procedures may be involved in order to provide you with
access through a channel that you have previously registered with UKHIGHLAND (such
as a particular email-address), but may impose more onerous procedures if you wish
to use some other channel.
In the event that you dispute some aspect of Your Data, UKHIGHLAND undertakes
to take reasonable steps in relation to the amendment, supplementation or deletion
of Your Data.
You undertake:
- not to seek access for frivolous purposes, or unreasonably frequently;
- to accept that deletion of some data may not be consistent with
the provision of particular services by UKHIGHLAND to you.
Information about Data-Handling Practices
UKHIGHLAND undertakes to make information available to you
about the manner in which UKHIGHLAND handles your data:
- in general terms, in a readily accessible manner; and
- in more specific terms, on request.
Where Your Data is disclosed to a contractor, UKHIGHLAND undertakes
to make information available to you on request about the manner in which UKHIGHLAND's
contractors handle your data.
UKHIGHLAND undertakes to ensure that the information provided
is meaningful, and addresses your concerns.
You undertake:
- not to seek such information for frivolous purposes, or unreasonably
frequently; and
- to accept that the disclosure of excessive detail may harm the
security of Your Data and UKHIGHLAND's business processes,
and may harm UKHIGHLAND's commercial interests.
Handling of Enquiries, General Concerns and Complaints
If you have enquiries, general concerns, or complaints about these Terms, or about UKHIGHLAND's
behaviour in relation to these Terms, you undertake:
- to communicate them in the first instance:
- to UKHIGHLAND only;
- in sufficient detail;
- through a channel made available by UKHIGHLAND for
that purpose;
UKHIGHLAND undertakes:
- to provide one or more channels for communications
to UKHIGHLAND, which are convenient to users;
- to promptly provide acknowledgement of the receipt
of communications, including the provision of a copy of the communication, the date
and time it was registered, and UKHIGHLAND's reference-code
for the communication;
- to promptly provide a response to the communication,
in an appropriate and meaningful manner.
You further undertake to not pursue UKHIGHLAND through any
Regulator or the media:
- until and unless UKHIGHLAND has had a reasonable
opportunity to respond to the initial communication; and
- while UKHIGHLAND and you remain are conducting
a meaningful dialogue about the matter.
Enforcement
UKHIGHLAND declares that its undertakings in these Terms are
intended to create legal obligations, and that those obligations
are intended to be enforceable under appropriate laws in appropriate
jurisdictions. These include laws relating to data protection, privacy, fair trading,
corporations and criminal laws.
You undertake to seek enforcement only in a jurisdiction that is
relevant to the transactions that have taken place between You and UKHIGHLAND,
in particular the jurisdiction in which you live or in which you performed the relevant
acts, and the jurisdiction in which UKHIGHLAND is domiciled
or performed the relevant acts.
Changes to These Privacy Undertakings
UKHIGHLAND undertakes:
- not to materially change these Terms in a manner that reduces
the protections for Your Data;
- to take all possible steps to prevent any company that acquires
this company or any of its relevant assets from materially changing the Terms applicable
to Your Data in a manner that reduces the protections for Your Data;
- where it is considering making changes to these Terms, or creating
more specific Terms relating to specific services, to consult with appropriate representative
and advocacy organisations;
- where it makes changes to these Terms, to ensure that the differences
between successive versions are readily accessible;
- to maintain all prior versions of these Terms in such a manner
that they are dated, and readily accessible.
Definitions
UKHIGHLAND means ukhighland.com.
Your Data means data that is capable of being associated with you,
whether or not it includes an explicit identifier such as your name or customer
number. In particular, it encompasses all data that UKHIGHLAND is
capable of correlating with you, using such means as server-logs and cookie-contents.
Your Data does not refer to data that can no longer be associated with you.
This includes aggregated data that does not and cannot identify the individuals
whose data are included in the aggregation.
Consent means your concurrence with an action to be taken by
UKHIGHLAND. Consent may be express or implicit, but in either case
must be informed and freely-given.