1.1 We are committed to safeguarding the privacy of our website visitors and service users.
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.
1.4 In this policy, “we”, “us” and “our” refer to Steel Blue Tech Ltd t/a Manchester VPS. For more information about us, see Section 14.
2. How we use your personal data
2.1 In this Section 2 we have set out:
(a) the general categories of personal data that we may process;
(b) the purposes for which we may process personal data; and
(c) the legal bases of the processing.
2.2 We may process data about your use of websites we operate which you may visit using a web browser (“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 use. The source of the usage data is our own internal web server logs as well as Google Analytics, a web analysis service provided by Google Inc. Please see Section 11 for more information about Google Analytics. This usage data may be processed for the purposes of analysing your use of our website. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website.
2.3 We may process your website user account data (“account data“). The account data may include your first and last names, you or your employer’s company name (if provided), your job title or role (if provided), postal address, telephone number (if provided), and email address. We do not ask for or store your title/appellation or your sex. The source of the account data is you or your employer. The account data may be processed for the purposes of operating our websites, providing our services, ensuring the security of our websites and services, maintaining back-ups of our databases and other software data, and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our websites and business.
2.4 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 the performance of a contract between you and us and/or the taking steps, at your request, to enter into such a contract.
2.5 We may process information relating to our customer relationships, including customer contact information (“customer relationship data“). The customer relationship data may include your first and last names, you or your employer’s company name (if provided), your job title or role (if provided), postal address, telephone number (if provided), and email address, and information contained in communications between us and you or your employer. We do not ask for or store your title/appellation or your sex. The source of the customer relationship data is you or your employer. 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 our legitimate interests, namely the proper management of our customer relationships.
2.6 We may process information relating to transactions, including purchases of goods and/or services, that you enter into with us and/or through our website (“transaction data“). The transaction data may include some or all of the contact details that we have stored as part of the customer relationship data. The transaction data will also contain details such as which method of payment you have chosen, transaction identifiers, the date and time of the transaction, the name of the service which is being paid for, and the amount of money being paid. The source of the transaction data is you/your employer and/or our payment services providers. The transaction data may be processed for the purpose of supplying the purchased goods and/or services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract; providing that, if you are not the person contracting with us, the legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.
2.7 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 our legitimate interests, namely communications with our website visitors and service users.
2.8 We may process information contained in or relating to any communication that you send to us (“communication data“). The communication data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The communication 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 communications with our website visitors and service users and the proper administration of our website and business.
2.9 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.
2.10 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.
2.11 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 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.
2.12 Please do not supply any other person’s personal data to us, unless we prompt you to do so.
3. Providing your personal data to others
3.1 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
3.2 Financial transactions relating to our website and services are handled by our payment services providers, which include the following companies: PayPal (Europe) S.Ã r.l. et Cie, S.C.A., GoCardless Ltd., BitPay, Inc. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers’ privacy policies and practices at the following URLs:
3.3 In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data where such disclosure 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. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
4. Retaining and deleting personal data
4.1 This Section 4 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.
4.2 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.
4.3 We will either delete or anonymise the personal data referred to in this policy within 18 months of the end date of our commercial or business relationship with you. If you ask us to delete or anonymise any data held about you before 18 months has passed, we will do so upon receiving your request. You can make this request by sending us a message using our website contact form here
4.4 Notwithstanding the other provisions of this Section 4, 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.
5. Security of personal data
5.1 We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of
your personal data.
5.2 Any of your personal data identified in this policy will be stored in computer RAM (temporarily, as needed by the Operating System or until powered off) and on long-term storage media (such as hard disk drives) connected only to physical computers which we wholly own. These computers are located only in secure premises in the United Kingdom, housed in cabinets and/or rooms where only we, together with the owners/occupiers of the premises where applicable, control the arrangements for physical access to the computers. Your personal data will also normally be periodically copied onto external storage devices or media, which are temporarily connected to our computers for the purposes of obtaining a backup, before being disconnected and physically moved to a separate location, sometimes at different premises. These backups are always kept securely locked, normally in a safe, and only accessible by a very limited number of staff who have been specifically granted access. In addition, some of your personal data may be stored in secure manual record-keeping systems for specific and limited purposes that may or may not arise in the course of the administration of our business.
5.3 In order to achieve high levels of security for any data that is transmitted or received between your web browser and any of our web servers, and which might reasonably be considered sensitive in nature (e.g. data relating to your enquiries, financial transactions, and management of our services), such data will be protected exclusively using the Transport Layer Security (TLS) cryptographic protocol. In line with accepted security best practise, we have disabled the Secure Sockets Layer (SSL) encryption protocol (now universally regarded as highly insecure) and encryption ciphers known to be weak (e.g. DES/3DES, RC4) on our web servers. Additionally, we will endeavour to a) run modern software and operating systems on our web servers, configured in a secure manner, b) have an awareness of security issues when writing code for any web applications we develop in house, and c) apply any security fixes rated as significant and made available to us, for any software we run on our web servers, as soon as it is operationally possible.
5.4 Where we have issued you with a password to be used in order to gain access to a resource or service provided by us, we will never store the password in its original form. Instead, we will always use a strong, one-way cryptographic hash function to generate an encrypted string of characters (a “hash”) representing your password, and only this hash is stored on our systems. We only use cryptographic hash functions regarded by cryptographers as practically infeasible to invert.
5.5 You should ensure that any passwords used to access our websites and services are not susceptible to being guessed, whether by a person or a computer program. You are responsible for keeping such passwords confidential. We will never ask you to disclose your password to any human at our organisation while communicating with us. You will only need to supply your password to our computer systems as part of any automated authentication process that is part of the service or resource we have made available to you and for which the password has been issued.
6. Your rights
6.1 In this Section 6, 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.
6.2 Your principal rights under data protection law are:
(a) the right to access – you can ask for copies of your personal data;
(b) the right to rectification – you can ask us to rectify inaccurate personal data and to complete incomplete personal data;
(c) the right to erasure – you can ask us to erase your personal data;
(d) the right to restrict processing – you can ask use to restrict the processing of your personal data;
(e) the right to object to processing – you can object to the processing of your personal data;
(f) the right to data portability – you can ask that we transfer your personal data to another organisation or to you;
(g) the right to complain to a supervisory authority – you can complain about our processing of your personal data; and
(h) the right to withdraw consent – to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.
6.3 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.
6.4 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.
6.5 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.
6.6 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.
6.7 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 data 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.
6.8 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.
6.9 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.
6.10 To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(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,
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.
6.11 If you consider that our processing of your personal data 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.
6.12 To the extent that the legal basis for our processing of your personal data is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
6.13 You may exercise any of your rights in relation to your personal data by written notice to us, in addition to the other methods specified in this Section 6.
7. Third party websites
7.1 Our website includes hyperlinks to, and details of, third party websites.
7.2 We have no control over, and are not responsible for, the privacy policies and practices of third parties.
8. Updating information
8.1 Please let us know if the personal information that we hold about you needs to be corrected or updated.
9. About cookies
9.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
9.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
9.3 Cookies do not typically contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.
10. Cookies that we use
determine if you are logged into our website;
11. Cookies used by our service providers
12. Managing cookies
12.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
12.2 Blocking all cookies will have a negative impact upon the usability of many websites.
12.3 If you block cookies, you will not be able to use all the features on our website.
13.1 We may update this policy from time to time by publishing a new version on our website.
13.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
13.3 We may notify you of changes to this policy by email.
14. Our details
14.1 This website is owned and operated by Steel Blue Tech Ltd t/a Manchester VPS.
14.2 We are registered in England and Wales under registration number 08133819, and our registered office is at 50 Cambridge Road, Macclesfield, Cheshire, SK11 8JW, United Kingdom.
14.3 You can contact us:
(a) by post, to the postal address given above; or
(b) using our website contact form here