TABLE OF CONTENTS

1. Introduction
2. Collection of Information
3. How we utilise Information
4. Purposes of Data Processing
5. Cookies, Beacons, Tags, Pixels
6. How we share your Personal Information and who with
7. International transfers
8. Security measures
9. Retention periods
10. Your rights
11. Age restrictions
12. Changes to Privacy Policy
13. Data Protection Authority
14. Further questions and contacts

1. INTRODUCTION

At SDC Hosting and Support we care about your privacy and believe in transparency. That’s why we are committed to being upfront about our privacy practices. We only collect personal information necessary to deliver our services and we handle it carefully and sensibly.
This Policy explains the privacy practices for SDC Hosting and Support Ltd (“SDC Hosting and Support,” together with “we,” “us,” “SDC”, and “our”), our websites (“Sites”) and other services provided by SDC (“Services”).
This Privacy Policy describes why and how we collect and use the personal information of our customers and website visitors. It also describes your options to choose how we use your personal data and how to contact us with any concerns and requests to in relation to that. SDC Hosting and Support Ltd is a company registered in England and Wales (registration number 10363780), with registered address: 82B High Street, Sawston, Cambridge, CB22 3HJ and is the data controller of the personal data that we collect from you.
If you have any questions, comments or concerns about any aspect of our Privacy Policy, please contact us using the details set out in the “Further questions and contacts” section at the end of this Privacy Policy.
Where the use of Client Area is mentioned, this refers to the web address https://billing.sdchas.co.uk

2. COLLECTION OF INFORMATION

When you access and browse the Sites (including when you submit personal information to us through data entry fields on the Sites) we will collect the following from you:
Information you provide:
• Contact information – we receive and store any information you enter on our Sites. Our Sites uses forms to collect your personal information including your name, address, telephone number, email address so you can place orders, request information, get support and use our services.
• Payments and billing information – when signing up for any of our Services, products, or programs, we request additional personal and payment information such as your name, credit card information, PayPal or relevant service, billing address, personal, government or TAX identification number or other information including but not limited to certificates, tax declarations, forms, payment documents and other relevant documents.
• Surveys and contests – we may, from time to time, offer surveys and opinion polls and ask you to provide information about your experience and feedback for our services. Occasionally we may organize promotions on our Sites or through our Social Media accounts and may offer a prize or discount as a sign of appreciation to the people who have participated, qualified and/or completed our Contest. Information requested for entry may include personal contact information such as your name, email, address, phone number, etc. Participation is entirely voluntary and it’s up to you whether you choose to disclose any information or not.

Information we receive from your use of our services or third-parties:
• Automated information – when you visit our Sites we receive and collect information, which may in certain circumstances constitute personal information and which includes your IP address, referral URL, exit URL, browser software, operating system, date/time and/or clickstream data.
• Websites Analytics tools – We may use analytics services by third parties to collect information about the use of the Sites, such as number of visits, pages visited, popularity of certain content. Analytics tools use tracking technologies (like cookies) to recognize your device and compile information about you. They collect information such as what pages you visit and how much time you spend on these pages, the IP address assigned to you, what operating system and web browser you use, and what sites you visited prior to visiting our Sites.
• Information Logs – when you visit our Sites, view content provided by us, use our Services, use our chat service, ask us a question, request technical assistance in regard to our Services, send us an email or participate in a contest or survey on our Sites, we automatically collect and store certain information in log files. This includes your IP address, URL, referral URL, exit URL, browser software, operating system, date/time, requests type to our Sites and error responses returned by our Sites or Services.
• Other information – we also receive and store any information that you provide on our Sites, our Chat service, any forms on our sites, email, telephone, or any other type of communication with our team or related to the provisioning of our services. Whenever you contact us, we will record the ticket, chat or call to ensure we have an accurate record of all communication, which is needed to provide our Services and to support any action taken by our team as a result in the event of a dispute over our response.

3. HOW WE UTILISE INFORMATION

Information you provide
We collect, store and use the information you provide for the following reasons:
• Contact information – to contact you regarding the progress of your orders, status of the services, functionality changes to our products and our Sites, and – where you have opted in to receive such information – other/new services, and/or special offers/newsletters we think you might find useful, we use email, telephone, and/or text message, as well as to inform you about hosting account issues, service interruptions or updates, service improvements or new products in accordance with our Terms of Service and applicable law.
• Payment and billing information – we need it together with your contact details, to open a Client or an Affiliate account for you, to process your orders and renewals, to enter into a contractual agreement for any Services, to invoice you and to fulfil our legal obligations for tax calculations.
Surveys and Contests
• Any answers to surveys and opinion polls are stored separately from your details and we either anonymize or pseudonymize the data collected, which can be used for ascertaining the usage of certain aspects of our Sites and Services and market research. We may share the anonymised or pseudonymised data with third parties when they need the information to fulfil their obligations to process it on our behalf. However, neither the anonymised data nor the pseudonymised data allows to identify you personally without the use of additional information which is kept separately and is subject to technical and organisational measures to ensure that none of the data is attributed directly to you.
• If you enter a Contest, we use the data you provide for the successful administration of the Contest, to contact you or work with third parties to contact you in case you’ve won anything and fulfil prizes in accordance to the announcement and terms of the participation for the respective Contest. We may also, where you have opted in to receive such communication, and unless prohibited by law, use your information provided via our surveys and Contests to send you details about our services or offers.
Information we receive from your use of our services or third-parties
We collect, store and use the information that we receive from your use of our services or third-parties for the following reasons:
• Automated information – to diagnose problems with our servers, to administer our Sites and Services. This is not linked to any personally identifiable information, except if necessary, to prevent fraud or abuse on our Sites and systems.
• Analytics tools – to improve services on our Sites.
• Information Logs – for diagnosing problems, administering our Sites and resolving issues.
• Other information – to maintain your account and purchased products, to have an accurate record of any inquiries in case of a dispute and to identify certain characteristics that could help us optimise and improve our products and Services.

4. PURPOSES OF DATA PROCESSING

When you access or use our Services, we need to collect, use, and otherwise process your information, as set out in this Policy. We are committed to your privacy and follow a few fundamental principles when we process personal data:
1. We strive to collect only the minimum personal data that we need to deliver any Services to you.
2. We aim for full transparency on how we use your information to comply with legal or other lawful purposes and respect your privacy.
3. We make sure we only use your information for the purposes you have given us permission for.
4. We rely on a number of legal bases to use your information, as set out in this Policy:
• Contract – the use of your information is necessary to perform any contractual obligations in order to provide any Services to you or to administer any Contests you enter into;
• Legal obligations – our use of your personal information is necessary to comply with a legal obligation, a court order, or to exercise or defend legal claims. For example, if we are requested to disclose your personal information to regulatory bodies or law enforcement authorities; or to use your personal information for tax calculations.
• Our legitimate interests – necessary for the purposes of our legitimate interests, such as to:
• run, grow, develop and deliver our services;
• detect and prevent fraudulent activities;
• enhance the security of our network and information systems;
• better understand how people interact with our websites;
• determine the effectiveness of our promotional campaigns and advertising; and,
• enhance, modify, personalise or otherwise improve our services and communications for the benefit of our customers.
5. Consent – we rely on your consent for us to use your personal information to send you marketing information (such as our newsletters and promotional offers) by email, SMS, or telephone. You may withdraw your consent at any time by updating your personal Info/Settings in your user profile in your Client Area, using our Unsubscribe option in relation to email subscriptions, or contacting us using the details set out in the “Further questions and contacts” section of this Policy.

5. COOKIES, BEACONS, TAGS, PIXELS

We may use Cookies to collect some of the information set out in this Policy. A cookie is a small piece of data sent from a website and stored in your web browser on your computer, mobile or other handheld device, while you are browsing a website.
Our Sites uses cookies to identify you. Cookies can store your account identifier, ordering status, personalisation or websites tracking. They can also be used for technical purposes such as keeping track of your current shopping session and enabling you to proceed to checkout and pay for your according order or to save information which has already been entered (languages choices, and your region), so that we can offer improved and more personalised services, products and other relevant communication tailored to you. Cookies also allow us to fulfil our contractual obligations to third parties and partners if you have made a purchase on our websites by following a link from theirs.
Our Sites may include marketing cookies and remarketing pixel provided by third parties. That allows these parties to collect the information that you have visited our Sites and were interested in certain offers. We may also use beacons, tags, click tracking codes and scripts to analyse trends and movements of users around the Sites, gather information about user base as a whole and how we can improve our Services and Sites, to provide advertising based upon activities and interests and to measure advertising effectiveness. As a result, we may display targeted, or interest-based, offers to you based on the products you currently own or have recently viewed and deliver other communication more relevant to you and your interests outside of our Sites, on other websites part of the third party’s network.
You can manage your preferences regarding Cookies either by modifying your browser settings or using the designated pop-up tool on our websites. In the ‘Cookie Settings’ pop-up on our Sites you will find a list of all cookies within each category (required, statistics, marketing), or a list of vendors serving cookies and similar technologies and will be able to choose which types of cookies you would like our Sites to use, if any.
You can also modify your Cookie preferences straight from your browser. Please note that if you simply disable all of our cookies or cookies in general in your browser settings, you may find that certain sections or features of our Sites will not work, because your browser may prevent us from setting Sites functionally required cookies.
You can find more detailed information about our use of cookies in our Cookies Policy.

6. HOW WE SHARE YOUR PERSONAL INFORMATION AND WHO WITH

All personal information collected by SDC Hosting and Support is treated as confidential. We disclose entire or part of your data in the limited circumstances described below and with appropriate safeguards on your privacy:
• If we are required by law – we will disclose information about you in response to a subpoena, court order, or other legitimate governmental request.
• Our SDC Hosting and Support group companies, Subsidiaries, employees, and independent contractors – we will disclose information about you to our SDC Hosting and Support group companies, subsidiaries, business partners, external consultants, auditors, collaborators or other third parties, some of our employees, and individuals who are our independent contractors that need to know the information in order to help us provide our services or to process the information on our behalf and also for administrative purposes, billing and tax and all other purposes related to the management of your account. We require all of them to comply strictly with this Privacy Policy.
• Third Party Vendors – we will share information with third party vendors based within the European Union and United States, Data Centre services providers based within the United Kingdom, external advisors/consultants, business partners, tax, accounting and legal companies, collaborators based within the European Union and United States, who need to know information about you in order to provide various services on our behalf. This group includes vendors that help us provide our services such as payment providers that process your credit card information or information about alternative payment methods and invoicing, and accounting companies as well as vendors that help us prevent fraud. This group also includes trusted vendors we partner with that perform analysis of our products or customer demographics and do market research that help us understand and enhance our services and help us serve better advertisements. This group also includes third party providers that perform analytic services and analyse the data of our surveys and/or contests. We will only share information about you that is necessary for the third-party vendor to provide the requested service. These companies will process the provided data under instructions of SDC Hosting and Support and in compliance with this Privacy Policy. We do not authorise vendors to retain, share, store or use your personally identifiable information for any secondary purposes. The third-party vendors include companies that operate in different industries such as Fraud Detection, Technology Service, Internet Information Providers, Payments and Data Processors, Specialty Finance, Media, Internet Content & Information Industries, Advertising & Marketing and Technologies, that are located in the territory of the European Union and United States.
• To Protect Rights and Property – We will share account and personal information with companies, organisations or individuals when we believe in good-faith that access, use, preservation or disclosure of the information is necessary to meet any applicable law, comply with regulation, legal process or enforceable request; to enforce or apply our Terms of Service and other agreements; to investigate potential violations; to protect against harm to the rights, property or safety of SDC Hosting and Support Ltd, our users or the public as required or permitted by law. To the extent we are legally permitted to do so, we will take all reasonable steps to notify you in the event that we are required to provide your personal information to third parties as part of legal process.
• Domain Registrars – the domain’s owner information (WHOIS Data) for any domain name is required and controlled by the ICANN-accredited registrar provider and the Registry for the top-level domain which you wish or have registered. We share your information to the extent necessary to comply with ICANN’s rules, regulations and policies, with rules and policies by the ICANN-accredited registrar providers we represent and the rules and policies of the top-level domain Registry. These registrar providers are located in Europe, USA and Canada. The information is also shared with the Registry for the top-level domain which may be located in another jurisdiction. The use and disclosure of the personal information as part of the domain registration process is governed by the Domain Name terms in our Terms of Service and the applicable agreements with the ICANN-accredited registrar.
• Business Transfers – in connection with any merger, sale of company assets, or acquisition of all or a portion of our business by another company, or in the unlikely event that SDC Hosting and Support Ltd goes out of business or enters bankruptcy, user information would likely be one of the assets that is transferred or acquired by a third party. If any of these events happens, we will take any reasonable steps to notify you and this Privacy Policy would continue to apply to your information and the party receiving your information shall continue to use your information, but only consistent with this Privacy Policy.
• With Your Consent – with your explicit consent or at your direction we may share and disclose information you have authorised us to with third parties. We will not, however, sell, rent, share or otherwise disclose personally identifiable information for commercial purposes in any way that is contrary to the commitments made in this Privacy Policy. We will take all reasonable steps to notify you when and what information might go to third parties and you will be able to choose whether to share it or not.

7. INTERNATIONAL TRANSFERS

We host, store or otherwise handle your personal information within the borders of European Economic Area (EEA) and the USA.
We will make sure that any transfers of your personal information from one country to another comply with the data protection and privacy laws that apply.
European data protection laws, in particular, include specific rules on transferring personal information outside the EEA.
When transferring personal information outside the EEA to the USA, we will include the standard data protection clauses approved by the European Commission under Article 46.2 of the General Data Protection Regulation (GDPR) into our contract with the US-based Partners.
You can find out further information about the rules on data transfers outside the EEA, including the mechanisms that we rely upon, on the European Commission websites here.
In any event, your information will be processed in accordance with this Privacy Policy. If you would like further information about the global handling of your personal information, please contact us using the details set out in the “Further questions” section below.

8. SECURITY MEASURES

We use Secure Sockets Layer (SSL) software to encrypt the information you enter on our Sites in order to protect its security during transmission to and from our Sites. When storing information, we protect its security by encryption and pseudonymization of critical data. When we process credit card information and payments, the credit card is subject to tokenization and strong security measures.
We maintain physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of personally identifiable customer information. Our security procedures require us in some cases to request proof of identity before disclosing personal information to you.
To protect against unauthorised access to your account and information, we implement session management, login expiration mechanisms and the option of using 2-factor authentication for Client Area access. As an additional safety measure, be sure to sign off when you finish using your account and your computer.
Although we take all these measures to maintain the safety and security of your personal information, please note that no transmission over the Internet can ever be guaranteed to be secure. Consequently, please note that we cannot fully guarantee the security of any personal information that you transfer over the Internet to us.

9. RETENTION PERIODS

Information collected on our Sites will only be retained for as long as necessary to fulfil the purpose for which it was collected. In general, we will automatically delete your Client Area account information 2 years after you no longer have any active services with us. Since we offer a service for customers worldwide and we need to comply with regulations across the globe in regard to retention of personal information related to contractual agreements, provision of services, financial, billing, invoicing operations and tax calculations, a versioned copy of your contact, payment and billing personal data associated with your past invoices is stored for a period of 7 years after deactivating an account. Your personal data is deleted automatically by our systems in accordance with these retention periods.

10. YOUR RIGHTS

By visiting the My Details page in your Client Area, you can access, correct, change, and delete certain personal information associated with your account. If you need further assistance, you can contact us using the details in the “Further questions and contacts” section of this policy to request any of the following:
• confirm whether or not personal data about you is being processed;
• provide you with further details about how we process your personal data;
• provide you with a copy of any data which we hold about you;
• withdraw your consent to using your personal information, where we rely on your consent as a legal basis to justify using your personal data;
• consider any valid objection to the processing of your personal information (including the right to object to processing on grounds related to your particular situation where we are relying on our legitimate interests as a legal basis for processing);
• request to update or delete personal data which we hold about you;
• restrict the way that we process your personal data;
• consider any valid request to transfer your personal data to a third-party provider of services (data portability); and
We will consider all those requests. However, certain personal information may be exempt from those requests in certain circumstances, which include a need to keep processing information for our legitimate interests or to comply with a legal obligation. If such an exception applies, we will notify you when responding to your request. Please note that we may ask you to provide us with information necessary to confirm your identity before responding.

11. AGE RESTRICTIONS

In accordance with SDC Hosting and Support Terms of Service, we do not sell products, provide services or collect information from any individual under the age of 13. If you are under the age of 13, you are not allowed to use the Sites and you must request your parent or guardian to use the Sites instead. Should you have any evidence that someone under the age of 13 has bought Services and provided their personal information to us, please contact us using the details set out in the “Further questions and contacts” section below.

12. CHANGES TO PRIVACY POLICY

We reserve the right to modify this Privacy Policy at any time. If we decide to change our Privacy Policy, we will post the updates to this Privacy Policy here and on any other place we deem appropriate, so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it.
If we make material changes to this Policy, we will notify you here, by email, or by means of a notice via our Sites, at least ten (10) calendar days before the changes take effect.

13. DATA PROTECTION AUTHORITY

In the EEA, you have the right to direct questions or lodge a complaint about our treatment of your personal information with our supervisory body for data protection – the Information Commissioner’s Office in the UK, at any time at:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

14. FURTHER QUESTIONS AND CONTACTS

If you have any questions regarding this Privacy Policy, if you wish to exercise any of your rights in relation to your personal information, or if you want to object to the collection or processing of your data by SDC, whether entirely or partially, please contact our Data Protection Officer who can reached at privacy@sdchostingandsupport.co.uk.