Privacy Policy

WesternPathWays Website Privacy Policy

WesternPathWays take the protection and security of your personal information very seriously and this policy sets out our responsibilities under The General Data Protection Regulation 2016 (‘GDPR’) and other applicable laws in England and Wales relating to the processing and security of personal information.

This policy explains to you how WesternPathWays uses and secures your personal information whilst you are using the WesternPathWays website www.westernpathways.co.uk or when you enter into a contract with WesternPathWays to provide services to your organisation.

WesternPathWays are global specialists in identity intelligence we have customers located in over 70 countries. WesternPathWays uses data under licence to support our customers with their business needs, such as locating people, identity verification, reducing fraud and marketing solutions.

WesternPathWays has offices in —– locations; our registered head office is located within the United Kingdom.

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United Kingdom
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Company Registration Number:

Our Data Protection Officer is Kate Lewis, please contact Kate if you have any questions about how your personal information is used by WesternPathWays info@westernpathways.co.uk or …………………….

WesternPathWays review our Privacy Policy on an annual basis, sooner if changes to regulation require it or WesternPathWays changes the way it processes personal information.

This policy was last updated on 20^th Jan 2020.

What personal information do WesternPathWays collect and why?

Browsing our website: When you browse our website www.westernpathways.co.uk, we will collect the Internet Protocol (IP) address of the PC you are using, this data is anonymous and we cannot identify you at this point. We collect this data so that we can identify where customers are dropping out of the website and to identify areas of improvement to make the experience more engaging for our customers.

We use Cookies on our website so please see the Cookies section for more information.

Requesting a brochure: When you request a brochure from us, we will collect the following information from you:

Email address (so that we can send the brochure to you)
The name of your organisation (so that we can identify which sectors are showing the most interest in our products/services)
Your IP address will no longer be anonymous and we will be able to identify you

Requesting a call back: when you request a call back from us, we will collect the following information from you:

Your name (so that we contact the right individual)
Your contact telephone number (so that we contact the right individual)
Your reason for contact (this is so that we can direct your call back to the right team who will respond to you directly)
Your IP address will no longer be anonymous and we will be able to identify you

Subscribing to our marketing lists: Where you have consented to receive marketing from WesternPathWays, we will collect the following information from you:

Your name (so that we market to the right individual)
Email address (so that we send the marketing to right place)
The marketing preferences indicated by yourself, such as your areas of interest and how you want to be marketed.
Your IP address will no longer be anonymous and we will be able to identify you
A record of your consent to confirm what you have consented to and when

Conference and Events: As a global organisation, WesternPathWays attends worldwide events and have marketing team members located around the world. WesternPathWays will obtain from the event organiser a delegate list of all attendees who have consented to their personal information being shared with WesternPathWays.

Entering into an agreement with WesternPathWays: When your organisation enters into an agreement with WesternPathWays to provide products and services, we will collect additional information, which is necessary for

The performance of the contract we have with your organisation such as billing information
Providing service updates related to the product/service WesternPathWays are providing to you

All personal information we collect is held electronically within our Customer Relationship Management system (CRM) and Salesforce, located in the United Kingdom and USA.

Who will we share your personal information with and why?

WesternPathWays will share your information with third party service partners, who are acting on behalf of WesternPathWays as our data processor, the details are below of whom WesternPathWays will share your personal information with and why:

WesternPathWays has an email marketing solution, which delivers marketing emails on our behalf. We share the following personal information with

When you are browsing our website we capture the anonymous IP address
At the point that you enter all of the required personal information relating to a free trial, demo, brochure request, contact information for marketing, we will receive all of the personal information you provide via the website.

WesternPathWays can assure you that we have taken all technical and organisational measures necessary to protect the personal information, which HubSpot may access.

…………………..: provide WesternPathWays with our Customer Relationship Management (CRM) systems and they may access the live system for technical support. WesternPathWays can assure you that we have taken all technical and organisational measures necessary to protect the personal information, which …………………… may access.

Marketing and the use of your personal information.

Where you have consented to receive marketing from WesternPathWays we will only market to you via the channel you have consented to (such as email, telephone etc.). As stated above we use a third party service provider HubSpot to manage our email marketing solution. When you receive an email from WesternPathWays it will include an unsubscribe link which you can click if you wish to unsubscribe from our marketing lists. We will then add your email address to our suppression list, which will ensure you do not receive any further marketing from WesternPathWays.

Please be assured we do not sell your personal information to third party companies for marketing purposes.

Accuracy of your personal information

As part of the account management process WesternPathWays will, on a regular basis enquire if the personal information we hold about you is correct. You can also ensure your personal information is correct by:

Contacting WesternPathWays at compliance@westernpathways.co.uk
Alternatively, if your organisation has an agreement with WesternPathWays for the provision of services, you can contact your WesternPathWays account manager who will ensure they update your record on our CRM system.

Transfers outside of the European Economic Area (EEA)

As a global organisation, we have sales teams located all over the world, it will be necessary for your personal information to be transferred to them for account management activities and where you have provided consent, for marketing purposes. WesternPathWays will take appropriate technical and organisational measures to ensure the security of your personal data when processed outside of the EEA.

How long do we retain your personal information for and why?

Where we have collected your personal information for marketing purposes we will retain your personal information for as long as you remain subscribed to our mailing lists or until the time when you inform us that you no longer wish to receive marketing from us.

For account management purposes, we will retain the personal information for as long as we have the relationship with your organisation. If WesternPathWays no longer has a relationship with your organisation then we will only keep the relevant information such as invoices for audit purposes 6 years after the relationship with WesternPathWays has ended.

Once WesternPathWays are informed, you are no longer the contact we need to liaise with or you leave your organisation, we will remove your details from our system.

Security

As you will probably be aware, the internet is not a secure medium. However we have put in place various security procedures by way of reasonable measures to protect your information. We consider the security of your personal data and the details of any transactions you make to be a matter of the highest priority. Your account information is protected by your account code and password which you should keep safe at all times. In addition to your password, we generate keys which are used to authenticate your account against our servers when you are querying the database. Keys are a randomly generated and unique set of letters and numbers. If you feel that there has been a breach in the security on your licence please contact us on +44 ……………….. or by email at security@.co.uk.

Purchasing

When you place an order with us, we use a secure server. Any data you provide to us, is encrypted using a ‘Secure Socket Layer’ (SSL) session. SSL is an industry standard and is a widely used measure to guard against Internet messages being intercepted. You should be aware, however, that older browsers cannot use SSL. To be sure, you will need Netscape version 4.05 or above, Microsoft Internet Explorer version 4 or above, or any similar generation browser (e.g. Firefox, Opera). Although your account can be set up to make repeat purchases to automatically top-up your account by credit card, we do not actually store credit card details. We only hold the last 4 digits of your card, the card holder name and a reference to the last transaction made on that card from us. It is the transaction reference that is used to make repeat purchases and this can only be used between ourselves and our payment service provider, SecureTrading.

Your rights under GDPR

As an individual, you have rights under the GDPR regarding the use of your personal information, these are:

The right to withdraw consent – you can withdraw your consent at any time
The right to be forgotten – you can request that WesternPathWays remove your personal information from our systems
The right to restrict processing – you can request that WesternPathWays only process your personal information for purposes specified by yourself
The right to data portability – you can request that the personal information you have provided to WesternPathWays be ported to another organisation
The right to access your personal information – You have a right to know what personal information WesternPathWays hold on you and for what purpose we are processing your personal information this is known as a Data Subject Access Request (DSAR). These requests must be made in writing by either email or letter with photographic identification to confirm your identity.

You can send these requests to info@westernpathways.co.uk or by post to:

Privacy & Data Compliance Team
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How to complain

We appreciate that at WesternPathWays we do not always get things right and it is regrettable for us as an organisation when we receive a complaint. We take all complaints seriously and can assure you we will do our best to deliver a satisfactory outcome. If you do wish to complain about how your personal information is used by WesternPathWays then please write to us at:

Alternatively, you can email us at compliance@westernpathways.co.uk

WesternPathWays will investigate and respond within 10 working days, this allows us time to investigate your complaint thoroughly.

The right to lodge a complaint with the Supervisory Authority

Where you believe that WesternPathWays have not taken our responsibilities with your personal information seriously, you have the right to complain to the Supervisory Authority. Their details are:

Information Commissioners office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Telephone number: 0303 123 113 or 01625 545 745

Email: casework@ico.org.uk