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1st Class Protection: Privacy Policy

1. Purpose This policy will advise you on how 1st Class Protection collects and processes your personal data via this website including purchasing a service or when you make any contact with us. Please note this website is not intended for children and we do not knowingly collect data related to children. Please ensure you read this policy so that you are fully aware of how and why we use your data. Controller: 1st Class Protection Ltd is the data controller and is responsible for your personal data. For EU data protection purposes our ICO registration is ZA311484. If you need any further information about this Privacy & Security Policy including any requests to exercise your legal rights please contact the Data Privacy Manager using the details below: Olga Mordukhay 1st Floor Buckingham House 45 Vivan Avenue Hendon NW4 3XA Tel: 020 8457 4722 In the first instance we would appreciate you contact us with any initial concerns or complaints. However, you have the right to make a complaint to the Information Commissioners Office (ICO) which is the UK supervisory body for data protection issues. Full details can be found here: Changes to the privacy notice This data protection law in the UK changed on 25th May 2018 and this Policy is updated in line with the new law. 3rd Party Links Our website may have links to 3rd party websites, plug-ins and applications. Clicking on these links may allow 3rd parties to collect or share data about you. We do not control these 3rd party websites and 1st Class Protection are not responsible for their Privacy Policies.

2. Data we collect about you Personal data covers any information about an individual from which that person can be identified. It does not include anonymous data where the identity has been removed. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together including: • Identity Data: including first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender. • Contact Data: includes billing address, home address, work address, email address and telephone numbers. • Financial Data: includes bank account and payment card details. • Transaction Data: includes details about payments to and from you and other details of services you have purchased from us. • Technical Data: includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website. • Profile Data: purchases or orders made by you, your interests/preferences, feedback and survey responses. • Usage Data: includes information about how you use our website, products and services. • Marketing and Communications Data: includes your preferences in receiving marketing from us and your communication preferences. We may also collect and use Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. We do not collect Special Categories of personal data including race, sexual orientation, health, genetic, religious beliefs or information about criminal convictions/offences.

3. How is your personal data collected? Different methods of data collection we use include: Direct correspondence/interaction – filling in forms, post, phone, email or otherwise. This includes personal data you provide when you apply for our security services, subscribe to any additional services, request marketing to be sent to you or give us feedback. Information collected automatically – as you browse our website we may automatically collect data about your equipment, browsing patterns, IP address, device type and browsing actions. This data is collected via cookies, server logs and other methods. We may also receive technical data about you if you visit other websites using our cookies.

4. How we use your personal data Your personal data will only be used where the law allows. The main purposes we will use your personal data for are: • Where we need to perform a contract we are about to or have entered into with you. • Where it is needed for our legitimate interests (or those of a 3rd party) and your interests/rights do not override those interests. • Where we need to comply with legal or regulatory obligation Please note that you have the right to withdraw consent to marketing any time by contacting the data controller. If we do not collect your personal data we may be unable to provide all of our services and some functions on our website may not be available to you. Listed are the ways we may use your personal data and the lawful bases for doing so: Communication – Providing you with information you have requested from us or information we are required to send to you; operational communications such as changes to our website or services, security updates, assistance with our website and/or services. Marketing – will be in accordance with your marketing preferences. Feedback – Any research or feedback from you Support –This may include assisting with the resolution of technical issues relating to the website or services Protection – To allow us to detect any fraudulent or malicious activity and to ensure everyone is using our website or services fairly. Report – We may use personal data we collect to produce anonymised analytics and reports. THIRD PARTIES

5. Disclosure We may need to share your personal data with the parties below: • Internal 3rd parties • External 3rd parties – listed below • 3rd parties to whom we may sell, transfer, merge with may use your personal data in the same way as noted in this policy We do not allow 3rd parties to use your personal data for their own purposes. NAME SERVICE TYPE DATA PROCESSED Google Cloud software Instances of customer name/email DropBox Cloud Storage Instances of customer name/email MailChimp Marketing Platform Instances of customer name/email Disqus Blog comment host Instances of customer name/email Reboot SEO (See technical data in Section 2)

6. International Transfers When we share data it may be transferred and processed in countries other than where you reside and outside the European Economic Area (EEA). These countries may have differing laws and we will endeavour to put safeguards in place to ensure your personal data remains protected under binding corporate rules.

7. Data Security 1st Class Protection are committed to protecting your personal data and have the necessary technical measures in place to ensure this happens. Procedures have been put in place to deal with any breaches of data.

8. Data Retention We will only keep your personal data for the duration necessary to fulfil the purposes we collected this for such as legal or accounting. Legally we are required to keep basic information about our customers past or present, for 6 years for HMRC. Following this period, we will ensure it is deleted or anonymised.

9. Your Rights You have certain rights to your personal data. If you do not wish to receive marketing communications from us you can follow the unsubscribe instructions contained in the communication. You have rights to: • Know what personal data we hold about you and request a correction of data • Request a copy of your personal data • Withdraw consent • Restrict processing your personal data or delete it • Object to us processing your personal data Please let us know via email if you wish to exercise any of your rights above to Please note that as a security measure we may need to request specific information from you to confirm your identity prior to you exercising your rights. We will do our best to respond to legitimate requests within 28 days, however for more complex enquiries this may take longer.

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