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Website Visitors

If you visit our website, we may collect information about you as follows:

• Server logs: Every time your web browser requests a page, image, file or other data from our servers, the request is logged. This includes your IP address, the date and time, your “user agent string” (which contains basic information about the software and device you are using), the address of the page that referred you to our website (if the software you are using has supplied it), and some technical details about the HTTP request. It is in our legitimate interests to collect this data to prevent malicious use of our services, monitor server performance, increase security, and diagnose problems. This information is only used within the organisation and is retained for up to one year.
• Website analytics: We use Google Analytics to analyse how visitors use our website. This stores a “cookie” on your computer containing an anonymous tracking ID to allow Google to track your activity around our website. This service is subject to Google’s Privacy Policy. We have taken steps to ensure that you are not personally identifiable to Google Analytics, including the anonymisation of your IP address and preventing Google from sharing our Analytics data with its other services. The information associated with your cookie tracking ID is deleted 14 months after your last use of our website. Learn more about how you can control the information sent to Google.
• Paying invoices: When you pay an invoice through our website, any personal information (including financial information) you enter is submitted directly to a third-party payment provider by your web browser, and your relationship is direct with the relevant payment provider and subject to their privacy policies. The payment providers allow us to view your name, contact information, and basic transaction information, which we use to match the payment to the relevant invoice. We do not store your personal information at any point in this process. Card payments are processed by Stripe (privacy policy) and Direct Debits by GoCardless (privacy policy).

Clients

If you are one of our clients, we may use your personal information in the following ways:

• Accounts: We store and use the name and contact details of clients in our accounting software so that we can invoice and identify clients, chase late payments, and undertake other necessary administrative tasks. This is necessary in order to fulfil the contract. Only Hiltonian Media Ltd has access to this information, and it is retained for between seven and eight years since the client’s last transaction.
• Communicating with customers: It is necessary to send occasional emails to customers to inform them of changes to their contract, the services they are receiving, pricing, etc. The information used is derived from the information held in our accounting software. This is usually necessary to fulfil the contract, but in some cases it may be in our legitimate interests to communicate other important service information to customers. At the present time this information is not processed by any third party, but if that changes any affected individuals will be informed.
• Domain name registration: To register domain names on behalf of clients, we have to supply information about the domain name owner to the relevant registry or registrar. Without this information, the domain name cannot be registered. The information includes the client’s name and contact details. From 25 May 2018, this information will no longer be made public by the registry/registrar. For UK domain names, the registry is Nominet (privacy policy), and for most other domain names the registrar is OpenSRS, which is based in Canada (privacy policy). Where a different registry/registrar is used, this will be communicated before the domain name is registered. The use of this information is necessary to fulfil the contract and will be retained for as long as the domain name is registered (or longer, if specified in the privacy policies linked above).
• Webmail: If you use our webmail systems, your name, email address and any other information you supply will be stored to facilitate your use of the webmail software. It is in our legitimate interests to provide you with a webmail service and allow you to input and store information. The information is not used for any other purpose and is retained for as long as you (or the organisation paying for your hosting account) is a customer. If you use the service to store personal information about any other individual (in the address book, for example), you must request their permission to do so, and delete it if they ask you to.
• Email server configuration: If you use our servers for email services, relevant email addresses will be stored in the email server configuration. This is necessary in order to fulfil the contract. Only Hiltonian Media Ltd has access to this information, and it is deleted at the end of the contract.
• Content Management System: Clients who use our Content Management System require one or more logins to allow administrators to log in to make modifications to the website. The user profile consists of name, email address and login credentials, plus any other information the website owner decides is necessary to collect. It is in our legitimate interests to allow website owners flexibility over who can modify their website. This information can be accessed by Hiltonian Media Ltd and any other users of the Content Management System who have been given sufficient permission by the website owner, and is deleted at the end of the contract.
• Hosting logins: Login credentials are stored for hosting accounts to allow the owner to log in to the service. This is necessary in order to fulfil the contract. Only Hiltonian Media Ltd has access to this information, and it is deleted at the end of the contract.

Your Rights

Depending on why we use your data, you have various rights under the GDPR. These are:

• The right to be informed about the use of your data. This privacy policy forms part of that obligation.
• The right to access your personal data or confirm that it is being processed.
• The right to rectify any inaccurate personal data or complete any incomplete personal data.
• The right to have any personal data erased or restrict its processing in some circumstances.
• The right to object to the use of your personal data, but only if we are processing your data for legitimate interests (rather than, for example, to fulfil a contract).
• The right to data portability of personal data they have provided to a controller, but only if we are processing the information on the basis of consent or to fulfil a contract, and when the processing is carried out by automated means.

To exercise any of these rights, please contact us. Where a request is unfounded or excessive, or you are requesting information we have already provided to you, we may charge a reasonable fee to fulfil the request or refuse to respond. We will take reasonable steps to verify your identity before fulfilling the request, and we will respond within one month.

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