We are Ability2code Ltd. We’re a company registered in England and Wales with company number 09212051, whose registered address is at 49 Coleshill Road Marston Green Birmingham B37 7HT. In this privacy notice, we will refer to ourselves as ‘we’, ‘us’ or ‘our’.
You can get hold of us in any of the following ways:
We take the privacy, including the security, of the personal information we hold about you seriously. This privacy notice is designed to inform you about how we collect personal information about you and how we use that personal information. You should read this privacy notice carefully so that you know and can understand why and how we use the personal information we collect and hold about you.
We do not have a Data Protection Officer, but if you have any questions about this privacy notice or issues arising from it then you should contact Emran, who is responsible for matters relating to data protection at our organisation, including any matters in this privacy notice. You can contact them using the details set out above.
We may issue you with other privacy notices from time to time, including when we collect personal information from you. This privacy notice is intended to supplement these and does not override them.
We may update this privacy notice from time to time. This version was last updated on 01/02/2023.
The key terms that we use throughout this privacy notice are defined below, for ease:
Data Controller: under UK data protection law, this is the organisation or person responsible for deciding how personal information is collected and stored and how it is used.
Data Processor: a Data Controller may appoint another organisation or person to carry out certain tasks in relation to the personal information on behalf of, and on the written instructions of, the Data Controller. (This might be the hosting of a site containing personal data, for example, or providing an email marketing service that facilitates mass distribution of marketing material to a Data Controller’s customer-base.)
Personal Information: in this privacy notice we refer to your personal data as ‘personal information’. ‘Personal information’ means any information from which a living individual can be identified. It does not apply to information which has been anonymised.
Special Information: certain very sensitive personal information requires extra protection under data protection law. Sensitive data includes information relating to health, racial and ethnic origin, political opinions, religious and similar beliefs, trade union membership, sex life and sexual orientation and also includes genetic information and biometric information.
2.1 Set out below are the general categories and details of retention periods in relation to those categories (see section 8 below for more details about retention and in each case, the types of personal information which we collect, use, and hold about you:
| General Category | Types of Personal Data in that category | Retention Periods |
|---|---|---|
| Identity Information | This is information relating to your identities such as your name (including any previous names and any titles which you use) | 30 days unless it becomes part of an email conversation. Then will be held indefinitely until the request for removal has been raised. |
| Contact Information | This is information relating to your contact details such as e-mail address, addresses, telephone numbers | 30 days unless it becomes part of an email conversation. Then will be held indefinitely until the request for removal has been raised. |
2.2 The types of personal data we collect about you may differ from person to person, depending on who you are and the relationship between us.
3.1 Special information is explained in section 1 above. We do not collect or hold any special information about you.
3.2 We do not collect information from you relating to criminal convictions or offenses.
4.1 We are only able to use your personal information for certain legal reasons set out in data protection law. There are legal reasons under data protection law other than those listed below, but in most cases, we will use your personal information for the following legal reasons:
4.2 As explained in section 3 above, there are more sensitive types of personal data that require higher levels of protection. When we process such sensitive types of personal data we will usually do this in the following circumstances:
4.3 So that we are able to provide you with services, we will need your personal information. If you do not provide us with the required personal information, we may be prevented from supplying the services to you.
4.4 It is important that you keep your personal information up to date. If any of your personal information changes, please contact us as soon as possible to let us know. If you do not do this then we may be prevented from supplying the services to you.
4.5 Where we rely on consent for a specific purpose as the legal reason for processing your personal information, you have the right under data protection law to withdraw your consent at any time. If you do wish to withdraw your consent, please contact us using the details set out at the beginning of this notice. If we receive a request from you withdrawing your consent to a specific purpose, we will stop processing your personal information for that purpose, unless we have another legal reason for processing your personal information, in which case, we will confirm that reason to you.
4.6 We have explained below the different purposes for which we use your personal information and, in each case, the legal reason(s) for allowing us to use your personal information. Please also note the following
| Purpose | Legal Reason(s) for using the personal information |
|---|---|
| To register a customer as a new customer (including contacting those who have started the signup process but have not completed it). | (a) Contract Reason.(b) Legitimate Interests Reason (because of a contract we have entered or are about to enter into with a customer in order to fulfil that contract, which is in our and their legitimate interests). |
| To carry out our obligations to a customer under our contract with them, including providing them with products and services which they request from us. | (a) Contract Reason.(b) Legitimate Interests Reason (because of a contract we have entered into with a customer in order to fulfil that contract, which is in our and their legitimate interests). |
| To manage our relationship with a customer which will include:(a) Notifying a customer about changes to our terms or privacy policy(b) Asking a customer to leave a review or take a survey | (a) Contract Reason(b) Legal Obligations Reason.(c) Legitimate Interests Reason (to keep our records updated and to study how customers use our products/services) |
| To allow a customer to participate in interactive features of our website. | (a) Contract Reason(b) Legitimate Interests Reason (because of a contract we have entered into with a customer in order to fulfil that contract, which is in our and their legitimate interests). |
| To provide customer service and support. | (a) Contract Reason(b) Legitimate Interests Reason (because of a contract we have entered into with a customer in order to fulfil that contract, which is in our and their legitimate interests and to ensure that we give the best customer service to our customers) |
| To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | (a) Legitimate Interests Reason (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)(b) Legal Obligations Reason. |
| To monitor the use of our website. | Legitimate Interests Reason (to ensure that our website is being used in accordance with our acceptable use policy) |
| To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you | Legitimate Interests Reason (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) |
| To use data analytics to improve our website, products/services, marketing, customer relationships and experiences | Legitimate Interests Reason (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
4.7 Sometimes we may anonymise personal information so that you can no longer be identified from it and use this for our own purposes. In addition, sometimes we may use some of your personal information together with other people’s personal information to give us statistical information for our own purposes. Because this is grouped together wither other personal information and you are not identifiable from that combined data we are able to use this.
4.8 Under data protection laws we can only use your personal information for the purposes we have told you about unless we consider that the new purpose is compatible with the purpose(s) which we told you about. If we want to use your personal information for a different purpose that we do not think is compatible with the purpose(s) that we told you about then we will contact you to explain this and what legal reason is in place to allow us to do this.
5.1 We usually collect Identity Information, Contact Information, directly from you when you fill out a form, contact us by e-mail, telephone, in writing, or otherwise. This includes the personal information which you provide to us when you subscribe to our mailing list.
5.2 We may receive some of your personal information from third parties or publicly available sources. This includes:
5.3 We may also receive Website, Device, and Technical Information automatically from technologies such as cookies that are installed on our website. To find out more about these please see our cookie policy which is available here
6.1 We may need to share your personal information with other organisations or people. These organisations include:
6.2 Depending on the circumstances, the organisations or people whom we share your personal information with will be acting as either Data Processors or Data Controllers. Where we share your personal information with a Data Processor we will ensure that we have in place contracts, which set out the responsibilities and obligations of us and them, including in respect of the security of personal information.
6.3 We do not sell or trade any of the personal information which you have provided to us.
7.1 We do not transfer your personal information outside of the EEA.
8.1 We will only hold your personal data for as long as is necessary. How long is necessary will depend upon the purposes for which we collected the personal information (see section 4 above) and whether we are under any legal obligation to keep the personal information (such as in relation to accounting or auditing records or for tax reasons). We may also need to keep personal information in case of any legal claims, including in relation to any guarantees or warranties which we have provided with the services and digital content.
8.2 We have set out above the details of our retention periods for different types of data. You can find them in section 2 and also in section 3
9.1 Under data protection laws you have certain rights in relation to your personal information, as follows:
9.2 In addition to the rights set out in section 10.1, where we rely on consent as the legal reason for using your personal information, you have the right to withdraw your consent. Further details about this are set out in section 4.5.
9.3 If you want to exercise any of the above rights in relation to your personal information, please contact us using the details set out at the beginning of this notice. If you do make a request then please note:
10.1 You may receive marketing from us about similar goods and services, where either you have consented to this, or we have another legal reason by which we can contact you for marketing purposes.
10.2 However, we will give you the opportunity to manage how or if we market to you. In any e-mail which we send to you, we provide a link to either unsubscribe or opt-out, or to change your marketing preferences. To change your marketing preferences, and/or to request that we stop processing your personal information for marketing purposes, you can always contact us at the details set out at the beginning of this notice.
10.3 If you do request that we stop marketing to you, this will not prevent us from sending communications to you which are not have to do with marketing (for example in relation to services and digital content which you have purchased from us).
10.4 We do not pass your personal information on to any third parties for marketing purposes.
If you are unhappy about the way that we have handled or used your personal information, you have the right to complain to the UK supervisory authority for data protection, which is the Information Commissioner’s Office (ICO). Please do contact us in the first instance if you wish to raise any queries or make a complaint in respect of our handling or use of your personal information so that we have the opportunity to discuss this with you and take steps to resolve the position. You can contact us using the details set out at the beginning of this privacy notice