Limitless respects your privacy and is committed to protecting your privacy and personal data.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
WHO WE ARE
We are bound by applicable data protection laws in respect of the handling and collection of your personal data. Limitless is registered as a data controller in England and Wales, with the Information Commissioner’s Office (ICO) under the ICO number ZA190183.
WHAT INFORMATION DOES LIMITLESS COLLECT ABOUT YOU?
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identifiers have been removed (anonymous data) or data relating to a corporate entity.
If you visit our Website, or contact us to enquire about our services or are a making use of our services, we may collect, use, store and transfer different kinds of personal data about you, which we have grouped together as follows:
- Identity Data includes first name, last name and title.
- Contact Data includes email address, telephone number(s) and address.
- Usage Data includes information and details about your visits to and use of the Website including, but not limited to traffic data, location data, weblogs and other such usage data, including any records of your correspondence with us via or about the Website, as well as your use of the Website for systems administration and quality control purposes.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We do not collect any Special Categories of Personal Data about you via the Website (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
Our Website is not intended to be used by children and we therefore do not knowingly collect or process the personal data of anyone under the age of 18.
HOW DOES LIMITLESS COLLECT YOUR PERSONAL DATA?
We use different methods to collect data from and about you including through:
Direct interactions: You may give us your Identity and Contact Data by filling in forms or by corresponding with us via our Website, by email, telephone, post or otherwise. This includes personal data you provide when you:
- contact us for further information via our Website;
- subscribe to our publications;
- request marketing to be sent to you;
- enter a survey; or
- give us some feedback.
Automated technologies or interactions: As you interact with our Website, we may automatically collect Usage and Technical Data about your equipment, browsing actions and patterns of use. We collect this personal data by using cookies and other similar technologies.
HOW DOES LIMITLESS USE INFORMATION ABOUT YOU?
Limitless will only use your personal data when the law allows us to. The types of lawful basis for processing personal data that we rely on are:
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Consent means agreement which must be freely given, specific, informed and be an unambiguous indication of your wishes by which you, by a statement or by a clear positive action, signify agreement to the processing of personal data relating to you.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending our newsletters and/or marketing to you via email or text message. You have the right to withdraw consent to newsletters and other marketing at any time by contacting us.
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below:
|Purpose/Activity||Type of Data||Lawful basis for processing (including basis of legitimate interest)|
| Identity Data |
| To manage our relationship with you which will include: |
(b) asking you to leave a review or take a survey
| Necessary to comply with a legal obligation |
Necessary for our legitimate interests (to keep our records updated and to study how individuals use our products/services)
|To administer and protect our business and website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||Identity Data |
|Necessary for our legitimate interests (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) |
Necessary to comply with legal obligation
|To deliver relevant website content and measure or understand the effectiveness of the consent we serve to you||Identity Data |
Marketing and Communications Data
|Necessary for our legitimate interest (to study how individuals 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||Usage Data |
|Necessary for our legitimate interests (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)|
|To process and deal with any complaints or enquiries made by or about you||Identity Data |
|Necessary to comply with a legal obligation |
Necessary for our legitimate interests to provide you with the best experience possible
|To carry out Limitless’ obligations arising from any contracts entered into between you and us||Identity Data |
Limitless may obtain information about your use of the Website by using cookies or other such devices. Cookies contain a small amount of data information that is transferred to your computer’s hard drive. This helps us to improve the Website and to deliver a better and more personalised service.
Cookies which are strictly necessary for the operation of the website – functional cookies
Some of the cookies Limitless uses are essential for parts of the Website to operate and are already set. These are strictly necessary for the use of the Website by you and without them the Website cannot operate as intended.
The types of functional cookies we use are set out in the table below:
|_faf||User verification||When session ends|
|_logged_in_faf||Logged in user||When session ends|
Other uses of cookies (where you have consented to such use) – non-functional cookies:
We only use (and store) non-functional cookies on your computer’s browser or hard drive if you provide your consent. You have the option turn off the non-functional cookies when using our Website if you desire. Where you consent to us using and storing non-functional cookies as above, Limitless may also use such cookies and other such devices to compile anonymous, aggregated statistics that allows Limitless to understand how users use the Website and to help Limitless improve the structure of the Website (Limitless cannot identify you personally in this way). For example, Limitless may use such cookies and other such devices to allow Limitless to understand who has seen which pages on the Website, to determine how frequently particular pages are visited, to determine the most popular areas of the Website and generally in order to monitor usage of the Website.
- allow you to carry information across pages of the website and avoid having to re-enter information;
- to allow us to tailor content to match your preferred interests or to avoid showing you the same content repeatedly;
- speed up searches; and/or
- within research surveys to ensure you are not invited to complete a questionnaire too often or after you have already done so.
If we currently use any such non-essential cookies, these are set out in the table below:
|_ga||Google Analytics||24 Months|
|gadwp_wg_default_dimension||Google Analytics plugin||7 Days|
|gadwp_wg_default_metric||Google Analytics plugin||7 Days|
Find out how to disable/enable cookies by clicking on the “Manage Cookies” section of the Interactive Advertising Bureau UK website on the following link.
WILL LIMITLESS SHARE YOUR INFORMATION WITH THIRD PARTIES?
Information stored or collected regarding you helps us improve and offer
For the purposes set out above, Limitless may have to share your personal data with the following parties:
- External Third Parties such as service providers who provide IT and system administration services; or professional advisors including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, legal, banking, accounting and insurance services; or HM Revenue & Customs, regulators or their authorities based in the United Kingdom who require reporting of processing in certain activities.
WHERE DOES LIMITLESS STORE YOUR PERSONAL DATA?
3.1 Any request you make of our site or personnel allows us to use
The data that Limitless collects from you will be stored on servers in the EU. The data that Limitless collects from you may be transferred to, and stored at, a destination outside the EU.
Whenever we transfer your personal data out of the EU, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EU.
SECURITY/HOW DOES LIMITLESS PROTECT YOUR INFORMATION?
Limitless endeavours to take all reasonable steps to protect your personal data. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. Where possible, Limitless uses industry-standard Secure Sockets Layer (SSL) technology to allow for the encryption of our personal data. Unfortunately, the transmission of information via the internet is not completely secure. Although Limitless will do its best to protect your personal data, Limitless cannot guarantee the security of your data transmitted via the internet; any transmission is at your own risk. Once Limitless has received your information, Limitless will use strict procedures and security features to try to prevent unauthorised access.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Where we have processed your personal data to provide you with marketing communications with consent, we may contact you at least every 12 (twelve) months, to ensure you are happy to continue receiving such communications. If you tell us that you no longer wish to receive such communications, your personal data will be removed from our marketing lists (but will be added to a “do not contact” list).
Where we have processed your data for any other reason (such as where you have contacted us with a question in connection with services), subject to the following paragraph, we will retain your data for 12 (twelve) months.
In some circumstances you can ask us to delete your data: see section 11 below for further information.
In some circumstances, we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
YOUR LEGAL RIGHTS
Third party links may be discovered on our site. Any such third party links may have their own privacy policies, which you agree to when you click on the link. We are not responsible nor do we accept responsibility for third party links.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These rights are detailed below
- Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us directly.
No fee usually required. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Our full details are:
Full name of legal entity: Limitless Technology Limited
Company Number: 10056048
Data Protection Officer: Megan Neale
Email address: firstname.lastname@example.org
Postal address: 1-2 Hatfields, Waterloo, London, SE1 9PG, United Kingdom.
Telephone number: + 44 07946322405
You can also email us with any questions, queries or complaints at email@example.com
You have the right to make a complaint at any time to the ICO, the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.