PRIVACY POLICY
Last updated July 01, 2024
This Privacy Notice for Ultima Services
Ltd ('we', 'us', or 'our'), describes
how and why we might access, collect, store, use, and/or
share ('process') your personal information when you
use our services ('Services'), including when you:
Questions or concerns? Reading
this Privacy Notice will help you understand your privacy
rights and choices. We are responsible for making decisions
about how your personal information is processed. If you do
not agree with our policies and practices, please do not use
our Services.
SUMMARY OF KEY POINTS
This summary provides key points
from our Privacy Notice, but you can find out more details
about any of these topics by clicking the link following
each key point or by using our table
of contents below to find the section you
are looking for.
What personal information do we
process? When you visit, use, or navigate our Services,
we may process personal information depending on how you
interact with us and the Services, the choices you make, and
the products and features you use. Learn more about personal
information you disclose to us.
Do we process any sensitive personal
information? Some of the information may be
considered 'special' or 'sensitive' in certain
jurisdictions, for example your racial or ethnic origins,
sexual orientation, and religious beliefs. We do not process
sensitive personal information.
Do we collect any information from
third parties? We may collect information from public
databases, marketing partners, social media platforms, and
other outside sources. Learn more about information
collected from other sources.
How do we process your information? We
process your information to provide, improve, and administer
our Services, communicate with you, for security and fraud
prevention, and to comply with law. We may also process your
information for other purposes with your consent. We process
your information only when we have a valid legal reason to
do so. Learn more about how we process
your information.
In what situations and with
which parties do we share personal information? We may
share information in specific situations and with
specific third parties. Learn more about when
and with whom we share your personal information.
How do we keep your information
safe? We have adequate organisational and technical
processes and procedures in place to protect your personal
information. However, no electronic transmission over the
internet or information storage technology can be guaranteed
to be 100% secure, so we cannot promise or guarantee that
hackers, cybercriminals, or other unauthorised third parties
will not be able to defeat our security and improperly
collect, access, steal, or modify your information. Learn
more about how we keep your information
safe.
What are your rights? Depending
on where you are located geographically, the applicable
privacy law may mean you have certain rights regarding your
personal information. Learn more about your
privacy rights.
How do you exercise your rights? The
easiest way to exercise your rights is by submitting a data
subject access request, or by contacting us. We will
consider and act upon any request in accordance with
applicable data protection laws.
Want to learn more about what we do
with any information we collect? Review the
Privacy Notice in full.
TABLE OF CONTENTS
1. WHAT
INFORMATION DO WE COLLECT?
2. HOW DO WE PROCESS
YOUR INFORMATION?
3. WHAT LEGAL
BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?
4. WHEN AND WITH
WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
5. DO WE USE COOKIES
AND OTHER TRACKING TECHNOLOGIES?
6. HOW LONG DO WE
KEEP YOUR INFORMATION?
7. HOW DO WE KEEP
YOUR INFORMATION SAFE?
8. DO WE COLLECT
INFORMATION FROM MINORS?
9. WHAT ARE
YOUR PRIVACY RIGHTS?
10. CONTROLS FOR
DO-NOT-TRACK FEATURES
11. DO WE MAKE
UPDATES TO THIS NOTICE?
12. HOW CAN YOU
CONTACT US ABOUT THIS NOTICE?
13. HOW CAN YOU
REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
1. WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to
us
In Short: We collect
personal information that you provide to us.
We collect personal information that
you voluntarily provide to us when you express an interest
in obtaining information about us or our products and
Services, when you participate in activities on the
Services, or otherwise when you contact us.
Personal Information Provided by
You. The personal information that we collect depends on
the context of your interactions with us and the Services,
the choices you make, and the products and features you use.
The personal information we collect may include the
following:
Sensitive Information. We do not
process sensitive information.
All personal information that you
provide to us must be true, complete, and accurate, and you
must notify us of any changes to such personal information.
Information collected from other
sources
In Short: We may
collect limited data from public databases, marketing
partners, and other outside sources.
In order to enhance our ability to
provide relevant marketing, offers, and services to you and
update our records, we may obtain information about you from
other sources, such as public databases, joint marketing
partners, affiliate programs, data providers, and from other
third parties. This information includes mailing addresses,
job titles, email addresses, phone numbers, intent data (or
user behaviour data), Internet Protocol (IP) addresses,
social media profiles, social media URLs, and custom
profiles, for purposes of targeted advertising and event
promotion.
2. HOW DO WE PROCESS YOUR
INFORMATION?
In Short: We process
your information to provide, improve, and administer our
Services, communicate with you, for security and fraud
prevention, and to comply with law. We may also process your
information for other purposes with your consent.
We process your personal information
for a variety of reasons, depending on how you interact with
our Services, including:
3. WHAT LEGAL BASES DO WE RELY ON TO
PROCESS YOUR INFORMATION?
In Short: We only
process your personal information when we believe it is
necessary and we have a valid legal reason (i.e. legal
basis) to do so under applicable law, like with your
consent, to comply with laws, to provide you with services
to enter into or fulfil our contractual obligations, to
protect your rights, or to fulfil our legitimate business
interests.
The General Data Protection Regulation
(GDPR) and UK GDPR require us to explain the valid legal
bases we rely on in order to process your personal
information. As such, we may rely on the following legal
bases to process your personal information:
In legal terms, we are generally
the 'data controller' under European data protection laws of
the personal information described in this Privacy Notice,
since we determine the means and/or purposes of the data
processing we perform. This Privacy Notice does not apply to
the personal information we process as a 'data processor' on
behalf of our customers. In those situations, the customer
that we provide services to and with whom we have entered
into a data processing agreement is the 'data
controller' responsible for your personal information, and
we merely process your information on their behalf in
accordance with your instructions. If you want to know more
about our customers' privacy practices, you should read
their privacy policies and direct any questions you have to
them.
4. WHEN AND WITH WHOM DO WE SHARE
YOUR PERSONAL INFORMATION?
In Short: We may share
information in specific situations described in this section
and/or with the following third parties.
Vendors, Consultants, and Other
Third-Party Service Providers. We may share your data
with third-party vendors, service providers, contractors, or
agents ('third parties') who perform services for us
or on our behalf and require access to such information to
do that work. We have contracts in place with our third
parties, which are designed to help safeguard your personal
information. This means that they cannot do anything with
your personal information unless we have instructed them to
do it. They will also not share your personal information
with any organisation apart from us. They also commit to
protect the data they hold on our behalf and to retain it
for the period we instruct.
The third parties we may share personal
information with are as follows:
Google AdSense
Google Cloud AI
Google Site Search
Dropbox Backup and Google Drive Backup
We also may need to share your personal
information in the following situations:
5. DO WE USE COOKIES AND OTHER
TRACKING TECHNOLOGIES?
In Short: We may use
cookies and other tracking technologies to collect and store
your information.
We may use cookies and similar tracking
technologies (like web beacons and pixels) to gather
information when you interact with our Services. Some online
tracking technologies help us maintain the security of our
Services, prevent crashes, fix bugs, save your preferences,
and assist with basic site functions.
We also permit third parties and
service providers to use online tracking technologies on our
Services for analytics and advertising, including to help
manage and display advertisements, to tailor advertisements
to your interests, or to send abandoned shopping cart
reminders (depending on your communication preferences). The
third parties and service providers use their technology to
provide advertising about products and services tailored to
your interests which may appear either on our Services or on
other websites.
Specific information about how we use
such technologies and how you can refuse certain cookies is
set out in our Cookie Notice.
Google Analytics
We may share your information with
Google Analytics to track and analyse the use of the
Services. The Google Analytics Advertising Features that we
may use include: Remarketing with Google Analytics, Google
Analytics Demographics and Interests Reporting and Google
Display Network Impressions Reporting. To opt out of being
tracked by Google Analytics across the Services, visit https://tools.google.com/dlpage/gaoptout. You
can opt out of Google Analytics Advertising Features
through Ads
Settings and Ad Settings for mobile apps. Other opt out
means include http://optout.networkadvertising.org/ and http://www.networkadvertising.org/mobile-choice. For
more information on the privacy practices of Google, please
visit the Google
Privacy & Terms page.
6. HOW LONG DO WE KEEP YOUR
INFORMATION?
In Short: We keep your
information for as long as necessary to fulfil the purposes
outlined in this Privacy Notice unless otherwise required by
law.
We will only keep your personal
information for as long as it is necessary for the purposes
set out in this Privacy Notice, unless a longer retention
period is required or permitted by law (such as tax,
accounting, or other legal requirements).
When we have no ongoing legitimate
business need to process your personal information, we will
either delete or anonymise such information, or, if this is
not possible (for example, because your personal information
has been stored in backup archives), then we will securely
store your personal information and isolate it from any
further processing until deletion is possible.
7. HOW DO WE KEEP YOUR INFORMATION
SAFE?
In Short: We aim to
protect your personal information through a system
of organisational and technical security measures.
We have implemented appropriate and
reasonable technical and organisational security measures
designed to protect the security of any personal information
we process. However, despite our safeguards and efforts to
secure your information, no electronic transmission over the
Internet or information storage technology can be guaranteed
to be 100% secure, so we cannot promise or guarantee that
hackers, cybercriminals, or other unauthorised third parties
will not be able to defeat our security and improperly
collect, access, steal, or modify your information. Although
we will do our best to protect your personal information,
transmission of personal information to and from our
Services is at your own risk. You should only access the
Services within a secure environment.
8. DO WE COLLECT INFORMATION FROM
MINORS?
In Short: We do not
knowingly collect data from or market to children under 18
years of age.
We do not knowingly collect, solicit
data from, or market to children under 18 years of age, nor
do we knowingly sell such personal information. By using the
Services, you represent that you are at least 18 or that you
are the parent or guardian of such a minor and consent to
such minor dependent’s use of the Services. If we learn that
personal information from users less than 18 years of age
has been collected, we will deactivate the account and take
reasonable measures to promptly delete such data from our
records. If you become aware of any data we may have
collected from children under age 18, please contact us
at mark@ultimasvs.com.
9. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: In some
regions, such as the European Economic Area (EEA), United
Kingdom (UK), and Switzerland, you have rights that allow
you greater access to and control over your personal
information. You may review, change, or terminate your
account at any time, depending on your country, province, or
state of residence.
In some regions (like the EEA, UK, and
Switzerland), you have certain rights under applicable data
protection laws. These may include the right (i) to request
access and obtain a copy of your personal information, (ii)
to request rectification or erasure; (iii) to restrict the
processing of your personal information; (iv) if applicable,
to data portability; and (v) not to be subject to automated
decision-making. In certain circumstances, you may also have
the right to object to the processing of your personal
information. You can make such a request by contacting us by
using the contact details provided in the section 'HOW
CAN YOU CONTACT US ABOUT THIS NOTICE?' below.
We will consider and act upon any
request in accordance with applicable data protection laws.
If you are located in the EEA or UK and
you believe we are unlawfully processing your personal
information, you also have the right to complain to your Member
State data protection authority or UK
data protection authority.
If you are located in Switzerland, you
may contact the Federal
Data Protection and Information Commissioner.
Withdrawing your consent: If we
are relying on your consent to process your personal
information, you have the right to withdraw your consent at
any time. You can withdraw your consent at any time by
contacting us by using the contact details provided in the
section 'HOW CAN YOU CONTACT US ABOUT
THIS NOTICE?' below.
However, please note that this will not
affect the lawfulness of the processing before its
withdrawal nor, will it affect the processing of your
personal information conducted in reliance on lawful
processing grounds other than consent.
Opting out of marketing and
promotional communications: You can unsubscribe from our
marketing and promotional communications at any time
by clicking on the unsubscribe link in the emails that we
send, replying 'STOP' or 'UNSUBSCRIBE' to the SMS messages
that we send, or by contacting us using the details provided
in the section 'HOW CAN YOU CONTACT US
ABOUT THIS NOTICE?' below. You will then be removed from
the marketing lists. However, we may still communicate with
you — for example, to send you service-related messages that
are necessary for the administration and use of your
account, to respond to service requests, or for other
non-marketing purposes.
Cookies and similar technologies: Most
Web browsers are set to accept cookies by default. If you
prefer, you can usually choose to set your browser to remove
cookies and to reject cookies. If you choose to remove
cookies or reject cookies, this could affect certain
features or services of our Services.
10. CONTROLS FOR DO-NOT-TRACK
FEATURES
Most web browsers and some mobile
operating systems and mobile applications include a
Do-Not-Track ('DNT') feature or setting you can activate to
signal your privacy preference not to have data about your
online browsing activities monitored and collected. At this
stage, no uniform technology standard for recognising and
implementing DNT signals has been finalised. As such, we do
not currently respond to DNT browser signals or any other
mechanism that automatically communicates your choice not to
be tracked online. If a standard for online tracking is
adopted that we must follow in the future, we will inform
you about that practice in a revised version of this Privacy
Notice.
11. DO WE MAKE UPDATES TO THIS
NOTICE?
In Short: Yes, we will
update this notice as necessary to stay compliant with
relevant laws.
We may update this Privacy Notice from
time to time. The updated version will be indicated by an
updated 'Revised' date at the top of this Privacy Notice. If
we make material changes to this Privacy Notice, we may
notify you either by prominently posting a notice of such
changes or by directly sending you a notification. We
encourage you to review this Privacy Notice frequently to be
informed of how we are protecting your information.
12. HOW CAN YOU CONTACT US ABOUT
THIS NOTICE?
If you have questions or comments about
this notice, you may email us at mark@ultimasvs.com
or contact us by post at:
Ultima Services Ltd
10 towerfield Rd
Shoeburyness SS3 9QE
England
If you are a resident in the United
Kingdom, we are the 'data controller' of your personal
information. We have appointed Mark Pinnock to be our
representative in the UK. You can contact them directly
regarding our processing of your information, by email
at mark@ultimasvs.com, by phone at 07502 433866, or by post
to:
10 towerfield Rd
Shoeburyness SS3 9QE
England
13. HOW CAN YOU REVIEW, UPDATE, OR
DELETE THE DATA WE COLLECT FROM YOU?
Based on the applicable laws of your
country, you may have the right to request access to the
personal information we collect from you, details about how
we have processed it, correct inaccuracies, or delete your
personal information. You may also have the right
to withdraw your consent to our processing of your personal
information. These rights may be limited in some
circumstances by applicable law. To request to review,
update, or delete your personal information, please fill out
and submit a data
subject access request.