Privacy policy

Website privacy policy

Introduction

Welcome to our privacy policy.

Service City Limited (collectively referred to as "the Company", "we", "us" or "our" in this privacy policy) respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

 Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.

1. Important information and who we are

Purpose of this privacy policy

This privacy policy aims to give you information on how the Company collects and processes your personal data through your use of this website (“the Site”), including any data you may provide through the Site when you sign up to it, and when you order services through the Site.

The Site is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.

Controller

Service City Limited is the controller and responsible for your personal data. Service City Limited is a company incorporated in England and Wales. Our company registration number is 12273952 and our registered office is at 71- 75 Shelton Street, London, WC2H 9JQ.

We have appointed a data protection officer (“DPO”) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, please contact the DPO:

Full name: Will Gaze

Email address: support@servicecity.co.uk

Postal address: 71- 75 Shelton Street, London, WC2H 9JQ

You have the right to make a complaint at any time to the Information Commissioner's Office (“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.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review.

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.

Third-party links

The Site may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave the Site, we encourage you to familiarise yourself with the privacy policy of every website you visit.

2. The data we 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 identity has been removed (anonymous data).

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, maiden name, last name, username or similar identifier, title, date of birth, gender and marital status.

Contact Data includes billing address, delivery 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 the Site.

• Profile Data includes your username and password, Orders made by you, your interests, preferences, feedback and survey responses.

• Usage Data includes information about how you use the Site.

Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data willnot directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (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.

If you fail to provide personal data 

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel an order for services you have with us but we will notify you if this is the case at the time.

 3. How is your personal data collected?

We use different methods to collect data from and about you including through:

 Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us through the Site, or by instant message or email, or by post or phone. This includes personal data you provide when you:

 • create an account on the Site;

 

 • order the Services;

 • request marketing to be sent to you;

 • give us feedback or contact us; or

 • enter a competition, promotion or survey.

• Location Data. We also use GPS technology to determine your current location. Some of our location-enabled Services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose.

• Automated technologies or interactions. As you interact with the Site, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy for further details.

• Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:

• Technical Data from analytics providers, advertising networks, and search information providers;

• Contact, Financial and Transaction Data from providers of technical, payment and delivery services;

• Identity and Contact Data from data brokers or aggregators; and

• Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register.

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

 • Where we need to perform the order for services that we are about to enter into or have entered into with you;

• Where it is necessary for our legitimate interests (or those of a third party), and your interests and fundamental rights do not override those interests;

 • Where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

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

To register you as a new customer.

(a) Identity

(b) Contact

Performance of a contract with you.

To process and deliver your order including:

(a) Manage payments, fees and charges;

(b) Collect and recover money owed to us.

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Marketing & Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests, to study how customers use our services, to develop them and grow our business.

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy;

(b) Asking you to leave a review or take a survey.

(a) Identity

(b) Contact

(c) Profile

(d) Marketing & Communications

(a) Performance of a contract with you.

(b) Necessary to comply with a legal obligation.

(c) Necessary for our legitimate interests, to keep our records updated and to study how customers use our services.

To enable you to partake in a prize draw, competition or complete a survey.

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing & Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests, to study how customers use our services, to develop them and grow our business.

To administer and protect our business and the Site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).

(a) Identity

(b) Contact

(c) Technical

(a) 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.

(b) Necessary to comply with a legal obligation.

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing & Communications

(f) Technical

Necessary for our legitimate interests, to study how customers use our services, to develop them, to grow our business and to inform our marketing strategy.

To use data analytics to improve the Site, services, marketing, customer relations and experiences.

a) Technical

(b) Usage

Necessary for our legitimate interests, to define types of customers for our services, to keep the Site updated and relevant, to develop our business and to inform our marketing strategy

To make suggestions and recommendations to you about services that may be of interest to you.

(a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

(f) Marketing & Communications

Necessary for our legitimate interests, to develop our services and grow our business.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising of the services we offer.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you. We call this marketing.

You will receive marketing communications from us if you have requested information from us or ordered services from us and you have not opted out of receiving that marketing.

Third-party marketing 

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by logging in to your Account and checking or unchecking relevant boxes to adjust your marketing preferences, or by following the opt-out links on any marketing message sent to you, or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of an order for services, feedback you provide relating to your services’ experience, any guarantee or warranty information, or other transactions.

Cookies 

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see ourCookie Policy.

Change of purpose 

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures of your personal data

We may share your personal data with the parties set out below:

• Internal Third Parties, as set out in the Glossary, below).

• External Third Parties as set out in the Glossary, below).

• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

 We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International transfers

We share your personal data within the Service City Group. This will involve transferring your data outside the European Economic Area (EEA).

Many of our external third parties are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it, and 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.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7. Data security

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.

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.

8. Data retention 

How long will you use my personal data for?

 We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for 6 years after they cease being customers for tax and regulatory purposes.

In some circumstances you can ask us to delete your data: see Section 9, below, for further information.

In some circumstances we will 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.

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:

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.

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 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.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

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.

We try to respond to all legitimate requests within one month. Occasionally it could 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.

10. Glossary

Lawful Basis: 

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.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Third Parties:

Internal Third Parties Other companies in the Quana S.A who are based in Uruguay and who provide IT and system administration services.

External Third Parties

• Service providers based in the UK who provide services to you on our behalf, or who provide IT and system administration services.

• Professional advisers including lawyers, accountants, auditors, bankers and insurers based in the UK, who provide legal, accounting, banking, insurance and consultancy services.

• HM Revenue & Customs, regulators and other authorities based in the UK.

App privacy policy

Consent to installation of the App 

Under data protection laws, we are required to provide you with certain information about who we are, how we process your personal data and for what purposes, and your rights in relation to your personal data. This information is provided in our App Privacy Policy and our Website Privacy Policy and it is important that you read that information.

Before installation of this App, please indicate your consent to our processing of your personal data (including your name, contact details, financial and device information) as described in App Privacy Policy.

YES I consent to the installation of the App for the purpose of the provision of Service City Services.

NO I do not consent to the installation of the App.

How you can withdraw consent 

Once you provide consent by selecting "YES", you may change your mind and withdraw consent at any time by contacting us but that will not affect the lawfulness of any processing carried out before you withdraw your consent.

Consent to processing Location Data 

YES I consent to processing of my Location Data (including details of my current location so that location-enabled Services are activated.

NO I do not consent to processing of my Location Data and location-enabled Services are disabled in my settings.

Location Data

Service City Limited (collectively referred to as "the Company", "we", "us" or "our" in this policy) are committed to protecting your personal data and respecting your privacy.

Introduction

This policy (together with our terms of use), together our Terms of Use) applies to your use of:

 • The Service City mobile application software (App) available in the App Store and on our website, once you have downloaded or streamed a copy of the App onto your mobile telephone or handheld device (Device).

• Any of the services accessible through the App (Services)

This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.

This App is not intended for children and we do not knowingly collect data relating to children. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

Important information and who we are 

Service City Limited is the controller and is responsible for your personal data (collectively referred to as "Company", "we", "us" or "our" in this policy).

We have appointed a data protection officer. If you have any questions about this privacy policy, please contact them using the details set out below.

Contact details 

Our full details are:

• Full name of legal entity: Service City Limited

• Name or title of DPO: Will Gaze

• Email address: support@servicecity.co.uk

• Postal address: 71- 75 Shelton Street, London, WC2H 9JQ

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues.

Changes to the privacy policy and your duty to inform us of changes 

We keep our privacy policy under regular review.

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 our relationship with you.

Third party links 

Our Sites may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as Contact and Location Data. Please check these policies before you submit any personal data to these websites or use these services.

The data we collect about you 

We may collect, use, store and transfer different kinds of personal data about you as follows:

Identity Data: Data includes first name, maiden name, last name, username or similar identifier, title, date of birth, gender and marital status.

Contact Data: includes billing address, delivery 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.

Device Data: includes the type of mobile device you use, a unique device identifier (for example, your Device's IMEI number, the MAC address of the Device's wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use, and time zone setting.

Content Data: includes information stored on your Device, including friends' lists, login information, photos, videos or other digital content, and check-ins.

Profile Data: includes your username and password, Order and in-App purchase history, your interests, preferences, feedback and survey responses.

Usage Data: includes details of your use of any of our Apps or your visits to our Site including, but not limited to, traffic data and other communication data, whether this is required for our own billing purposes or otherwise, and the resources that you access.

Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties and your communication preferences.

Location Data: includes your current location disclosed by GPS technology.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific App feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (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.

How is your personal data collected?

We will collect and process the following data about you:

Information you give us. This is information (including Identity, Contact, Financial, and Marketing and Communications Data) you consent to giving us about you by filling in forms on the App and the Site (togetherOur Sites), or by corresponding with us (for example, by email or chat). It includes information you provide when you register to use the App, download the App, register an Account, place an Order for any of the Services, search for an App or Service, make an in-App purchase, share data via an App's social media functions, enter a competition, promotion or survey, or any other day-to-day uses of the App, and when you report a problem with our Services or Our Sites. If you contact us, we will keep a record of that correspondence.

Information we collect about you and your device. Each time you visit one of Our Sites or use the App we will automatically collect personal data including Device, Content and Usage Data. We collect this data using cookies and other similar technologies. Please see our cookie policy for further details.

Location Data. We also use GPS technology to determine your current location. Some of our location enabled Services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling Location Data in your settings.

Information we receive from other sources including third parties and publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:

• Device Data from the following parties: analytics providers such as Google based outside the EU; advertising networks based inside or outside the EU; and search information providers based inside or outside the EU.

• Contact, Financial and Transaction Data from providers of technical, payment and delivery                             services such as Stripe Payments Australia Pty Ltd based inside or outside the EU;

• Identity and Contact Data from data brokers or aggregators based inside or outside the EU;

• Identity and Contact Data from publicly available sources (such as Companies House and the electoral register); and

Unique application numbers. When you want to install or uninstall a Service containing a unique application number or when such a Service searches for automatic updates, that number and information about your installation, for example, the type of operating system, may be sent to us.

Cookies 

We use cookies and other tracking technologies to distinguish you from other users of the App, and to remember your preferences. This helps us to provide you with a good experience when you use the App or browse our Site and also allows us to improve the App and our Site. For detailed information on the cookies we use, the purposes for which we use them and how you can exercise your choices regarding our use of your cookies, see our cookie policy.

How we use your personal data

We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:

• Where you have consented before the processing.

• Where we need to perform a contract we are about to enter or have entered with you.

• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

• Where we need to comply with a legal or regulatory obligation. We will only send you direct marketing communications by email or text if we have your consent. You have the right to withdraw that consent at any time bycontacting us.

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Purposes for which we will use your personal data

Purpose/activity

Type of data

Lawful basis for processing

To install the App and register you as a new App user.

Identity

Contact

Financial

Device

Your consent.

To deliver Services including managing payments and collecting money owed to us.

Identity

Contact

Financial

Transaction

Device Marketing and Communications

Location

Your consent.

Performance of a contract with you.

Necessary for our legitimate interests (to recover debts due to us).

To manage our relationship with you including notifying you of changes to the App or any of the Services.

Identity

Contact

Financial Profile

Marketing and Communications

Your consent

Performance of a contract with you

Necessary for our legitimate interests (to keep records updated and to analyse how customers use our Services)

Necessary to comply with legal obligations (to inform you of any changes to our terms).

To enable you to participate in a prize draw, competition or complete a survey.

Identity

Contact

Device

Profile

Marketing and Communications

Your consent

Performance of a contract with you

Necessary for our legitimate interests (to analyse how customers use our products/Services and to develop them and grow our business)

To administer and protect our business and this App including troubleshooting, data analysis and system testing.

Identity

Contact

Device

Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security).

To deliver content and advertisements to you

To make recommendations to you about Services which may interest you

To measure and analyse the effectiveness of the advertising

To monitor trends so we can improve the App

Identity

Contact

Device

Content

Profile

Usage

Marketing and Communications

Location

Consent Necessary for our legitimate interests (to develop Services and grow our business)

  Disclosures of your personal data 

When you consent to providing us with your personal data, we will also ask you for your consent to share your personal data with the third parties set out below for the purposes set out in the table [Purposes for which we will use your personal data]:

• Internal Third Parties, as set out in the Glossary, below).

• External Third Parties as set out in the Glossary, below).

• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

International transfers

We share your personal data within the QUANA S.A. This will involve transferring your data outside the European Economic Area (EEA).] [Many of our external third parties are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.]

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it, and 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.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

Data security

All information you provide to us is stored on our secure servers. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted using Secured Sockets Layer technology. Where we have given you (or where you have chosen) a password that enables you to access certain parts of our Site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way. We will collect and store personal data on your Device using application data caches and browser web storage (including HTML5) and other technology. Certain Services include social networking, chat room or forum features. Ensure when using these features that you do not submit any personal data that you do not want to be seen, collected or used by other users. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.

Data retention 

Details of retention periods for different aspects of your personal data are available in our retention policy, which you can request by contacting us.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for 6 years after they cease being customers for tax, insurance and governance purposes. In some circumstances you can ask us to delete your data: see Your legal rights below for further information. In some circumstances we will 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. In the event that you do not use the App for a period of 1year then we will treat the account as expired and your personal data may be deleted.

Your legal rights

Under certain circumstances you have the following rights under data protection laws in relation to your personal data.

You have the right to:

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 8 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. You also have the right to ask us not to continue to process your personal data for marketing purposes. You can exercise any of these rights at any time by contacting us.

Glossary

Lawful basis: 

Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.

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.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Third parties:

Internal third parties 

Other companies in the Quana S.A who are based in Uruguay and who provide IT and system administration services.

External third parties 

• Service providers based in the UK who provide services to you on our behalf, or who provide IT and system administration services.

• Professional advisers including lawyers, accountants, auditors, bankers and insurers based in the UK, who provide legal, accounting, banking, insurance and consultancy services.

• HM Revenue & Customs, regulators and other authorities based in the UK.

Data Retention Policy

1. ABOUT THIS POLICY 

1.1 The corporate information, records and data of Service City Limited is important to how we conduct business and manage employees.

2. Service City Limited (collectively referred to as "the Company", "we", "us" or "our" in this data retention policy) is a company incorporated in England and Wales. Our company registration number is 12273952 and our registered office is at 71-75 Shelton Street, London, WC2H 9JQ.

2.1 There are legal and regulatory requirements for us to retain certain data, usually for a specified amount of time. We also retain data to help our business operate and to have information available when we need it. However, we do not need to retain all data indefinitely, and retaining data can expose us to risk as well as be a cost to our business.

2.2 This Data Retention Policy explains our requirements to retain data and to dispose of data and provides guidance on appropriate data handling and disposal.

2.3 Failure to comply with this policy can expose us to fines and penalties, adverse publicity, difficulties in providing evidence when we need it and in running our business.

2.4 This policy does not form part of any employee's contract of employment and we may amend it at any time.

3. SCOPE OF POLICY

3.1 This policy covers all data that we hold or have control over. This includes physical data such as hard copy documents, contracts, notebooks, letters and invoices. It also includes electronic data such as emails, electronic documents, digital files, audio and video recordings and CCTV recordings. It applies to both personal data and non-personal data. In this policy we refer to this information and these records collectively as "data".

3.2 This policy covers data that is held by third parties on our behalf, for example cloud storage providers or offsite records storage. It also covers data that belongs to us but is held by employees on personal devices.

3.3 This policy explains the differences between our formal or official records, disposable information, confidential information belonging to others, personal data and non-personal data. It also gives guidance on how we classNameify our data.

3.4 This policy applies to all business units and functions of Service City Limited.

4. GUIDING PRINCIPLES

4.1 Through this policy, and our data retention practices, we aim to meet the following commitments:

• We comply with legal and regulatory requirements to retain data.

• We comply with our data protection obligations, in particular to keep personal data no longer than is necessary for the purposes for which it is processed (storage limitation principle).

• We handle, store and dispose of data responsibly and securely.

 We create and retain data where we need this to operate our business effectively, but we do not create or retain data without good business reason. • We allocate appropriate resources, roles and responsibilities to data retention. • We regularly remind employees of their data retention responsibilities. • We regularly monitor and audit compliance with this policy and update this policy when required.

5. ROLES AND RESPONSIBILITIES

5.1 Responsibility of all employees. We aim to comply with the laws, rules, and regulations that govern our organisation and with recognised compliance good practices. All employees must comply with this policy, the Record Retention Schedule, any communications suspending data disposal and any specific instructions from the Legal Department or the Board. Failure to do so may subject us, our employees, and contractors to serious civil and/or criminal liability. An employee's failure to comply with this policy may result in disciplinary sanctions, including suspension or termination. It is therefore the responsibility of everyone to understand and comply with this policy.

5.2 We have designated Will Gaze as the Records Management Officer, with responsibility for: • Administering the data management programme and related best practices; • Planning, developing, and prescribing data disposal policies, systems, standards, and procedures; and • Providing guidance, training, monitoring and updating in relation to this policy.

5.3 Data Protection Officer. Our Data Protection Officer (DPO) is responsible for advising on and monitoring our compliance with data protection laws which regulate personal data. Our DPO works with our Records Management Department on the retention requirements for personal data and on monitoring compliance with this policy in relation to personal data.

6. TYPES OF DATA AND DATA classNameIFICATIONS 

6.1 Formal or official records. Certain data is more important to us and is therefore listed in the Record Retention Schedule. This may be because we have a legal requirement to retain it, or because we may need it as evidence of our transactions, or because it is important to the running of our business. Please see paragraph 7.1 below for more information on retention periods for this type of data.

6.2 Disposable information. Disposable information consists of data that may be discarded or deleted at the discretion of the user once it has served its temporary useful purpose and/or data that may be safely destroyed because it is not a formal or official record as defined by this policy and the Record Retention Schedule. Examples may include: • Duplicates of originals that have not been annotated. • Preliminary drafts of letters, memoranda, reports, worksheets, and informal notes that do not represent significant steps or decisions in the preparation of an official record. • Books, periodicals, manuals, training binders, and other printed materials obtained from sources outside Service City Limited and retained primarily for reference purposes.

• Spam and junk mail. Please see paragraph 7.2 below for more information on how to determine retention periods for this type of data.

6.3 Personal data. Both formal or official records and disposable information may contain personal data; that is, data that identifies living individuals. Data protection laws require us to retain personal data for no longer than is necessary for the purposes for which it is processed (principle of storage limitation). See paragraph 7.3 below for more information on this.

6.4 Confidential information belonging to others. Any confidential information that an employee may have obtained from a source outside Service City Limited, such as a previous employer, must not, so long as such information remains confidential, be disclosed to or used by us. Unsolicited confidential information submitted to us should be refused, returned to the sender where possible, and deleted, if received via the internet.

7. RETENTION PERIODS

7.1 Formal or official records. Any data that is part of any of the categories listed in the Record Retention Schedule contained in the Annex to this policy, must be retained for the amount of time indicated in the Record Retention Schedule. A record must not be retained beyond the period indicated in the Record Retention Schedule, unless a valid business reason (or notice to preserve documents for contemplated litigation or other special situation) calls for its continued retention. If you are unsure whether to retain a certain record, contact the Records Management Officer.

7.2 Disposable information. The Record Retention Schedule will not set out retention periods for disposable information. This type of data should only be retained as long as it is needed for business purposes. Once it no longer has any business purpose or value it should be securely disposed of.

7.3 Personal data. As explained above, data protection laws require us to retain personal data for no longer than is necessary for the purposes for which it is processed (principle of storage limitation). Where data is listed in the Record Retention Schedule, we have taken into account the principle of storage limitation and balanced this against our requirements to retain the data.

7.4 What to do if data is not listed in the Record Retention Schedule. If data is not listed in the Record Retention Schedule, it is likely that it should be classNameed as disposable information. However, if you consider that there is an omission in the Record Retention Schedule, please contact the Records Management Department.

8. STORAGE, BACK-UP AND DISPOSAL OF DATA

8.1 Storage. Our data must be stored in a safe, secure, and accessible manner. Any documents and financial files that are essential to our business operations during an emergency must be duplicated and/or backed up at least once per week and maintained off site.

8.2 Destruction. Our Records Management Officer is responsible for the continuing process of identifying the data that has met its required retention period and supervising its destruction. The destruction of confidential, financial, and employee-related hard copy data must be conducted by shredding if possible. Non-confidential data may be destroyed by recycling. The destruction of electronic data must be undertaken with the appropriate IT safeguards.

8.3 The destruction of data must stop immediately upon notificationfrom the Legal Department that preservation of documents for contemplated litigation is required (sometimes referred to as a litigation hold). This is because we may be involved in a legal claim or an official investigation (see section 9). Destruction may begin again once the Legal Department lifts the requirement for preservation.

9. SPECIAL CIRCUMSTANCES 

9.1 Preservation of documents for contemplated litigation and other special situations. We require all employees to comply fully with our Record Retention Schedule and procedures as provided in this policy. All employees should note the following general exception to any stated destruction schedule: If you believe, or the Legal Department informs you, that certain records are relevant to current litigation or contemplated litigation (that is, a dispute that could result in litigation), government investigation, audit, or other event, you must preserve and not delete, dispose, destroy, or change those records, including emails and other electronic documents, until the Legal Department determines those records are no longer needed. Preserving documents includes suspending any requirements in the Record Retention Schedule and preserving the integrity of the electronic files or other format in which the records are kept.

9.2 If you believe this exception may apply, or have any questions regarding whether it may apply, please contact the Legal Department.

9.3 In addition, you may be asked to suspend any routine data disposal procedures in connection with certain other types of events, such as our merger with another organisation or the replacement of our information technology systems.

10. WHERE TO GO FOR ADVICE AND QUESTIONS

10.1 Questions about the policy. Any questions about retention periods relevant to your department, or about this policy, should be raised with the Records Management Officer or the DPO.

11. BREACH REPORTING AND AUDIT

11.1 Reporting policy breaches. We are committed to enforcing this policy as it applies to all forms of data. The effectiveness of our efforts, however, depend largely on employees. If you feel that you or someone else may have breached this policy, you should report the incident immediately to your supervisor. If you are not comfortable bringing the matter up with your immediate supervisor, or do not believe the supervisor has dealt with the matter properly, you should raise the matter with the Records Management Officer. If employees do not report inappropriate conduct, we may not become aware of a possible breach of this policy and may not be able to take appropriate corrective action.

11.2 No one will be subject to and we do not allow, any form of discipline, reprisal, intimidation, or retaliation for reporting incidents of inappropriate conduct of any kind, pursuing any record destruction claim, or cooperating in related investigations.

11.3 Audits. The Records Management Officer will periodically review this policy and its procedures (including where appropriate by taking outside legal or auditor advice) to ensure we are in compliance with relevant new or amended laws, regulations or guidance. Additionally, we will regularly monitor compliance with this policy, including by carrying out audits.

12. AND OTHER RELEVANT POLICIES 

12.1 This policy supplements and should be read in conjunction with our other policies and procedures in force from time to time.

13. ACKNOWLEDGEMENT OF RECEIPT AND REVIEW 

I, _______________________ [EMPLOYEE NAME], acknowledge that on _____________________ [DATE], I received a copy of Service City Limited]'s Data Retention Policy and that I read it, understood it, and agree to comply with it. This policy does not set terms or conditions of employment or form part of an employment contract. …………………………………………….

Signature

 …………………………………………….

Printed name

 ……………………………………………

Date

ANNEX A DEFINITIONS

Data: all data that we hold or have control over and therefore to which this policy applies. This includes physical data such as hard copy documents, contracts, notebooks, letters and invoices. It also includes electronic data such as emails, electronic documents, audio and video recordings and CCTV recordings. It applies to both personal data and non-personal data. In this policy we refer to this information and these records collectively as "data".

Data Protection Officer: our Data Protection Officer who is responsible for advising on and monitoring compliance with data protection laws.

Data Retention Policy: this policy, which explains our requirements to retain data and to dispose of data and provides guidance on appropriate data handling and disposal.

Disposable information: disposable information consists of data that may be discarded or deleted at the discretion of the user once it has served its temporary useful purpose and/or data that may be safely destroyed because it is not a formal or official record as defined by this policy and the Record Retention Schedule.

Formal or official record: certain data is more important to us and is therefore listed in the Record Retention Schedule. This may be because we have a legal requirement to retain it, or because we may need it as evidence of our transactions, or because it is important to the running of our business. We refer to this as formal or official records or data. 

Non-personal data: data which does not identify living individuals, either because it is not about living individuals (for example financial records) or because it has been fully anonymised.

Personal data: any information identifying a living individual or information relating to a living individual that we can identify (directly or indirectly) from that data alone or in combination with other identifiers we possess or can reasonably access. This includes special categories of personal data such as health data and pseudonymised personal data but excludes anonymous data or data that has had the identity of an individual permanently removed. Personal data can be factual (for example, a name, email address, location or date of birth) or an opinion about that person's actions or behaviour.

Records Management Officer: the Records Management Officer is responsible for administering the data management programme, helping department heads implement it and related best practices, planning, developing, and prescribing data disposal policies, systems, standards, and procedures and providing guidance, training, monitoring and updating in relation to this policy.

Record Retention Schedule: the schedule attached to this policy which sets out retention periods for our formal or official records.

Storage limitation principle: data protection laws require us to retain personal data for no longer than is necessary for the purposes for which it is processed. This is referred to in the GDPR as the principle of storage limitation.

ANNEX B RECORD RETENTION SCHEDULE

Service City Limited establishes retention or destruction schedules or procedures for specific categories of data. This is done to ensure legal compliance (for example with our data protection obligations) and accomplish other objectives, such as protecting intellectual property and controlling costs.

Employees should comply with the retention periods listed in the record retention schedule below, in accordance with our Data Retention Policy. If you hold data not listed below, please refer to our Data Retention Policy.

If you still consider your data should be listed, if you become aware of any changes that may affect the periods listed below or if you have any other questions about this record retention schedule, please contact the Records Management Officer.

TYPE OF DATA

RETENTION PERIOD

REASON / COMMENTS

employee recruitment forms, Customer application forms, Customer Account-opening forms, Service Provider terms etc.

6 months after notifying candidates of the outcome of the recruitment exercise/a minimum of 3 years after the end of the tax year to which they relate/7 years after employment ends/a minimum of [1] year and a maximum of 7 years.

Regulatory guidance or best practice.

COOKIE POLICY

We are Service City Limited (collectively referred to as "the Company", "we", "us" or "our" in these terms), a company incorporated in England and Wales. Our company registration number is 12273952 and our registered office is at 71-75 Shelton Street, London, WC2H 9JQ. Our registered VAT number is 280 770 787.

Our website at servicecity.co.uk (“our Site”) uses cookies to distinguish you from other users of our Site. This helps us to provide you with a good experience when you browse the Site and also allows us to improve our Site

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive. We use the following cookies:

• Strictly necessary cookies. These are cookies that are required for the operation of our Site. They include, for example, cookies that enable you to log into secure areas of our Site, use a shopping cart or make use of and Order services from us.

• Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our Site when they are using it. This helps us to improve the way our Site works, for example, by ensuring that users are finding what they are looking for easily.

• Functionality cookies. These are used to recognise you when you return to our Site. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

• Targeting cookies. These cookies record your visit to our Site, the pages you have visited and the links you have followed. We will use this information to make the Site and the advertising displayed on it more relevant to your interests. You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

Cookie Title

Cookie Name

Purpose

Examples of purposes for which a cookie may be used:

This cookie is essential/non-essential for our Site and enables us to:

(a) Estimate usage patterns.

(b) Store information about your preferences, and so allow us to customise our Site and to provide you with offers that are targeted to your individual interests or requirements.

(c) Speed up your searches.

(d) Recognise you when you return to our Site.

(e) Allow you to use our Site in a way that makes your browsing experience more convenient, for example, by allowing you to store items in an electronic shopping basket between visits. If you register with us or complete our online forms, we will use cookies to remember your details during your current visit, and any future visits provided the cookie was not deleted in the interim.

We do not share the information collected by the cookies with any third parties. You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our Site. Except for essential cookies, all cookies will expire after an expiry period.

Website Acceptable Use Policy

 Who we are and how to contact us

https://www.servicecity.co.uk (“our Site”) is a site operated by Service City Limited ("We, Us, Our”). We are registered in England and Wales under company number 12273952 and have our registered office at 71-75 Shelton Street, London, WC2H 9JQ.

Our main trading address is 71-75 Shelton Street, London, WC2H 9JQ.

Our VAT number is 280 770 787.

To contact us by please telephone our customer service team at08081890450 or write to us at support@servicecity.co.uk our address is 71-75 Shelton Street, London, WC2H 9JQ., or through our app (“the App”) or our Site.

What's in these terms?

This acceptable use policy sets out the content standards that apply when you upload content to our Site, make contact with other users on our site, link to our Site, or interact with our Site in any other way.

Please read the terms of this policy carefully before using our Site.

By using our Site you accept these terms

By using our Site, you confirm that you accept the terms of this policy and that you agree to comply with them.

If you do not agree to these terms, you must not use our Site.

We recommend that you print a copy of these terms for future reference.

There are other terms that may apply to you

Our Terms of use [INSERT AS LINK TO SC’S TERMS AND CONDITIONS] also apply to your use of our Site.

We may make changes to the terms of this policy 

We amend these terms from time to time. Every time you wish to use our Site, please check these terms to ensure you understand the terms that apply at that time.

Prohibited uses

You may use our Site only for lawful purposes. You may not use our Site:

• In any way that breaches any applicable local, national or international law or regulation.

• In any way that is unlawful or fraudulent or has any unlawful or fraudulent purpose or effect.  

• For the purpose of harming or attempting to harm minors in any way.

• To bully, insult, intimidate or humiliate any person.

• To send, knowingly receive, upload, download, use or re-use any material which does not comply with our content standards.

• To transmit, or procure the sending of, any unsolicited or unauthorised advertising or promotional material or any other form of similar solicitation (spam).

• To knowingly transmit any data, send or upload any material that contains viruses, Trojan horses, worms, time-bombs, keystroke loggers, spyware, adware or any other harmful programs or similar computer code designed to adversely affect the operation of any computer software or hardware. You also agree:

• Not to reproduce, duplicate, copy or re-sell any part of our Site in contravention of the provisions of our terms of use.

• Not to access without authority, interfere with, damage or disrupt:

• any part of our Site;

• any equipment or network on which our Site is stored;

• any software used in the provision of our Site; or

• any equipment or network or software owned or used by any third party.

Interactive services

We may from time to time provide interactive services on our Site, including, without limitation:

• Chat rooms.

• Bulletin boards.

(“interactive services”.)

Where we do provide any interactive service, we will provide clear information to you about the kind of service offered, if it is moderated and what form of moderation is used (including whether it is human or technical).

We will do our best to assess any possible risks for users (and in particular, for children) from third parties when they use any interactive service provided on our Site, and we will decide in each case whether it is appropriate to use moderation of the relevant service (including what kind of moderation to use) in the light of those risks. However, we are under no obligation to oversee, monitor or moderate any interactive service we provide on our Site, and we expressly exclude our liability for any loss or damage arising from the use of any interactive service by a user in contravention of our content standards, whether the service is moderated or not.

The use of any of our interactive services by a minor is subject to the consent of their parent or guardian. We advise parents who permit their children to use an interactive service that it is important that they communicate with their children about their safety online, as moderation is not fool proof. Minors who are using any interactive service should be made aware of the potential risks to them.

Where we do moderate an interactive service, we will normally provide you with a means of contacting the moderator, should a concern or difficulty arise.

Content standards

These content standards apply to any and all material which you contribute to our Site (“Contribution”), and to any interactive services associated with it.

The Content Standards must be complied with in spirit as well as to the letter. The standards apply to each part of any Contribution as well as to its whole.

Service City Limited will determine, in its discretion, whether a Contribution breaches the Content Standards.

A Contribution must:

• Be accurate (where it states facts).

• Be genuinely held (where it states opinions).

• Comply with the law applicable in England and Wales and in any country from which it is posted. A Contribution must not:

• Be defamatory of any person.

• Be obscene, offensive, hateful or inflammatory.

• Bully, insult, intimidate or humiliate.

• Promote sexually explicit material.

• Include child sexual abuse material.

• Promote violence.

• Promote discrimination based on race, sex, religion, nationality, disability, sexual orientation or age.

• Infringe any copyright, database right or trade mark of any other person.

• Be likely to deceive any person.

• Breach any legal duty owed to a third party, such as a contractual duty or a duty of confidence.

• Promote any illegal content or activity.

• Be in contempt of court.

• Be threatening, abuse or invade another's privacy, or cause annoyance, inconvenience or needless anxiety.

• Be likely to harass, upset, embarrass, alarm or annoy any other person.

• Impersonate any person or misrepresent your identity or affiliation with any person.

• Give the impression that the Contribution emanates from, if this is not the case.

• Advocate, promote, incite any party to commit, or assist any unlawful or criminal act such as (by way of example only) copyright infringement or computer misuse.

• Contain a statement which you know or believe, or have reasonable grounds for believing, that members of the public to whom the statement is, or is to be, published are likely to understand as a direct or indirect encouragement or other inducement to the commission, preparation or instigation of acts of terrorism.

• Contain any advertising or promote any services or web links to other sites.

Breach of this policy

When we consider that a breach of this acceptable use policy has occurred, we may take such action as we deem appropriate.

Failure to comply with this acceptable use policy constitutes a material breach of our Terms of use [INSERT AS LINK TO SC'S TERMS AND CONDITIONS] upon which you are permitted to use our Site, and may result in our taking all or any of the following actions:

• Immediate, temporary or permanent withdrawal of your right to use our Site.

• Immediate, temporary or permanent removal of any Contribution uploaded by you to our Site.

• Issue of a warning to you.

• Legal proceedings against you for reimbursement of all costs on an indemnity basis (including, but not limited to, reasonable administrative and legal costs) resulting from the breach.

• Further legal action against you.

• Disclosure of such information to law enforcement authorities as we reasonably feel is necessary or as required by law.

We exclude our liability for all action we may take in response to breaches of this acceptable use policy. The actions we may take are not limited to those described above, and we may take any other action we reasonably deem appropriate.

How this contract can be transferred

We can transfer our rights and obligations under these terms to any third party, provided this does not adversely affect your rights under these terms.

Which country's laws apply to any disputes?

The terms of this policy, its subject matter and its formation (and any non-contractual disputes or claims) are governed by English law. We both agree to the exclusive jurisdiction of the courts of England and Wales.