Privacy and Cookies Policy

1. Introduction

1.1 We are committed to safeguarding the privacy of our users.

1.2 We use cookies which are strictly necessary for the provision of our website.

1.3 This policy applies where we are acting as a data controller with respect to user personal data.

1.4 In this policy, "we", "us" and "our" refer to 108 Limited. For more information about us, see Section 14.

2. The personal data that we collect

2.1 In this Section 2 we have set out the general categories of personal data that we process.

2.2 We may process your website user account data ("account data”). The account data may include your username, email address, encrypted password, account creation date, account id and account status. The primary source of the account data is you, although some elements of the account data may be generated by our website.

2.3 We may process information contained in or relating to any communication that you send to us or that we send to you ("communication data"). The communication data may include the communication content and metadata associated with the communication. The source of the communication data is you and/or us.

2.4 We may process information relating to complaints of defamation ("complaint of defamation data"). The complaint of defamation data may include your full name and postal address where you have provided them as a result of a complaint of defamation. The source of the complaint of defamation data is you.

2.5 We may process information relating to our sponsor relationships ("sponsor relationship data"). The sponsor relationship data may include your name, the name of your business or employer, your job title or role and your contact details. The source of the sponsor relationship data is you and/or your employer.

2.6 We may process information relating to transactions, including purchases of services, that you enter into with us ("transaction data"). The transaction data may include your name, your contact details, your payment details and the transaction details. The source of the transaction data is you and/or our payment services provider.

2.7 Please do not supply any other person's personal data to us.

3. Purposes of processing and legal bases

3.1 In this Section 3, we have set out the purposes for which we may process personal data and the legal bases of the processing.

3.2 Operations - We may process your personal data for the purposes of operating our website, the processing and fulfilment of orders, providing our services, generating invoices, bills and other payment-related documentation, and credit control. The legal basis for this processing is our legitimate interests, namely the proper administration of our website, services and business.

3.3 Relationships and communications - We may process contact data, account data, sponsor relationship data, transaction data and/or communication data for the purposes of managing our relationships, communicating with you (excluding communicating for the purposes of direct marketing) by email, providing support services and complaint handling. The legal basis for this processing is our legitimate interests, namely communications with our website visitors, service users, individual sponsors and sponsor personnel, the maintenance of our relationships, enabling the use of our services, and the proper administration of our website, services and business.

3.4 Record keeping - We may process your personal data for the purposes of creating and maintaining our databases, back-up copies of our databases and our business records generally. The legal basis for this processing is our legitimate interests, namely ensuring that we have access to all the information we need to properly and efficiently run our business in accordance with this policy.

3.5 Security - We may process your personal data for the purposes of security and the prevention of fraud and other criminal activity. The legal basis of this processing is our legitimate interests, namely the protection of our website, services and business, and the protection of others.

3.6 Legal compliance and vital interests - We may also process your personal data where such processing is necessary for compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person.

4. Providing your personal data to others

4.1 Your personal data held in our website database will be stored on the servers of our hosting services providers.

4.2 We may disclose your personal data to our suppliers or subcontractors insofar as reasonably necessary for maintaining and operating our website and services.

4.3 Financial transactions relating to our website and services may be handled by our payment services providers. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments and dealing with complaints and queries relating to such payments.

4.4 In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

5. Retaining and deleting personal data

5.1 This Section 5 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

5.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

5.3 Notwithstanding the other provisions of this Section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

6. Security of personal data

6.1 We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.

6.2 Your password will be stored by us in encrypted form.

6.3 You should ensure that your password is not susceptible to being guessed, whether by a person or a computer program. You are responsible for keeping the password you use for accessing our website confidential and we will not ask you for your password (except when you log in to our website).

7. Your rights

7.1 In this Section 7, we have listed the rights that you have under data protection law.

7.2 Your principal rights under data protection law are:

(a) the right to access - you can ask for copies of your personal data;

(b) the right to rectification - you can ask us to rectify inaccurate personal data and to complete incomplete personal data;

(c) the right to erasure - you can ask us to erase your personal data;

(d) the right to restrict processing - you can ask us to restrict the processing of your personal data;

(e) the right to object to processing - you can object to the processing of your personal data;

(f) the right to data portability - you can ask that we transfer your personal data to another organisation or to you;

(g) the right to complain to a supervisory authority - you can complain about our processing of your personal data; and

(h) the right to withdraw consent - to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.

7.3 These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by visiting https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.

7.4 You may exercise any of your rights in relation to your personal data by email: [email protected]

8. Third party websites

8.1 Our website includes details of, hyperlinks to, and images from, third party websites.

8.2 In general we have no control over, and are not responsible for, the privacy policies and practices of third parties.

9. About cookies

9.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

10. Cookies that we use

10.1 We use cookies for the following purposes:

(a) authentication - we use cookies when you log in to our website. These cookies expire immediately when you log out of our website.

11. Managing cookies

11.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

(a) https://support.google.com/chrome/answer/95647 (Chrome);

(b) https://support.mozilla.org/en-US/kb/enhanced-tracking-protection-firefox-desktop (Firefox);

(c) https://help.opera.com/en/latest/security-and-privacy/ (Opera);

(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);

(e) https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac (Safari); and

(f) https://support.microsoft.com/en-gb/help/4468242/microsoft-edge-browsing-data-and-privacy (Edge).

11.2 Blocking all cookies will have a negative impact upon the usability of many websites.

11.3 If you block cookies, you will not be able to use all the features on our website.

12. Amendments

12.1 We may update this policy from time to time by publishing a new version on our website.

12.2 You should check this page occasionally to ensure you are happy with any changes to this policy.

13. Data protection registration

13.1 We are registered as a data controller with the UK Information Commissioner's Office.

13.2 Our data protection registration number is ZB755049.

14. Our details

14.1 This website is operated by 108 Limited.

14.2 We are registered in England and Wales under registration number 15947577.

14.3 Our registered office is at 27 Old Gloucester Street, London, England, WC1N 3AX.

14.4 General enquiries by email: [email protected]

14.5 Sponsorship enquiries by email: [email protected]

14.6 Technical feedback by email: [email protected]

14.7 Press and media enquiries by email: [email protected]