revised June, 2020
At Goldthorn Services Limited, we understand that we have a responsibility to protect and respect your privacy and look after your personal data.
This Privacy Policy, together with of our Terms and Conditions of Sale and Acceptable Use Policy (see https://goldthorn.uk/legal-information), explains what personal data we collect, how we use your personal data, reasons we may need to disclose your personal data to others and how we store your personal data securely.
For clarity, Goldthorn Services Limited may be both data controller and data processor for your personal data under certain circumstances.e with this privacy statement.
We must advise that this policy is subject to change, so please check our website on a regular basis for any further changes.
This Privacy Policy sets out your rights under the new laws.
Who are we?
Goldthorn Services Limited offer a range of services including domain names, shared web hosting, and business-class email. Goldthorn Services Limited has a registered office at 127 Goldthorn Hill, Wolverhampton, West Midlands WV2 4PS and company number 4102692.
How the law protects you
Data protection laws state that we are only able to process personal data if we have valid reasons to do so. Our basis for processing your personal data includes, but is not limited to, your consent, performance of a contract, to enable billing and remittance, and to contact you for customer service purposes.
How do we collect personal data from you?
We receive information about you from you when you use our website, complete forms on our website, if you contact us by phone, email, live-chat or otherwise in respect of any of our products and services or during the purchasing of any product or service. Additionally, we also collect information from you when you sign up, enter a competition, promotion or survey or when you inform us of any other matter.
If you provide us with personal data about a third party (for example when registering a domain on their behalf), you warrant that you have obtained the express consent from the third party for the disclosure and use of their personal data.
Your personal data may be automatically collected when you use our services, including but not limited to, your IP address, device-specific information, server logs, device event information, location information and unique application numbers.
What type of data do we collect from you?
The personal data that we may collect from you includes your name, address, email address, phone numbers, payment information and IP addresses. We may also keep details of your visits to our site including, but not limited to traffic data, location data, weblogs and other communication data. We also retain records of your queries and correspondence, in the event you contact us.
Please be aware that any video, image, or other content posted, uploaded or otherwise made available by you onto your website, whether published content or not, is not subject to our Privacy Policy.
We merely process such data on your behalf, subject to our Acceptable Use Policy and you are responsible for any applicable legal requirements in respect of your content.
We also collect information that is provided to Goldthorn Services by potential employee candidates, where information is sent to Goldthorn Services by their CV.
Personal data managed by you
As our customer, you use our services to host, transmit or process data on our hosting platforms, which may include personal data of your customers.
For the avoidance of doubt, under these circumstances, you stipulate the process for collecting your customer’s data. Most importantly, we do not have knowledge of or view, share or collect this specific data.
In accordance with this Privacy Policy, you are responsible for managing the security of your customers’ data which they upload onto our platforms and ensuring secure access to such data.
Our relationship is with you directly and there is no agreement in place between us and your customers and you are responsible for any applicable legal requirements in respect of such data.
How do we use your data?
We use information about you in the following ways:
- To process orders that you have submitted to us;
- To provide you with products and services;
- To comply with our contractual obligations we have with you;
- To help us identify you and any accounts you hold with us;
- To enable us to review, develop and improve the website and services;
- To provide customer care, including responding to your requests if you contact us with a query;
- To administer accounts, process payments and keep track of billing and payments;
- To detect fraud and to make sure what you have told us is correct;
- To carry out marketing and statistical analysis;
- To review job applications;
- To notify you about changes to our website and services;
- To provide you with information about products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes; and
- To inform you of service and price changes.
Retention periods
We will keep your personal data for the duration of the period you are a customer of Goldthorn Services. We shall retain your data only for as long as necessary in accordance with applicable laws.
On the closure of your account, we may keep your data for up to 7 years after you have cancelled your services with us. We may not be able to delete your data before this time due to our legal and/or accountancy obligations or as reasonably necessary to prevent fraud, abuse, enforce our terms and to protect our legitimate interests. We assure you that your personal data shall only be used for these purposes stated herein.
Who has access to your personal data?
Here is a list of all the ways that we may use your personal data and how we share the information with third parties. For clarity, we have grouped them into the specific products and services that we offer:
Domains
We process your data for administration, billing, support and the provision of services. Your data (Registrant) may be sent to a domain registrar outside of the EEA.
Webhosting
We process your data for administration, billing, support and the provision of services
Email hosting
We process your data for administration, billing, support and the provision of services. Additionally, to provide customer domain and connection details and use email addresses to provide the service.
SSL certificates
We process your data for administration, billing, support and the provision of services. Additionally, to provide details of the certificate owner to the certificate authority for its authentication and use. Owner data to certificate provider outside the EEA.
For the avoidance of doubt, we do not and never shall sell your personal data to third parties for marketing or advertising purposes.
We work closely with a number of third parties (including business partners, service providers and fraud protection services) and we may receive information from them about you. These third parties may collect information about you including, but not limited to, your IP address, device-specific information, server logs, device event information, location information, and unique application numbers. We use their features within our website, however, in some instances, they may be acting as data controller and they will have their own privacy policies, which we advise you to read.
We may pass your personal data to third parties for the provision of services on our behalf (for example processing your payment). However, we will only ever share information about you that is necessary to provide the service and we have specific contracts in place, which ensure your personal data is secure and will not be used for any marketing purposes.
We may share your information if we are acquired by a third party and therefore your data will be deemed an asset of the business. In these circumstances, we may disclose your personal data to the prospective buyer of our business, subject to both parties entering into appropriate confidentiality undertakings. Similarly, we may share your personal data if we are under a duty to disclose data in order to comply with any legal obligation or to protect the rights, property, or safety of Goldthorn Services, our customers, or others. This includes but is not limited to exchanging information with other companies and organisations for the purposes of fraud protection, credit risk reduction and dispute policies. However, we will take steps with the aim of ensuring that your privacy rights continue to be protected.
Your rights
In preventing the use or processing of your personal data, it may delay or prevent us from fulfilling our contractual obligations to you. It may also mean that we shall be unable to provide our services or process the cancellation of your service.
You have the right to object to our use of your personal data, or ask us to delete, remove or stop using it if there is no need for us to keep it. This is known as your right to be forgotten. There are legal and accountancy reasons why we will need to keep your data, but please do inform us if you think we are retaining or using your personal data incorrectly.
Our Privacy Policy shall be made clear to you at the point of collection of your personal data.
You can view, edit or delete your personal data through the Goldthorn Services’ control panel. You can also make choices about Goldthorn Services’ collection of your data and how we use it.
You have the right to ask us not to process your personal data for marketing purposes. If you choose not to receive marketing communications from us about our products and services, you will have the choice not to choose these by ticking the relevant boxes situated on the pages either at sign up or in your control panel.
We will not contact you for marketing purposes unless you have given us your prior consent. You can change your marketing preferences at any time within your hosting service control panel.
Accessing and updating your data
You must maintain the accuracy of your information and ensure all your details, including but not limited to, name, address, title, phone number, e-mail address and payment details are kept up to date at all times. You must do this by updating your personal details within your hosting service control panel.
You have the right to access the information we hold about you. Please email your requests to privacy@goldthorn.co.uk so that we can obtain this information for you.
Before Goldthorn Services disclose your personal data, we may ask you to provide additional information so that Goldthorn Services can confirm your identity and for your security.
We reserve the right to charge a fee if your request is excessive or unfounded.
Links to other sites
Goldthorn Services may provide links to third party sites. Since we do not control those websites, we encourage you to review the privacy policies of these third party sites. Any information that is supplied on these sites will not be within our control and we cannot be responsible for the privacy policies and practices of these.
Where we store your personal data
We follow accepted standards to store and protect the personal data we collect, including the use of encryption if appropriate.
All information you provide to us is stored on our secured servers within the UK. From time to time, we may transfer your personal data between different jurisdictions. However, in doing so we will comply with the European Data Protection Directive 95/46/EC (“GDPR”) and other applicable laws regulating the protection for the transfer of personal information between jurisdictions. This means that we may transfer your data to the United States, the EU, or other countries subject to conditions. By providing your data to us, you agree to this transfer and storage. However, we will ensure that reasonable steps are taken to protect your data in accordance with this Privacy Policy.
As the transmission of information via the internet is not completely secure, we cannot guarantee the security of your data transmitted to our site and any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Any sensitive data (payment details for example) are encrypted and protected.
Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website, you are responsible for keeping the password confidential. We ask you not to share a password with anyone.
Liability
We agree to take reasonable measures to protect your data in accordance with applicable laws and in accordance with our General Terms and Conditions: https://goldthorn.uk/wp-content/uploads/2019/09/TermsConditionsOfSale.pdf .
Data Breaches
In the event of a data breach, we shall ensure that our obligations under applicable data protection laws are complied with where necessary.
Contact us
Please e-mail any questions or comments you have about privacy to us at privacy@goldthorn.co.uk
Your right to make a complaint
You have the right to make a complaint about how we process your personal data to the Information Commissioner:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Tel: 0303 123 1113
