Welcome to the Redwood Technologies Limited (part of Redwood Technologies Group Limited) privacy and cookies policy. We respect your privacy and are committed to protecting your Personal Data (as defined by applicable data privacy laws) and other information that we may collect or process.

Redwood Technologies Limited may collect or process personal data in two ways:

• Through a direct relationship, via our website wp0.jlspfcw.com (the “Website”);
• Through information provided under contractual arrangements with our business partners and customers, with whom you will have a direct relationship. Details of the information provided will be available through the privacy policy of the respective business partner or customer, who will be the data controller. This information is not available through the Website and is processed by our sister company Content Guru Limited (also part of Redwood Technologies Group Limited).

This policy provides you with details about the personal information collected by us, and provided to us through the Website, how we store and use your personal information, and your rights to control the personal information we hold about you.

If accessing or browsing the Website, please read this privacy and cookies policy carefully. By accessing or browsing the Website, you confirm that you have read, understood, and agreed to this privacy and cookies policy in its entirety. If you do not agree to this privacy and cookies policy in its entirety, you must not use the Website.

We have tried to keep this privacy and cookies policy as simple as possible, but please let us know if you are not familiar with any of the terms, or have any other questions.

This privacy and cookies policy was last updated on 5 May 2021. Please check back regularly to keep informed of any updates to this privacy and cookies policy.

Who we are

Content Guru Limited (“we”, “our”, “us”) is a company registered in England and Wales (registration number 05653869), whose registered office is at Radius Court, Eastern Road, Bracknell, Berkshire, RG12 2UP. Content Guru Limited is also a company registered in England and Wales (registration number 05653869).

We respect your right to privacy and will only process personal information that you provide, or that is provided to us, under applicable data privacy laws. We will be the data controller for any data inputted into the Website, and will be the processor for data provided to us by our business partners and customers.

If you have any questions about how we collect, store or use personal information, or if you have any other privacy-related questions, please contact us by any of the following means:

• Phone us at: +[44] (0) 1344 304344; or
• E-mail us at: dpo@jlspfcw.com; or
• Write to us at: Information Security, Content Guru Limited, Radius Court, Eastern Road, Bracknell, Berkshire, RG12 2UP, United Kingdom.

We have appointed a Data Protection Officer who can be contacted as shown above.

The personal information we collect about you

When you access or browse the Website (including when you contact us and/or submit personal information to us through data entry fields on the Website), we may collect the following information from you:

• Contact details. When you contact us, you may provide us with your name, email address, and phone number.
• Browser and device data. When you visit the Website, we collect certain information about your device (e.g. information about your web browser, IP address, and time zone) and some of the cookies that are installed on your device. When you browse our Website, we will also collect information about the individual web pages that you view, which websites or search terms referred you to the Website, and how you interact with the Website. Even though we do not normally use this data to identify individuals, sometimes individuals can be recognized from it.
• Web forms. You will find web forms on the Website, where you can submit your information. For example, you can submit your contact details and ask us to contact you.
• Messages and communications. You may share personal data when you contact us, e.g. contact details, employer, job title, etc. We will also collect relevant information about your interactions with us, e.g. the date, time, method of contact, and subject of the conversation. Since email communications are not always secure, we encourage you not to include any sensitive data in your emails to us.

We may combine information we receive about you from other sources with the information that you give to us, but not information provided by our business partners or customers through our services. We may use that information and the combined information for the purposes set out below.

How we may store and use your information

We may collect, store, and use the personal information listed above for the following purposes:

• To make the Website available to you, and to provide you with content which is tailored to your individual tastes;
• To communicate with you. When you contact us, we process your contact details and messages based on our legitimate interest in communicating with you and answering the incoming correspondence that we receive;
• To provide you with the services that you request and to obtain your feedback on such services;
• To promote other goods and services we offer that are similar to those you have enquired about (“Direct Marketing”). With your consent, we will use your name and email address to send you periodic newsletters, information about our services, and invitations to events. You have the right to withdraw your consent at any time. You can opt-out from Direct Marketing by following the instructions in each marketing email you receive from us;
• To improve and optimize the Website. We will process your browser and device data for our legitimate interest in improving and optimizing the Website (e.g. by generating analytics about how you and others browse and interact with the site). For this purpose, we will not analyze your data on an individual level; all processing will take place on anonymized or pseudonymized data;
• To protect our legitimate interests. We will process your personal data when necessary to protect or exercise our rights or business interests, e.g. to defend us against claims from you or from third parties. The legal basis for this processing is usually to pursue legitimate interests;
• To meet legal requirements. We will process your personal data when necessary to comply with our legal obligations under laws, court rulings, or other appropriate legal mechanisms, e.g. to respond to lawful requests by public authorities;
• Where you have given us your consent to disclose your personal information to carefully chosen third parties, so that they may contact you (including by SMS and e-mail) with products and services that they think may interest you.

Where do we store your data?

• We will store your personal data within the UK in most situations. However, we may store Website data (but not business partner or customer data) in the EU under GDPR. Between the UK and the EU there is an Adequacy Agreement on the levels of Data Protection applied. However, your personal data could, in exceptional situations, be transferred to and processed outside of the EU/EEA.
• Please note that privacy laws in countries outside of the EU/EEA may not be the same as, and in some cases may be less protective than, privacy laws in your country. However, we will ensure that your personal data is processed safely and that adequate safeguards (e.g. standard Model Clauses and Privacy Shield) are in place to protect your personal data.
• You can always contact us for more information about the applicable safeguards.

Who can access your data?

We will not disclose, sell, or rent your personal information to any third party unless you have consented to this. If you do consent but later change your mind, you may contact us using the contact details above and we will cease any such activity.

However, if a third party acquires all (or substantially all) of our business and/or assets, we may disclose your personal information to that third party in connection with the acquisition. We may also disclose your personal information where we are required to do so by applicable laws, by a governmental body, or by a law enforcement agency.

We may share your personal information with the following parties:

• Our employees. We share your personal data with our employees. However, we will restrict access to only those of our employees who need your information to perform their jobs;
• Group companies. We may share your personal data with other companies within Redwood Technologies Group Limited;
• Service providers. We will share your personal data with service providers who help us provide the Website to you, or who supply other IT services to us that require the processing of personal data. Most of our service providers act as our data processors and may only process your personal data in accordance with our instructions, or to fulfil their legal obligations;
• Public authorities. Legal obligations may require us to share information about you, e.g. to respond to lawful requests from law enforcement agencies, regulatory agencies, and other public and government authorities. Such authorities are data controllers for their processing of your personal data;
• Legal processes. We may disclose personal data about you to courts, legal advisors and other parties when needed in connection with a legal process, e.g. to enforce our terms and conditions or to protect our rights.

Finally, we may also collect anonymized details about visitors to our Website for the purposes of aggregate statistics or other reporting. However, no single individual will be identifiable from the anonymized details we collect for these purposes.

How long do we keep your personal data?

How long we need to keep your data depends on the context, and cannot be specified in advance in all cases. When we no longer need your data, we will either delete it or anonymise it. We regularly review our need to keep your data, taking into account the applicable legislation.

• Contact details and messages. Normally, we will process your contact details and messages for as long as is motivated by the context, in order to respond to and handle your messages;
• Browser and device data. We keep browser and device data up to 30 days after collection;
• Direct marketing. We will process your contact details (e.g. name and email address) for marketing purposes until you unsubscribe from our mailings.
  We may keep your personal data for longer where it is necessary to comply with our legal obligations. We may also keep certain personal data during relevant liability periods.

International transfers

We may transfer personal information that we collect from you to third party data processors located in countries that are outside of the UK in connection with the above purposes. By continuing to use the Website, you consent to our making such transfers. Please be aware that countries that are outside the UK may not offer the same level of data protection as the UK; however, we will ensure that any transfer will continue to be governed by this privacy and cookies policy.

What are your rights?

Where applicable to you, you have the following rights in respect of our processing of your personal data:

• Right to object. You have the right to object to processing based on legitimate interest. You can contact us for more information on the balance test that we have made. You also have an absolute right to object to Direct Marketing;
• Right to access and transfer your data. You have the right to request a copy of the personal data we process about you, together with additional information on how the data have been collected, processed, shared, etc. You may also have the right to transfer your personal data to another data controller;
• Right to rectification. You have the right to correct inaccurate or incomplete information about yourself;
• Right to erasure (also known as the ‘right to be forgotten’). You have the right to request that we delete personal data about you;
• Right to restriction. You have the right to request that the processing of your personal data should be limited until inaccurate or incomplete information about you has been corrected, or until an objection from you has been handled;
• Right to withdraw your consent. You may withdraw, at any time, any consent that you have given to us. However, please note that such withdrawal will not affect any processing that has already taken place.

You can read more about your rights here.

Want to exercise your rights? Please contact us by telephone and ask for the Data Protection Officer, or email us at: dpo@jlspfcw.com

How do we protect your personal data?

We want you to feel confident about providing us with your personal data at all times. We have taken appropriate security measures to protect your personal data against unauthorized access, alteration and erasure.

Should a security breach occur that may materially impact you or your personal data (e.g. risk of fraud or identity theft), we will contact you to explain what action you can take to mitigate potential adverse effects of the breach.

Complaints

Should you feel that we have not complied with our obligations regarding your personal data, please let us know using the contact details above and we will address your concerns.

You may also raise your concern through the Information Commissioner’s Office (the supervisory authority in the United Kingdom):

• Telephone: 0303 123 1113; or
• Through their website: http://ico.org.uk/make-a-complaint/

Alternatively, you may raise your concern with the supervisory authority in the country where you live or work.

Security

We work hard to keep your data safe. We use a combination of technical and organizational measures to ensure, as far as is reasonably possible, the confidentiality, integrity, and availability of the personal information that you provide to us. However, no transmission over the Internet can ever be guaranteed to be secure. Consequently, please note that we cannot guarantee the security of any personal information that you transfer to us over the Internet.

Links to other websites

The Website contains links to other websites operated by third parties. Please note that this privacy and cookies policy applies only to the personal information that we collect through the Website, and we cannot be responsible for personal information that third parties may collect, store, or use through their websites. You should always read carefully the privacy and cookies policy of each website you visit.

Access by children

We do not and will not knowingly collect information from any unsupervised child under the age of 18. If you are under the age of 18, you may not use the Website unless you have the consent of, and are supervised by, a parent or guardian.

Cookies

Like most companies, we use cookies and similar technologies on the Website. You can read our cookie policy below to learn more about what cookies we use and how to control them.

We use cookies on the Website to provide you with an optimal and personalized user experience. Cookies are used to outline which parts of the Website you are using and how often. Cookies can also optimize your visits, by storing your passwords and other preferences, for your convenience.

Cookies are small, often encrypted text files, located in browser directories. They are used by web developers to help users to navigate their websites efficiently, and to perform certain functions. Cookies are created when a user’s browser loads a particular website. The website sends information to the browser, which then creates a text file. Every time the user goes back to the same website, the browser retrieves this file and sends it to the website’s server. Cookies contain information that is transferred to your computer’s hard drive, but they do not contain personal information that can be read by others. More information can be found at allaboutcookies.org.

We use the following cookies:

• Strictly necessary cookies. These are cookies that are required for the operation of the Website. They include, for example, cookies that enable you to log in to secure areas of the Website;
• Performance cookies. These allow us to recognize and count the number of visitors to the Website, and to see how visitors move around the Website when they are using it. This helps us to improve the way the Website works, for example by ensuring that users are finding what they are looking for easily.

Most web browsers are configured to automatically accept cookies as the default setting. If you do not want to receive cookies, you can block them by activating the setting on your browser that allows you to refuse the setting of all or some cookies (use the ‘help’ function to get to the relevant setting). 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 the Website.

Changes to our privacy and cookies policy

Any changes we may make to our privacy and cookies policy in future will be posted on this page. Please check back frequently to see any updates or changes. Your continued use of the Website after any modification to the privacy and cookies policy will constitute your acceptance of such modification.

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