45Red Ltd is committed to protecting the privacy of our customers and website visitors. We understand the importance you place on the privacy and security of information which personally identifies you, and we value our relationship with you. Whether you are a first time visitor or a regular user, we take your privacy seriously.
collected by us or provided by you in relation to your use of the Website.
Definitions and interpretation
Data collectively all information that you submit to 45red ltd via the Website. This definition incorporates,
where applicable, the definitions provided in the Data Protection Laws;
Cookies a small text file placed on your computer by this Website when you visit certain parts of the Website and
/or when you use certain features of the Website. Details of the cookies used by this Website are set out
in the clause below ( Cookies);
Data Protection Laws
any applicable law relating to the processing of personal Data, including but not limited to the Directive
96/46/EC (Data Protection Directive) or the GDPR, and any national implementing laws, regulations
and secondary legislation, for as long as the GDPR is effective in the UK;
GDPR the General Data Protection Regulation (EU) 2016/679;
45red ltd, we or us 45red ltd, a company incorporated in England and Wales with registered number 09743022 whose
registered office is at Suite C, Compass House, N Petherton, Somerset, TA6 6FA;
UK and EU Cookie Law the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended by the
Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011;
User or you any third party that accesses the Website and is not either (i) employed by 45red ltd and acting in the
course of their employment or (ii) engaged as a consultant or otherwise providing services to 45red ltd
and accessing the Website in connection with the provision of such services; and
Website the website that you are currently using, www.45red.com, and any sub-domains of this site unless
expressly excluded by their own terms and conditions.
a. the singular includes the plural and vice versa;
b. references to sub-clauses, clauses, schedules or appendices are to sub-clauses, clauses, schedules or appendices of
c. a reference to a person includes firms, companies, government entities, trusts and partnerships;
d. "including" is understood to mean "including without limitation";
e. reference to any statutory provision includes any modification or amendment of it;
any websites that can be accessed from this Website including, but not limited to, any links we may provide to social
4. For purposes of the applicable Data Protection Laws, 45red ltd is the "data controller". This means that 45red ltd
determines the purposes for which, and the manner in which, your Data is processed.
5. We may collect the following Data, which includes personal Data, from you:
b. job title;
d. contact Information such as email addresses and telephone numbers;
e. demographic information such as postcode, preferences and interests;
f. IP address (automatically collected);
g. web browser type and version (automatically collected);
h. operating system (automatically collected);
i. a list of URLs starting with a referring site, your activity on this Website, and the site you exit to (automatically
How we collect Data
6. We collect Data in the following ways:
a. data is given to us by you ; and
b. data is collected automatically.
Data that is given to us by you
7. 45red ltd will collect your Data in a number of ways, for example:
a. when you contact us through the Website, by telephone, post, e-mail or through any other means;
b. when you register with us and set up an account to receive our products/services;
c. when you complete surveys that we use for research purposes (although you are not obliged to respond to them);
d. when you enter a competition or promotion through a social media channel;
e. when you make payments to us, through this Website or otherwise;
f. when you elect to receive marketing communications from us;
g. when you use our services;
Data that is collected automatically
8. To the extent that you access the Website, we will collect your Data automatically, for example:
a. we automatically collect some information about your visit to the Website. This information helps us to make
improvements to Website content and navigation, and includes your IP address, the date, times and frequency with
which you access the Website and the way you use and interact with its content.
b. we will collect your Data automatically via cookies, in line with the cookie settings on your browser. For more
information about cookies, and how we use them on the Website, see the section below, headed "Cookies".
Our use of Data
9. Any or all of the above Data may be required by us from time to time in order to provide you with the best possible
service and experience when using our Website. Specifically, Data may be used by us for the following reasons:
a. internal record keeping;
b. improvement of our products / services;
c. transmission by email of marketing materials that may be of interest to you;
d. contact for market research purposes which may be done using email, telephone, fax or mail. Such information
may be used to customise or update the Website;
10. We may use your Data for the above purposes if we deem it necessary to do so for our legitimate interests. If you are
not satisfied with this, you have the right to object in certain circumstances (see the section headed "Your rights"
11. For the delivery of direct marketing to you via e-mail, we'll need your consent, whether via an opt-in or soft-opt-in:
a. soft opt-in consent is a specific type of consent which applies when you have previously engaged with us (for
example, you contact us to ask us for more details about a particular product/service, and we are marketing similar
products/services). Under "soft opt-in" consent, we will take your consent as given unless you opt-out.
b. for other types of e-marketing, we are required to obtain your explicit consent; that is, you need to take positive
and affirmative action when consenting by, for example, checking a tick box that we'll provide.
c. if you are not satisfied about our approach to marketing, you have the right to withdraw consent at any time. To
find out how to withdraw your consent, see the section headed "Your rights" below.
12. When you register with us and set up an account to receive our services, the legal basis for this processing is the
performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
Who we share Data with
13. We may share your Data with the following groups of people for the following reasons:
a. our employees, agents and/or professional advisors - for marketing purposes;
Keeping Data secure
14. We will use technical and organisational measures to safeguard your Data, for example:
a. access to your account is controlled by a password and a user name that is unique to you.
b. we store your Data on secure servers.
15. Technical and organisational measures include measures to deal with any suspected data breach. If you suspect any
misuse or loss or unauthorised access to your Data, please let us know immediately by contacting us via this e-mail
16. If you want detailed information from Get Safe Online on how to protect your information and your computers and
devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get
Safe Online is supported by HM Government and leading businesses.
17. Unless a longer retention period is required or permitted by law, we will only hold your Data on our systems for the
18. Even if we delete your Data, it may persist on backup or archival media for legal, tax or regulatory purposes.
19. You have the following rights in relation to your Data:
a. Right to access - the right to request (i) copies of the information we hold about you at any time, or (ii) that we
modify, update or delete such information. If we provide you with access to the information we hold about you,
we will not charge you for this, unless your request is "manifestly unfounded or excessive." Where we are legally
permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.
b. Right to correct - the right to have your Data rectified if it is inaccurate or incomplete.
c. Right to erase - the right to request that we delete or remove your Data from our systems.
d. Right to restrict our use of your Data - the right to "block" us from using your Data or limit the way in which
we can use it.
e. Right to data portability - the right to request that we move, copy or transfer your Data.
f. Right to object - the right to object to our use of your Data including where we use it for our legitimate interests.
20. To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Data
(where consent is our legal basis for processing your Data), please contact us via this e-mail address: firstname.lastname@example.org.
21. If you are not satisfied with the way a complaint you make in relation to your Data is handled by us, you may be able
to refer your complaint to the relevant data protection authority. For the UK, this is the Information Commissioner's
Office (ICO). The ICO's contact details can be found on their website at https://ico.org.uk/.
22. It is important that the Data we hold about you is accurate and current. Please keep us informed if your Data changes
during the period for which we hold it.
Links to other websites
23. This Website may, from time to time, provide links to other websites. We have no control over such websites and are
Changes of business ownership and control
24. 45red ltd may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of
control of all or part of 45red ltd. Data provided by Users will, where it is relevant to any part of our business so
transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of
25. We may also disclose Data to a prospective purchaser of our business or any part of it.
26. In the above instances, we will take steps with the aim of ensuring your privacy is protected.
experience of using the Website and to improve our range of products and services. 45red ltd has carefully chosen
these Cookies and has taken steps to ensure that your privacy is protected and respected at all times.
28. All Cookies used by this Website are used in accordance with current UK and EU Cookie Law.
29. Before the Website places Cookies on your computer, you will be presented with a message bar requesting your
consent to set those Cookies. By giving your consent to the placing of Cookies, you are enabling 45red ltd to provide a
better experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain
features of the Website may not function fully or as intended.
30. You can find a list of Cookies that we use in the Cookies Schedule.
31. You can choose to enable or disable Cookies in your internet browser. By default, most internet browsers accept
Cookies but this can be changed. For further details, please consult the help menu in your internet browser.
32. You can choose to delete Cookies at any time; however you may lose any information that enables you to access the
Website more quickly and efficiently including, but not limited to, personalisation settings.
33. It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance
provided by the developer of your internet browser if you are unsure about adjusting your privacy settings.
34. For more information generally on cookies, including how to disable them, please refer to aboutcookies.org. You will
also find details on how to delete cookies from your computer.
illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the
37. Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a
waiver of that, or any other, right or remedy.
38. This Agreement will be governed by and interpreted according to the law of England and Wales. All disputes arising
under the Agreement will be subject to the exclusive jurisdiction of the English and Welsh courts.
required by law. Any changes will be immediately posted on the Website and you are deemed to have accepted the
You may contact 45red ltd by email at email@example.com.
Below is a list of the cookies that we use. We have tried to ensure this is complete and up to date, but if you think that we
have missed a cookie or there is any discrepancy, please let us know.