Dumfries and Galloway Online

Privacy & Cookies Policy

1. Introduction

1.1    We are committed to safeguarding the privacy of our website visitors and service users.

1.2    This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.

1.3    By using our website and agreeing to this policy, you consent to our use of cookies in accordance with the terms of this policy.

1.4    Our website/email marketing system incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can specify whether you would like to receive direct marketing communications and limit the publication of your information. You can access the privacy controls via https://www.dumfries-and-galloway.co.uk/privacy.html.

1.5    In this policy, "we", "us" and "our" refer to web-link trading as Dumfries and Galloway Online.  For more information about us, see Section 14.

2.     How we use your personal data

2.1    In this Section 2 we have set out:

(a)    the general categories of personal data that we may process;
(b)    in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
(c)    the purposes for which we may process personal data; and
(d)    the legal bases of the processing.

2.2    We may process data about your use of our website and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.  

2.3    We may process your personal data that are provided in the course of the use of our services ("service data"). The service data may include company name, address and contact details. The service data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is the performance of an agreement between you and us i.e. for us to place advertising for your business on our web site at your request.  

2.4    We may process information that you post for publication on our website or through our services ("publication data"). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is the performance of an agreement between you and us i.e. for placing an event or listing on our web site at your request.

2.5    We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters ("notification data"). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is the performance of an agreement between you and us i.e. you signing up to our newsletter via the form on our web site.

2.6    We may process information contained in or relating to any communication that you send to us ("correspondence data"). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.

2.7    We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

2.8    We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

2.9    In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of 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.

2.10  Please do not supply any other person's personal data to us, unless we prompt you to do so.

3.     Providing your personal data to others

3.1    We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.

3.2    We may disclose your enquiry data to one or more of those selected third party suppliers of goods and services identified on our website for the purpose of enabling them to contact you so that they can offer, market and sell to you relevant goods and/or services. Each such third party will act as a data controller in relation to the enquiry data that we supply to it; and upon contacting you, each such third party will supply to you a copy of its own privacy policy, which will govern that third party's use of your personal data.

3.3    In addition to the specific disclosures of personal data set out in this Section 3, 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. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

4.     Retaining and deleting personal data

4.1    This Section 4 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

4.2    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.

4.3    We will retain your personal data as follows:

(a)    "service data"will be retained for so long as you are in agreement with us for your company to advertise on our web site. If you no longer wish to advertise, your data will be deleted from our systems.
(b)    "publication data"will be retained on our business email system until the data request has been added to our web site at which point the email will be deleted from our systems. Any listing on our web site will be retained until:
- an event has taken place;
- 2 months after a sales and wants listing has been posted;
- 2 months or 6 months after a property or general listing has been posted (depending on agreement with you);
- you request removal of the listing.
(c)    "notification data"will be retained until you unsubscribe from our mailing list which you can do at any time.
(d)    "correspondence data"will be retained until any query or request contained within the correspondence has been resolved.

4.4    Notwithstanding the other provisions of this Section 4, 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.

5.     Security of personal data

5.1    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.

5.2    We will store all your personal data on secure servers, personal computers and mobile devices, and in secure manual record-keeping systems if used.

5.3    The following personal data will be stored by us in encrypted form: your company name, advertising information and contact information.

5.4    Data relating to your enquiries and financial transactions that is sent from your web browser to our web server, or from our web server to your web browser, will be protected using encryption technology.

5.5    You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.

6.     Amendments

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

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

6.3    We may notify you of changes to this policy by email, unless you have explicitly requested that we do not do so.

7.     Your rights

7.1    In this Section 7, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

7.2    Your principal rights under data protection law are:

(a)    the right to access;
(b)    the right to rectification;
(c)    the right to erasure;
(d)    the right to restrict processing;
(e)    the right to object to processing;
(f)     the right to data portability;
(g)    the right to complain to a supervisory authority; and
(h)    the right to withdraw consent.

7.3    You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.

7.4    In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary:[for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.

7.5    In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

7.6    You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

7.7    You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.

7.8    You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

7.9    To the extent that the legal basis for our processing of your personal data is:

(a)    consent; or
(b)    that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,
and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

7.10  If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.

7.11  To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

7.12  You may exercise any of your rights in relation to your personal data by written notice to us, in addition to the other methods specified in this Section 7.

8.     Third party websites

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

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

9.     Updating information

9.1    Please let us know if the personal information that we hold about you needs to be corrected or updated.

10.   About cookies

10.1  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.

10.2  Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

10.3  Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

11.   Cookies that we use

11.1  We use cookies for the following purposes:

(a)    'necessary' - we use cookies to deliver our web site to you and to identify you when you visit our website and as you navigate our website - cookies used for this purpose are: BIGipServer#, TS#, CookieConsent; and
(b)    'statistics' - we use cookies to help us to analyse the use and performance of our website and services - cookies used for this purpose are: _ga, _gid, _gat.

Necessary cookies (3) help make a website usable by enabling basic functions like page navigation and access to secure areas of the website. The website cannot function properly without these cookies.

Name Provider Purpose Expiry Type
BIGipServer# dumfries-and-galloway.co.uk Used to distribute traffic to the website on several servers in order to optimise response times. Session HTTP Cookie
CookieConsent dumfries-and-galloway.co.uk Stores the user's cookie consent state for the current domain 1 year HTTP Cookie
TS# dumfries-and-galloway.co.uk Used to deliver our web site by our hosting provider Session HTTP Cookie

Statistic (3) cookies help website owners to understand how visitors interact with websites by collecting and reporting information anonymously.

Name Provider Purpose Expiry Type
_ga dumfries-and-galloway.co.uk Registers a unique ID that is used to generate statistical data on how the visitor uses the website. 2 years HTTP Cookie
_gat dumfries-and-galloway.co.uk Used by Google Analytics to throttle request rate Session HTTP Cookie
_gid dumfries-and-galloway.co.uk Registers a unique ID that is used to generate statistical data on how the visitor uses the website. Session HTTP Cookie

 

12.   Cookies used by our service providers

12.1  Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

Marketing (7) cookies are used to track visitors across websites. The intention is to display ads that are relevant and engaging for the individual user and thereby more valuable for publishers and third party advertisers.

Name Provider Purpose Expiry Type
BT tradedoubler.com Used to register what ads the user has seen. 1 year HTTP Cookie
collect google-analytics.com Used to send data to Google Analytics about the visitor's device and behaviour. Tracks the visitor across devices and marketing channels. Session Pixel Tracker
NID google.com Registers a unique ID that identifies a returning user's device. The ID is used for targeted ads. 6 months HTTP Cookie
PREF youtube.com Registers a unique ID that is used by Google to keep statistics of how the visitor uses YouTube videos across different websites. 8 months HTTP Cookie
UI tradedoubler.com Used to register what ads have been displayed to the user. 1 year HTTP Cookie
VISITOR_INFO1_LIVE youtube.com Tries to estimate the users' bandwidth on pages with integrated YouTube videos. 179 days HTTP Cookie
YSC youtube.com Registers a unique ID to keep statistics of what videos from YouTube the user has seen. Session HTTP Cookie

12.2  We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google's privacy policy is available at: https://www.google.com/policies/privacy/. The relevant cookies are: collect.

12.3  We use Google to deliver maps on our web site. Google gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google's privacy policy is available at: https://www.google.com/policies/privacy/. The relevant cookies are: NID.

12.4  We use YouTube to deliver relevant videos on our web site. This service is owned by Google who gather information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google's privacy policy is available at: https://www.google.com/policies/privacy/. The relevant cookies are: VISITOR_INFO1_LIVE, YSC, PREF.

12.5  We use Tradedoubler to deliver relevant adverts on our web site. Tradedoubler serves ads on websites using ad-serving technology. In doing so, one of their ad servers will place or read a unique ad-serving cookie on your computer and will use non-personal information about your browser and your activity at this site to serve ads on this and other sites. The ad-serving cookie is a persistent cookie. For more information about Tradedoubler ad serving or to opt-out of the Tradedoubler ad-serving cookie read the instructions on: http://www.tradedoubler.com/en/privacy-policy/. The relevant cookies are: BT, UI.

13.   Managing cookies

13.1  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?hl=en (Chrome);
(b)    https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
(c)    http://www.opera.com/help/tutorials/security/cookies/ (Opera);
(d)    https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(e)    https://support.apple.com/kb/PH21411 (Safari); and
(f)     https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).

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

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

14.   Our details  

14.1  This website is owned and operated by web-link.

14.2  Our principal place of business is at 12 Queensberry Terrace, Cummertrees, Annan DG12 5QF.

14.4  You can contact us:

(a)    by post, to [the postal address given above;
(b)    by using any of our website contact forms;
(c)    by telephone, on 01461 700545; or
(d)    by email, using info@dumfries-and-galloway.co.uk.

15.   Representative within the European Union

15.1  Our representative within the European Union with respect to our obligations under data protection law is Saskia Holling and you can contact our representative by using any of the methods listed in section 14.

16.   Data protection officer

16.1  Our data protection officer is Saskia Holling and you can contact them using any of the methods listed in section 14.