Last updated: 25th April 2018
We are committed to safeguarding the privacy of our website visitors; Trieste Group LLP t/a Habit Action complies with the principles of the Data Protection Act 1998, the Privacy and Electronic Communications Regulations 2003, as amended 2011 and the General Data Protection Regulation (GDPR) (EU) 2016/679. This policy sets out how we will treat your personal information.
Trieste Group LLP t/a Habit Action and its limited company’s websites contain hyperlinks to websites owned and operated by third parties and these websites will have their own privacy notices and Trieste Group LLP t/a Habit Action encourage users to review them. Trieste Group LLP t/a Habit Action does not accept any responsibility or liability for the practices of such third-party websites and users should read carefully their privacy statements. Trieste Group LLP t/a Habit Action understands that some communications may be relevant to users and others are not and some unsolicited communications are unwelcome, so it is fully committed to ensuring that the rights and obligations set out in the Data Protection Act 1998 and the Privacy and Electronic Communications Regulations 2003, as amended 2011, are respected.
2. Collecting personal information
Trieste Group LLP t/a Habit Action may ask for limited personal information when users register to receive a service from us. The information collected will vary depending on the part of the website visited, but only by supplying this data, is Trieste Group LLP t/a Habit Action able to provide users with the services requested.
We may collect, store and use the following kinds of personal information:
- information about your computer and about your visits to and use of this website (including your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths);
- information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (including your name and email address);
- information that you post to our website for publication on the internet (including your user name, your profile pictures and the content of your posts);
- information contained in or relating to any communications that you send to us or send through our website (including the communication content and meta data associated with the communication); and
- any other personal information that you choose to send to us.
Before you disclose to us the personal information of another person, you must obtain that person’s consent to both the disclosure and the processing of that personal information in accordance with the terms of this policy.
When we use this data to contact you we will always give you the opportunity to opt-out of receiving further communications from us.
3. Using your personal information
Personal information submitted to us through our website will be used for the purposes specified in this policy or on the relevant pages of the website.
We may use your personal information to:
- administer our website and business;
- send you non-marketing commercial communications;
- send you email notifications that you have specifically requested;
- send you our email newsletter, if you have requested it (you can inform us at any time if you no longer require the newsletter);
- send you marketing communications relating to our business or the businesses of carefully-selected third parties which we think may be of interest to you, by post or, where you have specifically agreed to this, by email or similar technology (you can inform us at any time if you no longer require marketing communications);
- deal with enquiries and complaints made by or about you relating to our website;
- deal with Trieste Group LLP software support requests made by you;
- deal with enquires, requests and registration for My Spacestor accounts and profiles made by you;
We will not, without your express consent, supply your personal information to any third party for the purpose of their or any other third party’s direct marketing.
4. Disclosing personal information
We may disclose your personal information to any of our employees, officers, insurers, professional advisers, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes set out in this policy.
We may disclose your personal information 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 set out in this policy.
We may disclose your personal information:
- to the extent that we are required to do so by law;
- in connection with any ongoing or prospective legal proceedings;
- in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk);
- to the purchaser (or prospective purchaser) of any business or asset that we are (or are contemplating) selling; and
- to any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.
Except as provided in this policy, we will not provide your personal information to third parties.
5. International data transfers
Information that we collect may be stored and processed in and transferred between any of the countries in which we operate in order to enable us to use the information in accordance with this policy.
Information that we collect may be transferred to the following countries which do not have data protection laws equivalent to those in force in the European Economic Area: the United States of America, Russia, Japan, China and India.
You expressly agree to the transfers of personal information described in this Section 5.
6. Retaining personal information
This Section 6 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 information.
Personal information that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes. We will send email and other marketing communications for a maximum of 24 months after initial collection unless there has been some subsequent positive contact (eg purchase, clicking email, visiting website).
Notwithstanding the other provisions of this Section 6, we will retain documents (including electronic documents) containing personal data:
- to the extent that we are required to do so by law;
- if we believe that the documents may be relevant to any ongoing or prospective legal proceedings; and
- in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).
7. Security of your personal information
We will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information.
We will store all the personal information you provide on our secure (password and firewall-protected) servers.
You acknowledge that the transmission of information over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
You are responsible for keeping the password you use for accessing our website confidential; we will not ask you for your password (except when you log in to our website).
You should check this page occasionally to ensure you are happy with any changes to this policy.
9. Opting Out of the various activities
If you do not wish to receive certain types of communication, just let us know. Any marketing communications you receive from us will always include a clear, simple method to ‘opt-out’ of future communications.
You may instruct us at any time not to process your personal information for marketing purposes. You will find our contact details below.
In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.
10. Your rights
You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to:
- the payment of a fee (currently fixed at GBP 10); and
- the supply of appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address).
We may withhold personal information that you request to the extent permitted by law.
11. Third party websites
Our website includes hyperlinks to, and details of, third party websites, social media and blogs.
We use third party organisations to manage some of our marketing processes. From time to time we may share your data with approved third party ad networks such as Google Ads, Linkedin, Facebook, Twitter and other similar platforms to enhance our marketing services.
We have no control over, and are not responsible for, the privacy policies and practices of third parties.
12. Updating information
Please let us know if the personal information that we hold about you needs to be corrected or updated.
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.
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.
We use both session and persistent cookies on our website. Cookies are used for the following purposes:
- Identifying users when they sign into a website, allowing them to see a customised version and therefore eliminating the need to re-enter their log-in details.
- Tracking use of the Trieste Group LLP t/a Habit Action and its limited company’s websites to better develop them in the future.
- To speed up searches
Most browsers allow you to refuse to accept cookies; for example:
- in Internet Explorer (version 10) you can block cookies using the cookie handling override settings available by clicking “Tools”, “Internet Options”, “Privacy” and then “Advanced”;
- in Firefox (version 24) you can block all cookies by clicking “Tools”, “Options”, “Privacy”, selecting “Use custom settings for history” from the drop-down menu, and unticking “Accept cookies from sites”; and
- in Chrome (version 29), you can block all cookies by accessing the “Customise and control” menu, and clicking “Settings”, “Show advanced settings” and “Content settings”, and then selecting “Block sites from setting any data” under the “Cookies” heading.
Blocking all cookies will have a negative impact upon the usability of many websites.
If you block cookies, you will not be able to use all the features on our website.
You can delete cookies already stored on your computer; for example:
- in Internet Explorer (version 10), you must manually delete cookie files (you can find instructions for doing so at http://support.microsoft.com/kb/278835);
- in Firefox (version 24), you can delete cookies by clicking “Tools”, “Options” and “Privacy”, then selecting “Use custom settings for history”, clicking “Show Cookies”, and then clicking “Remove All Cookies”; and
- in Chrome (version 29), you can delete all cookies by accessing the “Customise and control” menu, and clicking “Settings”, “Show advanced settings” and “Clear browsing data”, and then selecting “Delete cookies and other site and plug-in data” before clicking “Clear browsing data”.
Deleting cookies will have a negative impact on the usability of many websites.
13. Data protection registration
We are registered as a data controller with the UK Information Commissioner’s Office.
14. Our details
This website is owned and operated by Trieste Group LLP t/a Habit Action .
We are registered in England and Wales under registration number , and our registered office is at, United Kingdom.
Our principal place of business is at Noble House, Eaton Road, Hemel Hempstead, Hertfordshire, HP2 7UB, United Kingdom.
You can contact us by writing to the business address given above, by using our website contact form, by email to firstname.lastname@example.org or by telephone on +44 (0)20 8991 6057.