PRIVACY POLICY

Last updated May 14, 2024

This privacy notice for Sessions UK ('we', 'us', or 'our'), describes how and why we might collect, store, use, and/or share ('process') your information when you use our services ('Services'), such as when you:

• Visit our website at https://sessionsuk.com, or any website of ours that links to this privacy notice
• Engage with us in other related ways, including any sales, marketing, or events

Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at /contact-us/.

SUMMARY OF KEY POINTS

This summary provides key points from our privacy notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use.

Do we process any sensitive personal information? We do not process sensitive personal information.

Do we receive any information from third parties? We do not receive any information from third parties.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so.

In what situations and with which types of parties do we share personal information? We may share information in specific situations and with specific categories of third parties.

How do we keep your information safe? We have organisational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure…

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information.

How do you exercise your rights? The easiest way to exercise your rights is by visiting /contact-us/, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.

Want to learn more about what we do (/what-we-do/) with any information we collect? Review the privacy notice in full.

TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE PROCESS YOUR INFORMATION?
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
6. HOW LONG DO WE KEEP YOUR INFORMATION?
7. HOW DO WE KEEP YOUR INFORMATION SAFE?
8. DO WE COLLECT INFORMATION FROM MINORS?
9. WHAT ARE YOUR PRIVACY RIGHTS?
10. CONTROLS FOR DO-NOT-TRACK FEATURES
11. DO WE MAKE UPDATES TO THIS NOTICE?
12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
13. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us (/about-us/) when you express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions… The personal information we collect may include the following:

• names
• phone numbers
• email addresses
• contact preferences

Sensitive Information. We do not process sensitive information.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity… but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information…

Like many businesses, we also collect information through cookies and similar technologies. You can find out more about this in our Cookie Notice: /cookie-policy/.

The information we collect includes:

• Log and Usage Data. …service-related, diagnostic, usage, and performance information our servers automatically collect… may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take…), device event information (such as system activity, error reports (sometimes called 'crash dumps'), and hardware settings).
• Device Data. …information about your computer, phone, tablet, or other device… may include your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.
• Location Data. …information about your device's location, which can be either precise or imprecise… we may use GPS and other technologies to collect geolocation data… You can opt out… by refusing access… or by disabling your Location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law…

We process your personal information for a variety of reasons… including:

• To deliver and facilitate delivery of services to the user.
• To respond to user inquiries/offer support to users.
• To send administrative information to you.
• To fulfil and manage your orders. …orders, payments, returns, and exchanges made through the Services.
• To enable user-to-user communications.
• To save or protect an individual's vital interest.

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e. legal basis) to do so under applicable law…

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases… we may rely on the following:

• Consent. …You can withdraw your consent at any time.
• Performance of a Contract.
• Legal Obligations. …cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights…
• Vital Interests.

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this section and/or with the following categories of third parties.

Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents… We have contracts in place… The categories of third parties we may share personal information with are as follows:

• Data Analytics Services
• Social Networks

We also may need to share your personal information in the following situations:

• Business Transfers. …in connection with… any merger, sale of company assets, financing, or acquisition…
• When we use Google Analytics. …The Google Analytics Advertising Features that we may use include: Google Analytics Demographics and Interests Reporting. To opt out… visit https://tools.google.com/dlpage/gaoptout. You can opt out… through Ads Settings (https://adssettings.google.com/)… Other opt out means include https://optout.networkadvertising.org/ and https://www.networkadvertising.org/mobile-choice. For more information… visit the Google Privacy & Terms page (https://policies.google.com/privacy).
• When we use Google Maps Platform APIs. …(e.g. Google Maps API, Places API). We obtain and store on your device ('cache') your location…
• Business Partners.

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels)… Specific information… is set out in our Cookie Notice: /cookie-policy/.

6. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary…

We will only keep your personal information for as long as it is necessary… unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). When we have no ongoing legitimate business need… we will either delete or anonymise such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

7. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organisational and technical security measures.

We have implemented appropriate and reasonable technical and organisational security measures… However, despite our safeguards… no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure… transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

8. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

…By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor… If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data… If you become aware of any data we may have collected from children under age 18, please contact us at enquiry@sessionsuk.com.

9. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: In some regions, such as the European Economic Area (EEA), United Kingdom (UK), and Switzerland, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.

In some regions… you have certain rights… These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing…; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making…

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority (https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm) or UK data protection authority (https://ico.org.uk/make-a-complaint/data-protection-complaints/data-protection-complaints/).

If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner (https://www.edoeb.admin.ch/edoeb/en/home.html).

Withdrawing your consent: …you have the right to withdraw your consent at any time… However… this will not affect the lawfulness of the processing before its withdrawal…

Cookies and similar technologies: Most Web browsers are set to accept cookies by default… see our Cookie Notice: /cookie-policy/.

If you have questions or comments about your privacy rights, you may email us at /contact-us/.

10. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems… include a Do-Not-Track ('DNT') feature… At this stage no uniform technology standard for recognising and implementing DNT signals has been finalised. As such, we do not currently respond to DNT browser signals…

11. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

…The updated version will be indicated by an updated 'Revised' date… If we make material changes… we may notify you either by prominently posting a notice of such changes or by directly sending you a notification…

12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may email us at enquiry@sessionsuk.com or contact us by post at:

13. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, please visit: /contact-us/.