Privacy policy

1. Introduction

1.1  By accessing and using our website or our services, you provide your express and voluntary consent to the processing of your personal information by Outsourcery services Limited (“Outsourcery” or “we”) on the basis set out in this Privacy Policy.

1.2  We collect, use and, in some circumstances, share your personal information in and through this website and during the provision of services to you.

1.3  We respect your rights, including your right to protection against the unlawful collection, retention, sharing and use of such personal information.

1.4  The purpose of this Privacy Policy is to provide you with information about our information processing activities and the manner in which your rights are protected.

1.5  This Privacy Policy shall serve as a blanket notification to you about our processing activities, which will remain valid for as long as you are using our services, including the browsing of our website. You will not be notified separately on each occasion that we process the same personal information in the same way over the period of this Privacy Policy.

1.6  We may amend the provisions of this Privacy Policy to comply with any changes in the law, and/or pursuant to any changes to our information processing activities or privacy practices. Such amendments will be published on the website and will become operable from the date of such publication.

1.7  As far as possible, the provisions of this Privacy Policy are to be incorporated into any agreement between us.

2. Definitions and interpretation

2.1  In this Privacy Policy:

2.1.1  “consent” means any voluntary, specific and informed expression of will in terms of which permission is given by you or on your behalf for the processing of your personal information;

2.1.2  “data protection laws” means the data protection laws that are applicable to our relationship with you, and the provision of our services (such laws may include the European Union’s General Data Protection Regulation (“GDPR”), and the Data Protection Law Enforcement Directive, and/or the Protection of Personal Information Act of 2013, including any regulations or codes of conduct promulgated under it);

2.1.3  “direct marketing” means to approach you, either in person or by mail or electronic communication, for the direct or indirect purpose of promoting or offering to supply any goods or services to you;

2.1.4  “operator” means an outside third party who processes personal information for or on our behalf in terms of a contract or mandate;

2.1.5  “personal information” means any information linked to you or information that can identify you, including but not limited to:

2.1.5.1   information relating to your gender, nationality, ethnic or social origin age, language;

2.1.5.2   your e-mail address, physical address, telephone number, location information or online identifier;

2.1.5.3   your financial information including banking details and invoice information;

2.1.5.4   your personal opinions, views or preferences;

2.1.5.5   correspondence sent by you which is of a private or confidential nature;

2.1.5.6   your special personal information; and

2.1.5.7   your name, if it appears with other personal information relating to you, or if the disclosure of your name on its own would reveal further personal information about you;

2.1.6  “process or processing” means, in relation to personal information, any operation or activity or any set of operations, whether or not by automatic means, including:

2.1.6.1   the collection, receipt, recording, organisation, collation, storage, updating or modification, retrieval, alteration, consultation or use of that information;

2.1.6.2   dissemination by means of transmission, distribution or making available in any other form; or

2.1.6.3   merging, linking, as well as restriction, degradation, erasure or destruction of that information;

2.1.7  “special personal information” means any biometric information linked to you or or biometrical information that can identify you, including without limitation a photographic image of you; and

2.1.8  “services” means the services provided to you by us.

2.2 Any reference in this Privacy Policy to an act, regulation or other law is to the version of that law in force at the effective date of this Privacy Policy and includes any amendment or re-enactment made to that law after the effective date of this Privacy Policy.

3. Responsible party

3.1  We will be the party who will be collecting and processing your personal information and, as such, we are designated as the “responsible party” for the purposes of this Privacy Policy.

3.2  We may instruct third party operators from time to time to undertake certain processing activities relating to your personal information.

4. Personal information collected

4.1  We may collect the following personal information from you (and we have grouped this personal information together as follows):

4.1.1   Identity Data – which includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.

4.1.2   Contact Data– which includes your billing address, delivery address, email address and telephone numbers.

4.1.3   Financial Data– which includes bank account and payment card details.

4.1.4   Transaction Data– which includes details about payments to and from you and other details of products and services you have purchased from us.

4.1.5   Technical Data – which includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website.

4.1.6   Usage Data– which includes information about how you use our website, products and services.

4.1.7   Marketing and Communications Data– which includes your preferences in receiving marketing from us and our third parties and your communication preferences.

4.2  The supply of personal information by you to us is voluntary and not mandatory. However, if you refuse to supply any personal information, certain consequences may naturally flow from such a refusal, such as preventing us from concluding or performing any contract with you, or preventing us from complying with one or more of our obligations in law.

5. Purpose/s for collection and processing of personal information

5.1  We will only collect your personal information for a specific, explicitly defined and lawful purpose relating to our business functions or activities.

5.2 Such purposes may include the following:

5.2.1   to process your personal information in order to provide services;

5.2.2   to enter into a contract with you and/or to enable a partner or service provider to contact you and enter into a contract with you;

5.2.3   to perform any obligations under a contract with you;

5.2.4   to comply with a legal obligation;

5.2.5   to protect your legitimate interests (unless you have specifically objected in writing to all or some of the processing activities on reasonable grounds);

5.2.6   to pursue our own legitimate interests or the legitimate interests of a third party who we are sharing the information with (unless you have specifically objected in writing to all or some of the processing activities on reasonable grounds);

5.2.7   to process personal information for direct marketing purposes (only if you have opted in to receiving any direct marketing material);

5.2.8   to customise and display content including, but not limited to products, articles, listings and advertisement to you in a way that we feel may interest you or be most beneficial to you;

5.2.9   to send content including, but not limited to products, articles, listings and advertisement content to you via email or other electronic media, where you have consented to be contacted by us with such content;

5.2.10   to enable you to voluntarily participate in interactive features on our website; and

5.2.11   to notify you about changes to our website or services.

5.3  If we intend to process your personal information for any other purpose not listed above or which is otherwise not automatically permitted by law, we will ensure that we obtain your written consent to do so.

5.4  We will not sell your personal information to any third party without your prior written consent.

6. Collection directly from you

6.1  We will, as far as possible, always collect personal information about you directly from you, except in the following circumstances:

6.1 .1   where personal information is collected from a public record, or from another source if the information has already been made public by you;

6.1 .2   where you have given your written consent to us to collect your information from another source;

6.1 .3   where the collection of your personal information from another source will not prejudice any of your legitimate interests;

6.1 .4   where the collection of personal information from another source is necessary to maintain your legitimate interests or those of any third party that we intend sharing the information with;

6.1 .5   where the collection of personal information directly from you would prejudice the purpose for the collection; and/or

6.1 .6   where the collection of personal information directly from you is not reasonably practicable in the circumstances.

6.2  If we collect personal information from a source other than you, we will record in writing the details of that source, including the full names and contact details of that source where applicable.

6.3  Personal information may be collected from or supplied by you in any of the following ways:

6.13.1   when subscribing to a service;

6.13.2   when requesting further services or information from us;

6.13.3   when contacting us to report a problem with our website or the services or for any other reason; and/or

6.13.4   when completing any forms on our website or the websites of the third parties appointed to process such information.

6.4  You may visit our website without providing any personal information. However, our website’s servers may still collect technical information regarding the use of the website, which is aggregated for analytical purposes, technical maintenance and for improving the content offered on the website. Such information may include details of your visit, information about the your computer, including IP (Internet Protocol) address, operating system and browser type, your location, and usage information. You will not be identified from or by this information and we are entitled to copy, distribute or otherwise use such information without limitation.

7. Cookies

7.1  “Cookies” are small text files transferred by a webserver to your device and thereafter stored on your device. The types of information a Cookie collects includes your username, the date and time of your visits to the website, your browsing history and preferences.

7.2  We may use Cookies on our website to:

7.2.1   distinguish you from another person on the website;

7.2.2   remember your last session when you return to our website;

7.2.3   estimate our website’s audience size and usage patterns;

7.2.4   store information about your preferences, which allows us to customize our website and content according to your individual preferences; and

7.2.5   speed up searches on our website.

7.3  The provisions of this clause are only applicable to Cookies used by us. In some instances, third-party service providers may use Cookies on our website. We cannot and do not control or access Cookies used by third party service providers and take no responsibility therefor.

7.4  You have the right and ability to either accept or decline the use of Cookies on your web browser. However, declining the use of Cookies may limit your access to certain features on our website.

8. General conditions for processing personal information

8.1  We will comply with all laws, contracts or regulations when we your personal information.

8.2  We will not act unreasonably when processing your personal information. This means that we will collect and process your personal information in a way that you can reasonably expect and in a way that is fair.

8.3  We will respect your right to privacy at all times. If there is another way in which we can achieve the same goal without posing any risk of harm to your privacy rights, then we will choose that option.

8.4  Similarly, if we need to process personal information but there are less privacy-invasive methods of collecting, using and sharing that information, then we will use those methods.

8.5  We will ensure that your personal information that is collected and processed is and remains relevant to the identified purpose/s for such processing, and that such information is and remains adequate, but not excessive, for achieving the identified purpose/s.

8.6  If there are any alternative ways to achieve the identified purpose/s without processing your personal information, we will not process your personal information.

8.7  We will ensure that our processing activities are proportionate to achieving the identified purpose/s and that no less invasive measures are available to achieve the same purpose/s.

8.8  We will ensure that, regardless of the stated purpose/s for processing personal information, your rights and interests will not be unnecessarily prejudiced or infringed, unless it cannot be avoided, and then in such cases, we will ensure that our own rights and/or interests justify such prejudice or infringement taking place.

8.9  Once we have achieved the purpose for the collection of your personal information, we will destroy or delete such information, unless you have directed otherwise in writing, or if we are required by law to retain the information for a longer period of time.

8.10  If we no longer need to process personal information to achieve the purpose originally specified, then we will stop using that information.

9. Disclosure and sharing of personal information

9.1  We may share your with our partners and/or service providers, in order to enable the partner and/or service provider to contact you and, if applicable, to conclude a transaction with you.

9.2  We may, in the course of providing any content or services on our website, or for the purposes of concluding or performing any other services or transaction with you, share certain personal information with third party operators who perform certain processing activities on our behalf.

9.3  You will be advised of the information shared and the categories of third party operators with whom it is shared prior to it being shared.

9.4  We may also share aggregated information about you and your usage patterns. We may also use such aggregated information to help advertisers target specific audiences. Such aggregated information will be de-identified and your personal information will not be disclosed.

9.5  Other than as stated above, we will not share your personal information with any third parties unless we have your express consent to do so.

10. Your rights in relation to the processing of your personal information

You will have the following rights in relation to the processing of your personal information:

10. 1  to access and correct any of your personal information held by us (you will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances);

10. 2  to object to the processing of your personal information; and

10. 3  to lodge a complaint about us.

11. Further processing

11.1  We will not process your personal information for any purpose not previously specified, except in the following circumstances:

11.1.1   where you have consented to such further processing;

11.1.2   where the further processing is necessary for the exercise of any contractual rights or the fulfillment of any obligations between us;

11.1.3   where the further processing activities are linked to or compatible with the original purpose;

11.1.4   where the further processing is necessary for the prevention, detection, investigation, prosecution and punishment of an offence;

11.1.5   where the further processing is necessary to enforce any law;

11.1.6   where the further processing is necessary for the conduct of legal proceedings in any court or tribunal that have commenced or are reasonably contemplated;

11.1.7   where the further processing is necessary to prevent or mitigate a serious and imminent threat to your life or that of another individual; and/or

11.1.8   where the further processing is necessary for historical, statistical or research purposes.

11.2  We will ensure that if we intend on processing personal information for other purposes not previously specified, we will notify you of such further purposes and the possible consequences of the intended further processing.

12. Accuracy, correctness and completeness of personal information

12.1  We will take reasonably practicable steps to ensure that the personal information kept by us is complete, accurate, not misleading and is updated when necessary.

12.2  However, if you are aware of any personal information in our custody that is incorrect, inaccurate or which needs to be updated, you must make a written request to us to update or correct the relevant information.

12.3  If you have contested the accuracy of any personal information being used by us, we will immediately stop using that information until its accuracy has been verified.

12.4  We reserve our right to only adhere to a request from you in terms of clause 12.2 if the correction or updating of that information will result in the personal information being correct and accurate.

12.5  Where personal information that has been shared by us with a third party is subsequently updated or corrected, we will ensure that all third parties, with whom that information was shared, receive the updated and/or corrected version of the information as soon as it has been updated and/or corrected.

13. Security safeguards

13.1  We are committed to protecting the personal information in our custody against any loss of, damage to or unauthorised destruction of that information, and to preventing any unauthorised parties from accessing that information.

13.2  We take steps to continually identify and document any risks to the personal information we have in our possession or under our control and that appropriate security safeguards are in place against those risks.

13.3  We will ensure that in any contracts entered into with third party operators who process personal information on our behalf, include the following obligations:

13.3.1   the operator shall not process any personal information without our knowledge and authority;

13.3.2   the operator shall treat all personal information given to it as confidential and shall not disclose it to any unauthorised third parties;

13.3.3   the operator shall establish and maintain adequate security measures which are the same or offer similar protection over the personal information as that employed by us;

13.3.4   the operator shall notify us immediately where there are reasonable grounds to believe that any personal information has been leaked to or accessed by any unauthorised person;

13.3.5   if the operator is situated in another country, it must comply with the data protection laws in that country and be able to provide verification that it is so compliant; and

13.3.6   if an operator is legally obliged to disclose any personal information processed by them on our behalf to other parties, it must notify us beforehand to enable us and/or you to protect your rights if necessary.

13.4  We will ensure that all personal information on our systems is properly backed-up.

13.5  Our website is protected by reCAPTCHA and the Google Privacy Policyand Terms of Service

14. Notification of breach of security

14.1  If your personal information is inadvertently leaked or our security has been unlawfully breached by any unauthorised party, we will immediately contact you at your last known email address or contact details or by the quickest means possible.

14.2  We will provide sufficient information to you to allow you to take the necessary protective measures against the potential consequences of the compromise, or we will advise you of the steps to be taken by you and the possible consequences that may ensue from the breach.

15. Decisions based on personal information processed

15.1  If we are required to make a decision about you using any personal information that has been obtained, we will ensure that a record of such information and the decision made is kept for a reasonable period of time to give you an opportunity to request access to that record.

15.2  We will allow you a reasonable opportunity to make representations before any decision is made solely on the basis of the personal information processed, if that decision will affect your legal position, or will otherwise adversely affect you in some manner or form.

15.3  We will always ensure that the underlying logic behind any decision made pursuant to the automated processing of personal information is sound and that this underlying logic can be communicated to you to enable you to make representations.

15.4  If we have made a decision based on incorrect personal information, we will immediately revisit that decision as soon as we become aware of the error or inaccuracy of that information.

16. Linked third party websites

16.1  Our website may contain links or references to other websites, including those of our data processors or advertisers (“third party websites”) which are not under our

16.2  The provisions of this Privacy Policy are not applicable to third party websites and we will not be responsible for the information processing practices and/or privacy policies of those third party websites, or the cookies that those websites may use.

17. Direct marketing

17.1  You hereby consent to the processing of your personal information for the purpose of direct marketing by means of electronic communications including automatic calling machines, SMS’s or electronic mail.

17.2  We will only send electronic communications to you for the purpose of marketing similar products or services offered by us, with your consent as provided in clause 1.

17.3  You may object, free of charge, and without unnecessary formality, to the use of your details either when the information was first collected from you or when each subsequent electronic communication is sent to you by us.

17.4  You can opt out of receiving further marketing communications by un-checking certain boxes on the forms used on the website to collect your personal information, or by contacting

18. Children’s personal information

We will not process any personal information relating to a person under the age of 18 years unless we have obtained consent from that person’s parent or legal guardian. If our website is being accessed by the parent or guardian of a child under the age of 18 years, and personal information pertaining to that child is being provided by the parent or guardian, then they hereby expressly consent to us processing such information according to the further provisions of this Privacy Policy. Our website is not intended for children and we do not knowingly collect personal information relating to children.

19. Cross border transfers of personal information

19.1  We may transfer personal information to another country in the following circumstances:

19.1.1   the transfer is necessary for the performance of a contract that we have with you;

19.1.2   the transfer is necessary for the conclusion or performance of a contract with a third party which is for your benefit or in your interests;

19.1.3   the transfer is otherwise for your benefit; or

19.1.4   you have consented to the transfer of your information.

19.2  If we are required to transfer personal information to a third party in a foreign country, we will ensure that the third party is subject to a law, binding code of conduct or contract which effectively upholds principles for the reasonable processing of personal information which are substantially similar to the data protection offered in terms of the GDPR.

20. Retention of information

20.1  We will keep a record of any personal information collected for no longer than is necessary to achieve the specific purpose for which it collected such information in the first place unless:

20.1.1   we are required by law to keep a record of such information for a longer period of time; or

20.1.2   we need to keep a record of such information for another lawful purpose; or

20.1.3   we have a contractual obligation to keep a record of such information; or

20.1.4   you have consented to your information being kept for a longer period.

20.2  We may, if we have de-identified personal information, keep such information for historical, statistical or research purposes. We will ensure that appropriate safeguards are in place to prevent those records from being used for any other purposes, or against the information being re-identified.

21. Returning, destroying or deleting personal information

Where we are no longer authorised to retain a record of any personal information, we will either:

21.1  ensure that the information is permanently destroyed or deleted as soon as reasonably practicable; or

21.2  return the information to you or transfer it to a third party, if requested by you in writing to do so.

22. Consent

22.1  You hereby consent to the processing of your personal information in terms of the provisions of this Privacy Policy.

22.2  You acknowledge and agree that such consent has been given voluntarily after you have read and understood the provisions of this Privacy Policy, in particular, regarding the following:

22.2.1   the types of personal information to be processed, including specifically special personal information;

22.2.2   the specific processing activities to be undertaken;

22.2.3   the specific purpose/s for such processing; and

22.2.4   the possible consequences that may arise from such processing.

22.3  Should you wish to withdraw any consent given, you must notify us in writing.

23. Lodging an objection

23.1  You may, on reasonable grounds, object to the processing of your personal information at any time after that processing has started.

23.12  If you wish to object to the processing of your personal information, you must send written notice of your objection to us, together with your reasons for doing so.

24. Amendment of this Privacy Policy

24.1  We reserve the right to change, update, add, remove and/or amend any of the provisions of this Privacy Policy from time to time. Such changes, updates, additions, removals or amendments will become effective from the date of their publication on our website.

24.2  It is our responsibility to periodically check the provisions of this Privacy Policy for any such changes, updates, additions, removals or amendments.

24.3  Your continued use of our website following any changes, updates, additions, removals or amendments to this Privacy Policy will be considered notice of your acceptance to abide by and be bound by this Privacy Policy, as amended.

25. Contact

For more information on your rights to privacy over your information, or our information processing activities, please do not hesitate to contact us directly on hello@outsourcery.uk

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). 

26. ICO Registration

Outsourcery is registered with ICO. Registration #ZB772541. ICO certificate can be viewed and downloaded here https://ico.org.uk/about-the-ico/what-we-do/register-of-fee-payers/

27. Data Protection Officer

• Name: Michael Crowster
• Title: Operations Director and Data Protection Officer
• Contact Information: michael.crowster@outsourcery.uk
• Date of Appointment: 1 Aug 2024

Date of last update: 01 September 2024