Privacy 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 In this policy, "we", "us" and "our" refer to Celtest Company Limited. For more information about us,
see Section 13.


2. Credit
2.1 This document was created using a template from SEQ Legal (https://seqlegal.com).


3. How we use your personal data
3.1 In this Section 3 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.


3.2 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.


3.3 We may process ("account data"). The account data may include your name and email address The
account 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 our legitimate interests, namely the
proper administration of our website and business.


3.4 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 email addresses. The source of the service data is you
or your employer. 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 our legitimate interests,
namely the proper administration of our website and business.


3.5 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 our
legitimate interests, namely the proper administration of our website and business.


3.6 We may process information contained in any enquiry you submit to us regarding goods and/or
services ("enquiry data"). The enquiry data may be processed for the purposes of offering, marketing
and selling relevant goods and/or services to you. The legal basis for this processing is consent.

3.7 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 consent.


3.8 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.


3.9 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.


3.10 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.


3.11 In addition to the specific purposes for which we may process your personal data set out in this
Section 3, 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.


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


4. Providing your personal data to others
4.1 We may disclose your personal data to our insurers and/or professional advisers insofar as
reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing
risks, obtaining professional advice, or the establishment, exercise or defence of legal claims,
whether in court proceedings or in an administrative or out-of-court procedure.


4.2 In addition to the specific disclosures of personal data set out in this section, 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-ofcourt procedure.


5. International transfers of your personal data
5.1 In this section, we provide information about the circumstances in which your personal data may be
transferred to countries outside the European Economic Area (EEA).
5.2 You acknowledge that personal data that you submit for publication through our website or services
may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such
personal data by others.

6. Retaining and deleting personal data
6.1 This section 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.


6.2 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.


6.3 Notwithstanding the other provisions of this section, 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.


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


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


8. Your rights
8.1 In this section 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.


8.2 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.


8.3 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.


8.4 You have the right to have any inaccurate personal data about you rectified and, taking into account
the purposes of the processing, to have any incomplete personal data about you completed.


8.5 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.

8.6 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.


8.7 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.


8.8 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.


8.9 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.


8.10 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.


8.11 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.


9. About cookies
9.1 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.


9.2 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.


9.3 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.

10. Cookies that we use
10.1 We use cookies for the following purposes:
 See separate cookie policy, OHSP 4.2.19.


11. Cookies used by our service providers
11.1 Our service providers use cookies and those cookies may be stored on your computer when you visit
our website.


11.2 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/. Refer to OHSP 4.2.19, Cookies Policy.


12. Managing cookies – see separate cookie policy, OHSP 4.2.19


13. Our details
13.1 This website is owned and operated by Celtest Company Limited.


13.2 We are registered in Wales under registration number 01533370, and our registered office is at
Trefelin, Llandegai, Bangor, Gwynedd. LL57 4LH


13.3 Our principal place of business is as above.


14 Documentation
The documentation associated with this procedure includes:
Doc. Ref
Cookies Policy OHSP 4.2.19


Policy Review
This policy will be reviewed at the annual Management Review Meeting to ensure its continued effectiveness.