Data Collection

The data controller collecting the data described herein is Spadel Group. Personal data collected by Spadel Group may be transferred to other Spadel Group firms, which are member firms of the Spadel Group organisation, where it is necessary to meet the purpose for which the visitor has submitted the information. By submitting data on the Spadel Group site, the visitor is providing explicit consent to transmission of data collected on the web site for the fulfilment of their voluntary requests.

We collect only personally identifiable information that is specifically and voluntarily provided by visitors to the Spadel Group site. Spadel Group receives limited identifiable information, such as name, title, company address, email address, and telephone and fax numbers, from web site visitors. Typically, identifying information is collected to:

• Register for certain areas of the site
• Inquire for further information
• Distribute requested reference materials, or Submit information for publication to Spadel Group with reference to a particular business, society, club or other organisations that wish to be publicised by Spadel Group.

It is Spadel Group' policy to limit the information collected to only the minimum information required to complete a visitor's request. In any instance where non-mandatory information is sought, the web site visitor will be notified of this point of collection.

Spadel Group' intention is not to seek any sensitive information through our web site unless legally required. Sensitive information includes a number of types of data relating to: race or ethnic origin; political opinions; religious or other similar beliefs; trade union membership; physical or mental health: sexual life or criminal record. We suggest that you do not provide sensitive information of this nature. If you do wish to provide sensitive information for any reason, Spadel Group accepts your explicit consent to use that information in the ways described in this privacy statement or as described at the point where you choose to disclose this information.

Spadel Group collects personal information from you in order to fulfil requests for print and electronic products and services. We only require information that is necessary to fulfil such requests. Spadel Group links to hundreds of other web sites; we are not responsible for the privacy practices or the content of those web sites.

Non-personal information collected by web system
Our web servers automatically record general information on all users who browse the content of our site. These data collection systems gather:

Your IP address

• The internet domain for your Internet service, such as company.com or school.edu
• The type and version of the browser you are using to access a Spadel Group associated website (such as Netscape 4.0 or Internet Explorer 3.5)
• The type and version of the operating system you use (such as Macintosh or Windows)
• The address of the previous site you were visiting, if you linked to Spadel Group from another site
• The pages you visit on a Spadel Group associated website and the files you download
• The date, time and length of time of your visit

The logs are periodically summarised and analysed to study site usage over time to help us improve the site's organisation, performance and usefulness. This information is only examined in the aggregate, not at the individual level.

Opt-out Consent
In accordance with the requirements of the Data Protection Act 1998, we provide the opportunity for you to opt out of certain types of usage of your personal data when supplied to us via registration and order forms. Should you wish your personal data to be removed from our records or updated at a later date, you can request this by emailing uk.customerservices@spa.co.uk We would require verification of identification from the data subject before data is removed or ammended.

Use of data
Any data gathered through the a Spadel Group associated website is usually used for internal purposes only. This data is not usually shared with other organisations, unless this is necessary for the formation and/or completion of a contract. In the unlikely event that Spadel Group or substantially all of its assets are acquired by a third party, customer data will of course be one of the transferred assets.

A user may choose to provide personal information in the following examples:

Order services

• Submit CVs or work history information
• Participate in ‘joining our mailing list' initiatives
• Contact us for further information
• Enter Quick Surveys, Quiz's or Benchmarking Surveys
• Register for events and conferences
• Register for premium online services

If you would like to find out more about the different categories of information collected, please review the data collection section.

Information attained by the site is used only for the intended purpose stated at the time that the information is collected. This data is not shared with other entities in the firm for secondary or unrelated purposes, or shared with a third party, unless otherwise disclosed at the point of collection. If there is an instance where such information may be shared, the visitor will be asked for permission beforehand.

Spadel Group makes every practical effort to avoid excessive or irrelevant collection of data. If a visitor believes the site has collected excessive information, we encourage the visitor to contact us at uk.customerservices@spa.co.uk to raise any concerns.

Except for the mailing list initiative described above, where visitors explicitly choose to receive specific Spadel Group' marketing or other materials, Spadel Group will not use personal data collected from out web sites to facilitate unsolicited marketing activities.

E-mail newsletters
On each occasion that you receive an e-mail you will be given the opportunity to opt out of receiving future e-mail communications. We maintain a strict “No-Spam” policy that means that we do not intend to sell, rent, or otherwise give your e-mail address to a third party, without your consent.

Your consent to this policy
By using our web sites, you consent to the collection and use of your data by Spadel Group. Your visit and any dispute over privacy is subject to this policy and our disclaimer. Should we decide to change our privacy policy we will post all changes on this page so that you are always kept aware of how we use any data you provide to us.

Recording of IP addresses and statistical monitoring
Internet protocol (IP) addresses are used to connect your computer to the internet and are recorded by every site on the internet. Spadel Group use various data analysis software packages to gather and analyse anonymous activity information for statistical purposes and for administration of our web site and servers. The general information we collect is used to improve the content of our web pages and your navigation through our site. This software does not collect any personal information and we do not record or store individual visitor profiles.

Cookies and Log Files
Cookies may be used on some pages of our site. “Cookies” are small text files placed on your hard drive that assist us in providing a more customised Web site experience. For example, a cookie can be used to store registration information in an area of the site so that a user does not need to re-enter it on subsequent visits to that area. It is Spadel Group' policy to use cookies to navigate of our web sites for visitors and to facilitate efficient registration procedures.

If you are concerned about cookies, most browsers permit individuals to decline cookies. In most cases, a visitor may refuse a cookie and fully navigate our Web sites.

In order to properly manage our web site we may anonymously log information on our operational systems and identify categories of visitors by items such as domains and browser types. These statistics are reported in the aggregate for our webmasters. This is to ensure that our Web site presents the best web experience for visitors and is an effective information resource.

Third parties
It is Spadel Group' policy to only disclose information to third parties under the following circumstances:

• As required by law through subpoena, search warrant or other legal process
• When requested by the individual who is the data subject in question.

Spadel Group web sites do not collect or compile personally identifying information for dissemination or sale to outside parties for consumer marketing purposes, or host mailings on behalf of third parties.

Third Party Links There are several places throughout a Spadel Group associated website that may link to other web sites that do not operate under Spadel Group privacy practices. When you link to other web sites, Spadel Group' privacy practices no longer apply. We encourage visitors to review each site's privacy policy before disclosing any personally identifiable information.

Third party disclosures
Aside from the data collected as a result of the general day to day running of a Spadel Group associated website described within the data collection section of this policy, personal data may also be disclosed publicly by a user of a Spadel Group associated website via one of our communication services.

If a disclosure of such data occurs Spadel Group will remove the data posted as soon as possible unless instructions are given by the person(s) whom the personal data concerns state otherwise.

Data Retention
Some of the information we receive is not retained. Contact information about visitors (such as information generated through registration for access to areas on the site) will be kept as long as the information is required to completely service the contact request or until a user requests that we delete that information. Mailing list information, discussion points and email are kept for only the period time considered reasonable to facilitate the visitor's requests.

Choices
As a policy, visitors are not required to register to gain access to areas of the Spadel Group web sites. In certain cases in the future, as the Spadel Group web site expands, we may require visitors to register in order to obtain a user-id and password for authentication and secure access to a transaction or certain business confidential or proprietary information services on premium web sites. Personally identifiable information provided to Spadel Group through its web site is provided voluntarily by visitors. Should visitors subsequently choose to unsubscribe from mailing lists or any registrations, we will provide instructions, on the appropriate site.

Access
Each visitor has the right of access to personal data they have submitted through the web sites to Spadel Group.

User updates of information should be handled by going back through the registration process. Enquiries about the accuracy of identifying information previously submitted to Spadel Group through its web site, or requests to have outdated information removed, should be directed to uk.customerservices@spa.co.uk. Spadel Group is committed to providing reasonable and practical access to visitors to allow them the opportunity to identify and correct any inaccuracies. When requested and practical, Spadel Group will delete identifying information from current operational systems.

When personally identifiable information is retained, Spadel Group assumes responsibility for keeping an accurate record of the information once a visitor has submitted and verified the data. Spadel Group does not assume responsibility for verifying the ongoing accuracy of the content of personal information. When practically possible, if Spadel Group is informed that any personal data collected through a web site is no longer accurate, Spadel Group will make appropriate corrections based on the updated information provided by the authenticated visitor.

Security
Spadel Group has implemented generally accepted standards of technology and operational security in order to protect personally identifiable information from loss, misuse, alteration or destruction. All Spadel Group employees follow a firm security policy. Only authorised Spadel Group personnel are provided access to personally identifiable information and these employees have agreed to ensure confidentiality of this information. Spadel Group policy is to use secure socket layer technology for the protection of credit card information submitted through web forms. This policy is also required for any fulfillment agents of our firm.

Copyright and usage information
Spadel Group holds copyright on all original materials we publish. However, the right to use materials for reproduction by others may on occasion be granted.

Requests for permission to reprint must be submitted by letter, fax or email.

Anyone is welcome to link to all Spadel Group associated website's public web pages (pages not protected by the requirement to register and login). There is no need to request permission.

Children
Spadel Group understands the importance of protecting children's privacy especially in an online environment. The Spadel Group site that's covered by this privacy statement are not intentionally designed for or directed at children 13 years of age or younger. It is Spadel Group' policy never to knowingly collect or maintain information about anyone under the age of 13.

Modifications
Spadel Group reserves the right to modify or amend this statement at any time. The effective date will be displayed at the beginning of this statement. To keep visitors informed, Spadel Group will notify users of changes to our privacy statement by prominently identifying the alteration for a period of not less than two weeks on our home page at http://www.breconwater.co.uk