Bott Limited respects your privacy and is committed to protecting your personal data. We understand that individuals value their privacy and data. This privacy policy will inform you as to how we manage and look after your personal data. This policy will inform you of your privacy rights and how the law protects you.
It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.
We keep our privacy policy under regular review.
This Policy was last updated on 14/01/22
This privacy policy will inform you as to how we look after your personal data when you visit our websites
Please note:
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
Bott Limited is the controller and responsible for your personal data (collectively referred to as "Bott", "we", "us" or "our" in this privacy policy). Bott is part of a corporate group of companies (our "Group") which includes Bott Internationale Holding Gmbh.
Our registered office is at
Bott Limited, Bude-Stratton Business Park, Bude, Cornwall, EX23 8LY.
If you have any questions or comments about our privacy policy or privacy practices, including any requests to exercise your legal rights detailed in Section 9 ‘Your Legal Rights’, these can be sent to us using any of the contact methods listed in Section 10 ‘Updates and Contact Information’ so our privacy team can deal with them.
We will only ever collect your data when we have a reason to do so and only where that reason is permitted under data protection law.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
Data we do not collect
Aggregated Data
We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods). In this case, we may have to cancel the contract you have with us but we will notify you if this is the case at the time.
We use different methods to collect data from and about you including through:
Direct interactions.
You may give us your Identity, Contact and Vehicle Data filling in forms or by corresponding with us by post, phone, email, social media or otherwise. This includes personal data you provide when you:
Automated technologies or interactions
As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy for further details.
Third parties or publicly available sources.
We will receive personal data about you from various third parties as set out below:
Contact and Transaction Data
We will only use your personal data when the law allows us to. The types of lawful basis for processing personal data that we rely on are:
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
The information set out in the table below also applies to how our Group may use your personal data.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground, we are relying on to process your personal data where more than one ground has been set out in the table below.
Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
---|---|---|
To register you as a new customer | (a) Identity (b) Contact (c) Vehicle | (a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us) |
To respond to and record enquires of prospective customers, including issuing quotations | (a) Identity (b) Contact (c) Transaction (d) Vehicle | (a) Necessary for our legitimate interests (b) Performance of a contract with you (processing is necessary in order to take steps at the request of the data subject prior to entering into a contract) |
To process and deliver your orders | (a) Identity (b) Contact (c) Transaction (d) Marketing and Communications (e) Vehicle | (a) Performance of a contract with you (b) Necessary for our legitimate interests |
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey (c) Making a record of our direct interactions with you | (a) Identity (b) Contact (c) Profile (d) Marketing and Communications (e) Transaction (f) Vehicle | (a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to effectively manage customer and prospective customer relationships, to improve our customer service and to study how customers use our products/services) |
To enable you to partake in a prize draw, competition or complete a survey. | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Vehicle | (a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) |
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | (a) Identity (b) Contact (c) Technical | (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or Group restructuring exercise) (b) Necessary to comply with a legal obligation |
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical | Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) |
To record protect and monitor the security of our sites by recording CCTV | (a) Identity (b) Vehicle | Necessary for our legitimate interests (to provide security on our sites) |
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences | (a) Technical (b) Usage | Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
To make suggestions and recommendations to you about goods or services that may be of interest to you | (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and communications (g) Vehicle | Necessary for our legitimate interests (to develop our products/services and grow our business) |
Marketing and Promotional offers from us
We may use your Identity, Contact, Vehicle, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We will process your personal data to provide you with marketing communications about our products and services if you have requested information from us or purchased products or services from us, and, in each case, you have not opted out of receiving that marketing. We may use external marketing agents to help us with such marketing communications. The legal basis on which we process personal data for marketing purposes is our legitimate interest to develop and market our products and services and to grow our business, or, because you have provided your consent for us to contact you.
We will always get your express opt-in consent before we share your personal data with any third party for marketing purposes.
We use Mailchimp, a marketing automation platform and email marketing service. Mailchimp allows us to track email open rates and clicks, providing us with analytics to improve our marketing. Mailchimp’s Privacy Policy and Standard Terms of Use can be found on their Legal page.
You can ask us or third parties to stop sending you marketing communications at any time by contacting us (Please see Section 10, ‘Updates and Contact Information’) or, where relevant, by following the unsubscribe link in any marketing communication sent to you. Where you opt out of receiving these marketing communications, this will not apply to personal data provided to us as a result of a product or service purchase or other transaction.
We may share your personal data with the parties set out below for the purposes set out in the table 'Purposes for which we will use your personal data' above.
Internal Third Parties
External Third Parties such as:
Third parties
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
We will generally retain our customers' data for a period of 7 (seven) years after a contract has ended, to ensure that we are able to assist you should you have any questions or feedback in relation to our products or services or to protect, or to defend our legal rights, or for tax purposes. If the warranty of your product is longer than the 7 (seven) year period then we will retain your data accordingly.
Where we hold your personal data solely for marketing and communications purposes and you unsubscribe or withdraw your consent for us to process your personal data for such purposes, we will delete your personal data. However, please be aware if we are storing your personal data under another lawful basis, for example personal data provided to us as a result of a product or service purchase or other transaction, then we will not delete the personal data but simply remove the marketing and communications consent.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
There are circumstances where you can ask us to delete your data see Section 9 ‘Your Legal Rights’ below for further information.
We may share your personal data within our Group. This will involve transferring your data outside of the UK.
Some of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.
Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
If you wish to exercise any of the rights set out above, please contact us directly using the details in Section 10, ‘Updates and Contact Information’.
Exercising your rights
If you wish to exercise any of the rights set out above, please contact us directly using the details below in Section 10 ‘Updates and Contact Information’.
Changes to our privacy policy
We keep our privacy policy under regular review. Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by email.
Contact us
Any questions or comments about our privacy policy or privacy practices, including any requests to exercise your legal rights, can be sent to us using any of the below contact methods so our privacy team can deal with them.
Full name of legal entity: Bott Limited
Email:privacy@bottltd.co.uk
Telephone number:01288 355666
Postal address: Bott Limited, Bude-Stratton Business Park, Bude, Cornwall, EX23 8LY
Information Commissioner
If you have any questions about our handling of your personal data, we would prefer it if you contact us first, so we can resolve any problems as quickly as possible and have opportunity to deal with your concerns. However, if you are not happy with the way we have handled your data, or would like more information about your rights, you can contact the Information Commissioner’s Office, the UK’s independent authority on data privacy at www.ico.org.uk.
Bott Limited respects your privacy and is committed to protecting your personal data. We understand that individuals value their privacy and data. This privacy policy will inform you as to how we manage and look after your personal data. This policy will inform you of your privacy rights and how the law protects you.
It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.
We keep our privacy policy under regular review.
This Policy was last updated on 14/01/22
This privacy policy will inform you as to how we look after your personal data when you visit our websites
Please note:
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
Bott Limited is the controller and responsible for your personal data (collectively referred to as "Bott", "we", "us" or "our" in this privacy policy). Bott is part of a corporate group of companies (our "Group") which includes Bott Internationale Holding Gmbh.
Our registered office is at
Bott Limited, Bude-Stratton Business Park, Bude, Cornwall, EX23 8LY.
If you have any questions or comments about our privacy policy or privacy practices, including any requests to exercise your legal rights detailed in Section 9 ‘Your Legal Rights’, these can be sent to us using any of the contact methods listed in Section 10 ‘Updates and Contact Information’ so our privacy team can deal with them.
We will only ever collect your data when we have a reason to do so and only where that reason is permitted under data protection law.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
Data we do not collect
Aggregated Data
We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods). In this case, we may have to cancel the contract you have with us but we will notify you if this is the case at the time.
We use different methods to collect data from and about you including through:
Direct interactions.
You may give us your Identity, Contact and Vehicle Data filling in forms or by corresponding with us by post, phone, email, social media or otherwise. This includes personal data you provide when you:
Automated technologies or interactions
As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy for further details.
Third parties or publicly available sources.
We will receive personal data about you from various third parties as set out below:
Contact and Transaction Data
We will only use your personal data when the law allows us to. The types of lawful basis for processing personal data that we rely on are:
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
The information set out in the table below also applies to how our Group may use your personal data.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground, we are relying on to process your personal data where more than one ground has been set out in the table below.
Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
---|---|---|
To register you as a new customer | (a) Identity (b) Contact (c) Vehicle | (a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us) |
To respond to and record enquires of prospective customers, including issuing quotations | (a) Identity (b) Contact (c) Transaction (d) Vehicle | (a) Necessary for our legitimate interests (b) Performance of a contract with you (processing is necessary in order to take steps at the request of the data subject prior to entering into a contract) |
To process and deliver your orders | (a) Identity (b) Contact (c) Transaction (d) Marketing and Communications (e) Vehicle | (a) Performance of a contract with you (b) Necessary for our legitimate interests |
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey (c) Making a record of our direct interactions with you | (a) Identity (b) Contact (c) Profile (d) Marketing and Communications (e) Transaction (f) Vehicle | (a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to effectively manage customer and prospective customer relationships, to improve our customer service and to study how customers use our products/services) |
To enable you to partake in a prize draw, competition or complete a survey. | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Vehicle | (a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) |
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | (a) Identity (b) Contact (c) Technical | (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or Group restructuring exercise) (b) Necessary to comply with a legal obligation |
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical | Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) |
To record protect and monitor the security of our sites by recording CCTV | (a) Identity (b) Vehicle | Necessary for our legitimate interests (to provide security on our sites) |
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences | (a) Technical (b) Usage | Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
To make suggestions and recommendations to you about goods or services that may be of interest to you | (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and communications (g) Vehicle | Necessary for our legitimate interests (to develop our products/services and grow our business) |
Marketing and Promotional offers from us
We may use your Identity, Contact, Vehicle, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We will process your personal data to provide you with marketing communications about our products and services if you have requested information from us or purchased products or services from us, and, in each case, you have not opted out of receiving that marketing. We may use external marketing agents to help us with such marketing communications. The legal basis on which we process personal data for marketing purposes is our legitimate interest to develop and market our products and services and to grow our business, or, because you have provided your consent for us to contact you.
We will always get your express opt-in consent before we share your personal data with any third party for marketing purposes.
We use Mailchimp, a marketing automation platform and email marketing service. Mailchimp allows us to track email open rates and clicks, providing us with analytics to improve our marketing. Mailchimp’s Privacy Policy and Standard Terms of Use can be found on their Legal page.
You can ask us or third parties to stop sending you marketing communications at any time by contacting us (Please see Section 10, ‘Updates and Contact Information’) or, where relevant, by following the unsubscribe link in any marketing communication sent to you. Where you opt out of receiving these marketing communications, this will not apply to personal data provided to us as a result of a product or service purchase or other transaction.
We may share your personal data with the parties set out below for the purposes set out in the table 'Purposes for which we will use your personal data' above.
Internal Third Parties
External Third Parties such as:
Third parties
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
We will generally retain our customers' data for a period of 7 (seven) years after a contract has ended, to ensure that we are able to assist you should you have any questions or feedback in relation to our products or services or to protect, or to defend our legal rights, or for tax purposes. If the warranty of your product is longer than the 7 (seven) year period then we will retain your data accordingly.
Where we hold your personal data solely for marketing and communications purposes and you unsubscribe or withdraw your consent for us to process your personal data for such purposes, we will delete your personal data. However, please be aware if we are storing your personal data under another lawful basis, for example personal data provided to us as a result of a product or service purchase or other transaction, then we will not delete the personal data but simply remove the marketing and communications consent.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
There are circumstances where you can ask us to delete your data see Section 9 ‘Your Legal Rights’ below for further information.
We may share your personal data within our Group. This will involve transferring your data outside of the UK.
Some of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.
Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
If you wish to exercise any of the rights set out above, please contact us directly using the details in Section 10, ‘Updates and Contact Information’.
Exercising your rights
If you wish to exercise any of the rights set out above, please contact us directly using the details below in Section 10 ‘Updates and Contact Information’.
Changes to our privacy policy
We keep our privacy policy under regular review. Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by email.
Contact us
Any questions or comments about our privacy policy or privacy practices, including any requests to exercise your legal rights, can be sent to us using any of the below contact methods so our privacy team can deal with them.
Full name of legal entity: Bott Limited
Email:privacy@bottltd.co.uk
Telephone number:01288 355666
Postal address: Bott Limited, Bude-Stratton Business Park, Bude, Cornwall, EX23 8LY
Information Commissioner
If you have any questions about our handling of your personal data, we would prefer it if you contact us first, so we can resolve any problems as quickly as possible and have opportunity to deal with your concerns. However, if you are not happy with the way we have handled your data, or would like more information about your rights, you can contact the Information Commissioner’s Office, the UK’s independent authority on data privacy at www.ico.org.uk.