1. Introduction

This Policy sets out the obligations of MyUnit Limited, a company registered in England under number 14720878, whose registered office is at Suite 2, Victoria House, South Street, Farnham, Surrey, GU9 7QU ("the Company") regarding data protection and the rights of Data Subjects in respect of their Personal Data under Data Protection Law.

This Policy sets out the Company's obligations regarding the Processing of Personal Data. The procedures and principles set out herein must be followed at all times by the Company, its employees, agents, Contractors, or other parties working on behalf of the Company.

2. Definitions

Consent - means the Consent of the Data Subject which must be a freely given, specific, informed, and unambiguous indication of the Data Subject's wishes by which they, by a statement or by a clear affirmative action, signify their agreement to the processing of Personal Data relating to them;

Contractor - any individual or third-party entity that provides services to the company under a contract or agreement but is not an employee of the company.

Data Controller - means the natural or legal person or organisation which, alone or jointly with others, determines the purposes and means of the processing of Personal Data.

For the purposes of this Policy, the Company and its Contractors are the Data Controller of all Personal Data relating to customers and business contacts used in our business for our commercial purposes;

Data Processor - any individual, entity, or organization that processes Personal Data on behalf of the Data Controller, as defined under applicable data protection laws. The Data Processor acts only under the instructions provided by the Data Controller and does not determine the purposes or means of processing the Personal Data. The Data Processor is responsible for ensuring the security, confidentiality, and integrity of Personal Data while processing it according to the agreed terms and relevant legal requirements.

For the purposes of this Policy, the Company and its service providers are the Data Processor of all Personal Data relating to customers and business contacts used in our business for our commercial purposes;

Data Protection Law - all applicable legislation in force from time to time in the United Kingdom applicable to data protection and privacy including, but not limited to, the UK GDPR, the Data Protection Act 2018 (and regulations made thereunder), and the Privacy and Electronic Communications Regulations 2003 as amended, and any successor legislation.

Data Protection Officer - The Data Protection Officer is responsible for administering this Policy, for developing and implementing any applicable related policies, procedures, and/or guidelines, and company's data protection strategy and compliance with Data Protection Laws.

The Company's Data Protection Officer is Christopher Scorer, chris@myunit.tech

Data Subject - any identified or identifiable natural person whose Personal Data is processed by the Data Controller or Data Processor. An identifiable person is one who can be identified, directly or indirectly, by reference to an identifier such as a name, an identification number, location data, an online identifier, or other specific factors that are unique to the individual's physical, physiological, genetic, mental, economic, cultural, or social identity.

Directors - includes all Directors and persons of significant control of the Company as listed on Companies House

EEA - means the European Economic Area, consisting of all EU Member States, Iceland, Liechtenstein, and Norway;

Personal Data - means any information relating to a Data Subject who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that Data Subject;

Personal Data Breach - means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, Personal Data transmitted, stored, or otherwise processed;

Processing - means any operation or set of operations performed on Personal Data or sets of Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, transferring, constraining, alignment or combination, restriction, erasure, disposal or destruction;

Special Category Personal Data - means Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, sexual life, sexual orientation, biometric, or genetic data.

Also known as Sensitive Personal Data.

3. Scope

1. The Company is committed not only to the letter of the law, but also to the spirit of the law and places high importance on the correct, lawful, and fair handling of all Personal Data, respecting the legal rights, privacy, and trust of all individuals with whom it deals.

2. All Directors are responsible for ensuring that all employees, agents, Contractors, or other parties working on behalf of the Company comply with this Policy and, where applicable, must implement such practices, processes, controls, and training as are reasonably necessary to ensure such compliance.

3. Any questions relating to this Policy or to Data Protection Law should be referred to the Data Protection Officer.

4. The Data Protection Principles

In line with the Data Protection Laws, the Company's Data Controllers must be able to demonstrate that all Personal Data is:

1. processed lawfully, fairly, and in a transparent manner in relation to the Data Subject;

2. collected for specified, explicit, and legitimate purposes and not further processed in a manner that is incompatible with those purposes. Further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;

3. adequate, relevant, and limited to what is necessary in relation to the purposes for which it is processed;

4. accurate and, where necessary, kept up to date. Every reasonable step must be taken to ensure that Personal Data that is inaccurate, having regard to the purposes for which it is processed, is erased, or rectified without delay;

5. kept in a form which permits identification of Data Subjects for no longer than is necessary for the purposes for which the Personal Data is processed. Personal Data may be stored for longer periods insofar as the Personal Data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes, subject to implementation of the appropriate technical and organisational measures required by the UK GDPR in order to safeguard the rights and freedoms of the Data Subject;

6. processed in a manner that ensures appropriate security of the Personal Data, including protection against unauthorised or unlawful Processing and against accidental loss, destruction, or damage, using appropriate technical or organisational measures.

5. The Rights of Data Subjects

In line with the Data Protection Laws, the Company's Data Subjects have the following key rights:

1. The right to be informed;

2. the right of access;

3. the right to rectification;

4. the right to erasure (also known as the 'right to be forgotten');

5. the right to restrict Processing;

6. the right to data portability;

7. the right to object; and

8. rights with respect to automated decision-making and profiling.

21. Personal Data Collected, Held, and Processed

The following Personal Data is collected, held, and processed by the Company (for details of data retention, please refer to the Company's Data Retention Policy):