Technical Data Processing Policy – Version 1.1 17-05-18
This website is built and hosting on the Fledge Content Management
System stack (“Fledge”) and we describe here how this underlying technology works and the principles put
in place with our website technology provider to observe
personal data processing obligations.
- The Fledge team have fully assessed their own GDPR compliance both in terms of the services they offer to
us and in terms of their own internal policies and procedures.
- The Fledge team have appropriate technical and personnel protocols in place to ensure the security of your
- The Fledge team carry out due diligence against any sub-processors or other third party processors and
ensure their GDPR compliance (such as data centres)
- The Fledge team only allow specific members of staff access to servers and what access that is available,
is limited to specific circumstances
- The Fledge team do not transfer your data outside the EEA (all services are hosted in the UK)
- The Fledge staff are trained in GDPR compliance and understand their responsibilities for managing the
systems that process your personal data
You are the owner of the data you submit to our services. When your data is placed on a Fledge server, the
Fledge team do not access the data we store on their services, except where required to support technical
queries to us, and any processing (as a Data Processor) is only in terms of the hosting services they provide
to us. They do not use your data for any processing of their own. They do not share or provide access to any
of your data with third parties unless required to do so by law. Where authorised parties request access to
their servers, they follow strict internal policies for dealing with such requests in line with existing UK
law. Furthermore, the third parties are required to demonstrate they have a lawful reason to access the data
and under what authority.
On most web browsers, you will find a “help” or “settings” section on the toolbar. Please refer to this
section for information on how to receive a notification when you are receiving a new cookie and how to turn
unable to access certain parts of the site and you may not be able to benefit from the full functionality of
- Session – We use a cookie called allows us to identify when a user has visited the site. This
cookie is an essential part of serving site content to you. Without such a cookie, you would not be able to
properly view our site and basic functions of our site would not work. We also use a cookie that allows to
detect a user’s geographical location, mainly using the IP address of the connection point. In some cases,
this cookie can redirect malicious uses of our site away from our server.
- Source Data - Fledge records the source of how you got to our site, including for example from
another website or from a link to our website.
- Log Files - Fledge collects information about you when you visit our site including which pages you
visit, when you have visited them etc. The server may also keep log files which contain data about the
device you’re using, the IP address, internet service provider, operating system, timestamps and files you
view from our site.
- IP Addresses – By visiting our site, your IP address will be recorded by our servers and stored in
log files. These log files are used for record keeping, tracking referring websites, inferring your general
location, and for security purposes to avoid SPAM, abuse and DDOS attacks.
- Device Data – We collect data about the device and system you use to access our site. In
particular, we collection your IP address, operating system, device type, browser type and your general
location of accessing the site.
ensuring that the user stays on the same host server for the entire duration of the session. These include a
cookie that expires after 30 minutes, and a cookie called that expires after 3600 minutes.
requirements, for example to remember your site preferences, show you when you are logged into our system
and allow you to remain logged-in for a period of time, provide you with support services, remember your
login information, and prepopulate forms that you have already completed, maintain accurate records of your
interactions with us through our site. In particular, we use a cookie which expires after 365 days to keep
cookie banner displayed after you have agreed to such use.
- Analytics – We use analytical cookies that allow us to recognise and count the number of visitors
and to see how visitors move around the site when they are using it. This helps us to improve the way our
site works, for example by making sure users are finding what they need easily. The collected data provides
us only with anonymous traffic statistics (like number of page views, number of visitors, and time spent on
each page). By continuing to use our site, you accept the site’s use of audience measurement cookies.
- Usage – We use a cookie that allows us to measure activity on our site, so that we can better
evaluate which types of content and formats are interesting and valuable for our visitors.
- Pixel Tags – We periodically use pixel tags from the following third parties, to help us improve
use of the Site and our services, and know when content has been shown to you: Twitter. For information
https://support.twitter.com/articles/20170405#. Facebook. For information regarding Facebook’s data privacy
Facebook ad settings. LinkedIn. For additional information regarding LinkedIn’s data privacy and cookies,
https://www.linkedin.com/help/linkedin/answer/62931/manage-advertising-preferences?lang=en. Google. For
- AB Testing – We use A/B cookies and multivariate testing to identify a visitor's browser and to analyse
the use of this site.
Legal Basis for Processing
Fledge will collect your usage statistics and submitted details on our behalf. Fledge then stores and
processes those on our behalf. If you would like your data to be erased, rectified, accessed or for any other
queries about your responses, please contact us directly.
As the legal basis of processing data, it is necessary for the purposes of the legitimate interests pursued
by both us and our technology providers. Our legitimate interests are:
- Distinguish you from other users of our website and help to improve our website’s performance and your
experience of using our website
- Make it easier and more convenient for you to interact with us, including responding to enquiries and
provide customer support, and to improve or modify our services
- For regulatory purposes and compliance with industry standards and to ensuring secure usage of the site
and to conduct manual or systematic monitoring for fraud and other harmful activity
Fledge will retain data for the period necessary to fulfil the purposes outlined in this policy unless a
longer retention period is required or permitted by law. Please note that we have a variety of obligations to
retain data provided to us, including to help identify fraud and malicious computer usage such as hacking,
phishing, and ransomware attacks. Accordingly, even if you chose to submit a data amendment request, we may
retain certain data to meet our obligations under the law.
Contacting the Fledge Team
firstname.lastname@example.org or at:
Attention: Fledge Team, Pint Sized Giants Ltd, i-Lab,
Stannard Way, Bedford, MK44 3RZ, UK