GLOBAL STUDY TECHNOLOGY LIMITED
When we refer to “Global Study”, we mean Global Study Technology Limited, as explained in more detail in the “Identifying the Data Controller and Processor” section below.
California Notice of Collection of Personal Information: We collect the information described below under “Information We Collect and Receive” for the business and commercial purposes described below under “Information Use.” To learn more about exercising your California Privacy Rights please review the “California Privacy Rights” section below.
2. Information We Collect And Receive
Global Study will collect and receive information through operating the Services and Websites, and through other interactions with Global Study. Such information will include Customer Data and other information and data (“Other Information”) in a variety of ways:
- Customer Data. Customers or individuals granted access to our Software by a Customer (“Authorized Users”) routinely submit Customer Data (such as messages, files or other content submitted through Services accounts) to Global Study when using the Services.
- Other Information. Global Study also collects, generates and/or receives the following categories of other information.
- 1. Account information: To create or update an account using our Software, you or our Customer (e.g. your employer) supply Global Study with an email address, phone number, and/or other account set up. In addition, Customers that purchase a paid version of the Services provide Global Study (or its payment processors) with billing details such as credit card information, banking information, and/or a billing address.
- 2. Usage information:
- Services metadata. When an Authorized User interacts with the Services, metadata is generated that provides additional context about the way that an Authorized User uses the Services. For example, Global Study logs the sessions, people, features, content, and links you view or interact with, the types of files shared and what Third-Party Services are used (if any).
- Log data. As with most websites and technology services delivered over the Internet, our servers automatically collect information when you access or use our Websites or Services and record it in log files. This log data may include your Internet Protocol (IP) address, the address of the web page you visited before using the Website or Services, browser type and settings, the date and time the Services were used, information about browser configuration and plugins, and your language preferences.
- Device information. Global Study may collect information about devices accessing the Services, including type of device, what operating system is used, device settings, application IDs, unique device identifiers and crash data. Whether we collect some or all of this Other Information often depends on the type of device used and its settings.
- Location information. We may receive information from you, our Customers and other third-parties that helps us approximate your location. We may, for example, use a business address submitted by your employer (who is our Customer) or an IP address received from your browser or device to determine approximate location to assist with localization or for security purposes.
- 3. Cookie information: Global Study uses a variety of cookies and similar technologies in our Websites and Services to help us collect Other Information.
- 4. Third-Party Services information: A Customer can choose to permit or restrict Third-Party Services for its accounts and Global Study can receive personal data from such Third-Party Services. Typically, Third-Party Services are software that integrate with our Services, and a Customer can permit its Authorized Users to enable and disable these integrations for its accounts. Global Study may also develop and offer Global Study applications that connect the Services with a Third-Party Service. Once enabled, the provider of a Third-Party Service may share certain information with Global Study. For example, if a cloud storage application you are using is enabled to permit files to be imported to a Student Advisor student journey tracker, we may receive the user name and email address of Authorized Users, along with additional information that the application makes available to Global Study to facilitate the integration. Authorized Users should check the privacy settings and notices in these Third-Party Services to understand what data may be disclosed to Global Study. When a Third-Party Service is enabled, Global Study is authorized to connect and access Other Information made available to Global Study in accordance with our agreement with the provider of the Third-Party Service and any permission(s) granted by our Customer (including, by its Authorized User(s)). Examples of information which Global Study may receive in this manner include whether you successfully created a new account or interacted with a third-party application in a way that is attributable to Global Study usage activity. We do not, however, receive or store passwords for any of these Third-Party Services when connecting them to the Services.
- 5. Contact information: In accordance with the consent process provided by your device or other third-party API, any contact information that an Authorized User chooses to import (such as importing student information from a device or API), forward or upload to the Services (for example, when sending emails to the Services) is collected when using the Services.
- 6. Third-Party data: Global Study may receive data about organizations, industries, lists of companies that are customers, Website visitors, marketing campaigns and other matters related to our business from parent corporation(s), affiliates and subsidiaries, our partners, or others that we use to make our own information better or more useful. This data may be combined with Other Information we collect and might include aggregate-level data, such as which IP addresses correspond to zip codes or countries. Or it might be more specific: for example, how well an online marketing or email campaign performed.
- 7. Audio and video metadata: Global Study may receive, capture, and store metadata derived from your use of features such as video room conversations, and additional related data such as data regarding the date and time of your video room conversations and the Authorized User that you connected with.
- 8. Additional information provided to Global Study: We also receive Other Information when submitted to our Websites or in other ways, such as responses or opinions you provide if you participate in a focus group, contest, activity or event, feedback you provide about our products or services, information you provide if you apply for a job with Global Study, enroll in a certification program or other educational program hosted by Global Study or a vendor, request support, interact with our social media accounts or otherwise communicate with Global Study.
Generally, no one is under a statutory or contractual obligation to provide any Customer Data or Other Information (collectively, “Information”). However, certain Information is collected automatically and, if some Information, such as account setup details, is not provided, we may be unable to provide the Services.
3. How We Process Your Information and our Legal Bases for Doing So
Customer Data will be used by Global Study in accordance with a Customer’s instructions, including to provide the Services, any applicable terms in the Customer Agreement, a Customer’s use of Services functionality, and as required by applicable law. Global Study is a processor of Customer Data and the Customer is the controller. Customer may, for example, use the Services to grant and remove access to a Student Advisor account, assign roles and configure settings, access, modify, export, share, and remove Customer Data, and otherwise apply its policies to the Services.
Global Study uses Other Information to operate our Services, Websites, and business. More specifically, Global Study uses Other Information for the following purposes:
Compliance With A Legal Obligation:
Global Study processes Other Information when we comply with a legal obligation including, for example, to access, preserve or disclose certain information if there is a valid legal request from a regulator, law enforcement or others. For example, a search warrant or production order from law enforcement to provide information in relation to an investigation, such as your profile picture or IP address.
We use account information, Usage information, Cookie information, Third-Party Services Information, Contact information, Third-Party data, Audio and video metadata, and Additional information provided to Global Study for compliance with a legal obligation.
We rely on our legitimate interests or the legitimate interests of a third-party where they are not outweighed by your interests or fundamental rights and freedoms ("legitimate interests").
We use account information, Usage information, Cookie information, Third-Party Services Information, Contact information, Third-Party data, Audio and video metadata, and Additional information provided to Global Study for the following legitimate interests:
- To provide, update, maintain and protect our Services, Websites, and business: This includes the use of Other Information to support delivery of the Services under a Customer Agreement, prevent or address service errors, security or technical issues, analyze and monitor usage, trends and other activities, or at an Authorized User’s request.
- It is in our and your interests to provide, update, maintain and protect our Services, Websites, and business.
- To develop and provide search, learning and productivity tools and additional features: Global Study tries to make the Services as useful as possible for specific accounts and Authorized Users. For example, we may:
- Improve the Astro AI Memory Bank by using Other Information to help determine and rank the relevance of content, channels or expertise to an Authorized User.
- Make Services or Third-Party Service suggestions based on historical use and predictive models.
- Identify organizational trends and insights.
- Customize a Services experience.
- Create new productivity features and products.
- It is in our interest and in the interest of Customers and Authorized Users to continuously improve and develop the customer support we provide.
- To investigate and help prevent security issues and abuse: We may use a variety of tools such as device fingerprinting to prevent issues and abuse. We may process, including in an automated fashion, Other Information to better understand how Global Study is used or to prevent spam or abuse.
- It is in our interest to keep the Service secure and to detect, prevent, and address abuse (such as spam) and to investigate and take action in respect of suspicious activity on the Services.
- To aggregate or de-identify information: In some cases, we aggregate or de-identify information we have associated with you and use the resulting information, for example, to improve the Services.
- It is in our interest to research and improve the Services.
- It is in the interests of Customers and Authorized Users to practice data minimization and privacy by design in respect of their information.
- Share information with others, including law enforcement and to respond to legal requests:
- It is in our interest and the interest of the general public to prevent and address fraud, unauthorized use of Global Study, violations of our terms or other harmful or illegal activity; to protect ourselves, our users or others, including as part of investigations or regulatory enquiries; or to prevent death or imminent bodily harm.
- Transfer, store or process your information outside the European Economic Area: As the Websites and Services operate globally, with Customers around the world, we need to share information we collect globally. We carry out necessary transfers outside the European Economic Area, including to Australia, Canada, Japan, India, South Korea, and the United States, to provide, update, maintain and protect our Services, Websites and business. For more information, review the “International Data Transfers” section below.
- In our and your interests to provide, update, maintain and protect our Services, Websites and business.
We use account information, Third-Party Services Information, Third-Party data, and Additional information provided to Global Study for the following legitimate interests:
- To communicate with you by responding to your requests, comments, and questions. If you contact us, we may use your Other Information to respond.
- It is in our, our Customers’ and Authorized Users’ interests to facilitate communication (for example to answer questions from Customers).
- To send service emails and other communications: For example, we may:
- Send you service, technical, and other administrative emails, messages, and other types of communications; or
- Contact you to inform you about changes in our Services, our Service offerings, and important Service-related notices, such as security and fraud notices. These communications are considered part of the Services, and you may not opt out of them. It is in our Customers and Authorized Users’ interests to address service-related issues.
We use account information and Usage information for the following legitimate interests:
- For billing, account management, and other administrative matters: Global Study may need to contact you for invoicing, account management, and similar reasons, and we use account data to administer accounts and keep track of billing and payments.
- It is in our interest to facilitate the effective provision and administration of the Websites and Services.
We use Workspace and account information, Usage Information, Cookie information, Third-Party Services Information, Third-Party data, and Additional information provided to Global Study for the following legitimate interests:
- To send marketing emails and other communications: We sometimes send emails about new product features, promotional communications, or other news about Global Study. These are marketing messages, so you can control whether you receive them. If you have additional questions about a message you have received from Global Study, please get in touch through the contact mechanisms described below.
- It is in our interest to promote the Websites and Services and send our direct marketing.
4. How we Access, Use, Share and Store Your Information.
This section describes how Global Study may share and disclose Information, as described in the section entitled 'Information We Collect and Receive' above. Customers determine their own policies and practices for the sharing and disclosure of Information to third parties. Global Study does not control how a Customer or any third party chooses to share or disclose Information.
Student Advisor allows you to create and automatically manage events related to your activity within Student Advisor. To do so, Student Advisor uses OAuth token-based authentication mechanism, which gives access to your Google account data without letting it know your password. This token is securely stored on our servers and used to access Google Calendar API to manage events related to your activity in Student Advisor.
A. In particular, Student Advisor:
- Will only use access to read, modify and delete events within your calendar including event metadata, summary, start and end date.
- Does not store any data related to your Google calendar content.
- Will read and store your primary Google account email address in order to correctly identify you and link to a proper account in the calendar event link.
- Will only create new events based on your direct interaction by pressing the ‘Add to Google Calendar’ button.
- Will only modify or delete google calendar events that were created through Student Advisor.
- Will not use this Google Calendar data for serving advertisements.
- Will not allow humans to read this data.
- Google Calendar integration is optional, thus authorization of your Google account is not mandatory to use Student Advisor.
You can revoke Student Advisor access to your Google account anytime by going to Carl configuration or directly at https://globalstudy.chat/community/microbot/carl/configure (address requires being signed in).
Student Advisor’s use and transfer to any other app of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.
B. We may share and disclose your Information whenproviding the Services:
- The Customer’s Instructions. Global Study may share and disclose Information in accordance with a Customer’s instructions and with appropriate consent, including any applicable terms in the Customer Agreement and the Customer’s use of Services functionality and in compliance with applicable law and legal process. Some sharing at a Customer’s request may incur additional fees.
- To enable Global Study to follow our Customers’ instructions, Global Study provides administrator controls to allow Customers to manage their accounts. For example, we follow our Customers’ instructions to enable or disable Authorized Users' use of various features of the Services, such as the Retool administrative dashboard.
- We also follow Customer and Authorized User instructions on how an Authorized User’s profile may be displayed within a Customer’s account or when shared through other features.
- Customers may also provide their Authorized Users with the ability to adjust the audience and visibility of certain Customer Data.
- Displaying the Services: When an Authorized User submits Information, it may be displayed or discoverable to other Authorized Users in the same or connected account(s). For example, an Authorized User’s email address may be displayed with their profile, or other profile and organizational information may be displayed to Authorized Users.
- Collaborating with Others: The Services provide different ways for Authorized Users working to collaborate and interact. Information, such as an Authorized User’s profile and organizational information, may be shared, subject to the policies and practices of the account(s) you use. For example, depending on the settings of your account, to enable connections with other Authorized Users, your profile may be shared or searchable or discoverable by Authorized Users. In many instances, Global Study includes either administrator controls or user controls, depending on the use case, with respect to external collaboration. Authorized Users may also decide to expand the visibility of certain content and Customer Data, such as files.
- Customer Access: Owners, administrators, Authorized Users, and other Customer representatives and personnel may be able to access, modify, or restrict access to Information. This may include, for example, your employer using features of the Services to access or modify your profile details or to export logs of account activity.
- Third-Party Service Providers and Partners: We may engage third-party companies or individuals as service providers or business partners to process Information and support our business. These third parties may, for example, provide virtual computing and storage services, assist Global Study with verifying Owners and Customers, or we may share business information to develop strategic partnerships with Third-Party service providers to support our common customers. In this respect, depending on the Third-Party service provided, Global Study may share your Information.
- Third-Party Services: A Customer may enable, or permit Authorized Users to enable, Third-Party Services. We require each Third-Party Service provider to disclose all permissions for information accessible through the Services, but we do not guarantee that they do so. When Third-Party Services are enabled by a Customer or an Authorized User, Global Study may share Information with Third-Party Services. Third-Party Services are not owned or controlled by Global Study, and third parties that have been granted access to Information may have their own policies and practices for its collection, use, and sharing. Please check the permissions, privacy settings, and notices for these Third-Party Services or contact the provider for any questions.
- Forums: The Information you choose to provide in a community forum, including personal data, will be publicly available.
- Organizers and Sponsors of Events/Webinars: If you attend an event or webinar organized by Global Study, we may share your profile and organizational information with the event or webinar sponsors when you register, have your badge scanned, or join a breakout room. If required by applicable law, you may consent to such sharing via the registration form or by allowing your attendee badge to be scanned at a sponsor booth. In these circumstances, your information will be subject to the sponsors’ privacy statements. For more information, please refer to the terms provided when you register for such an event or webinar.
- Professional Advisers: We may share your Information with professional advisers acting as service providers, processors, controllers, or joint controllers - including lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance and accounting services, and to the extent we are legally obliged to share or have a legitimate interest in sharing your Information containing personal data.
- Corporate Affiliates: Global Study may share Information with our corporate affiliates, parents, and/or subsidiaries.
- During a Change to Global Study’s Business: If Global Study engages in a merger, acquisition, bankruptcy, dissolution, reorganization, sale of some or all of Global Study’s assets or stock, financing, public offering of securities, acquisition of all or a portion of our business, a similar transaction or proceeding, or steps in contemplation of such activities, some or all of the Information described in the ‘Information We Collect and Receive’ section may be shared or transferred, subject to standard confidentiality arrangements.
- Aggregated or De-identified Data: We may disclose or use aggregated or de-identified Information for any purpose. For example, we may share aggregated or de-identified Information with prospects or partners for business or research.
- Law Enforcement and Regulators: If we receive a request for information, we may disclose Other Information if we reasonably believe disclosure is in accordance with or required by any applicable law, regulation, or legal process.
- To Enforce Our Rights, Prevent Fraud, and for Safety: To protect and defend the rights, property, or safety of Global Study, its users, or third parties, including enforcing its contracts or policies, or in connection with investigating and preventing illegal activity, fraud, or security issues, including to prevent death or imminent bodily harm.
5. Data Retention
Global Study will retain Customer Data in accordance with a Customer’s instructions (including to perform any applicable terms in the Customer Agreement and through Customer’s use of Services functionality) and as required by applicable law. Customer may customize its retention settings and, depending on the Services plan, apply those customized settings. The Customer may also apply different settings to messages, files or other types of Customer Data. The deletion of Customer Data and other use of the Services by the Customer may result in the deletion and/or de-identification of certain associated Other Information.
Global Study takes security of data very seriously. Global Study works hard to protect Information you provide from loss, misuse, and unauthorized access or disclosure. These steps take into account the sensitivity of the Information we collect, process and store, and the current state of technology. Given the nature of communications and information processing technology, Global Study cannot guarantee that Information during transmission through the Internet or while stored on our systems or otherwise in our care will be absolutely safe from intrusion by others. When you click a link to a third-party site, you will be leaving our site and we don’t control or endorse what is on third-party sites.
7. Age Limitations
Global Study does not allow use of our Services and Websites by anyone younger than 13years old, to the extent prohibited by applicable law. If you learn that any one younger than 16 has unlawfully provided us with personal data, please contact us and we will take steps to delete such information.
9. International Data Transfers
Global Study may transfer your Personal Data to countries other than the one in which you live, including transfers to the United States. To the extent that Personal Data is transferred abroad, Global Study will ensure compliance with the requirements of the applicable laws in the respective jurisdiction in line with Global Study’s obligations.
In particular, we offer the following safeguards if Global Study transfers Personal Data from jurisdictions with differing data protection laws:
- European Commission’s Standard Contractual Clauses. Global Study uses Standard Contractual Clauses approved by the European Commission (and the equivalent standard contractual clauses for the UK where appropriate) for transfers to, among others, Australia, Canada, India, Japan, South Korea, and the United States. Global Study will transfer your Personal Data to facilitate the provision of the Services.
10. Data Protection Officer
To communicate with our Data Protection Officer, please email email@example.com.
11. Identifying The Data Controller And Processor
Data protection law in certain jurisdictions differentiates between the “controller” and “processor” of information. In general, Customer is the controller of Customer Data. In general, Global Study is the processor of Customer Data and the controller of Other Information.
12. Your Rights
Individuals in the European Economic Area, the United Kingdom, Brazil, and across the globe have certain statutory rights in relation to their personal data. Subject to any exemptions provided by law, you may have the right to request access to your personal information, as well as to seek to update, delete, or correct this information. You can do this using the settings and tools provided in your Services account. If you cannot use the settings and tools, contact the Customer who controls your account for additional access and assistance.
To the extent that Global Study’s processing of your Personal Data is subject to the General Data Protection Regulation or other applicable laws requiring a legal basis for processing Personal Data, such as the UK Data Protection Act and the Brazilian General Data Protection Act (Lei Geral de Proteção de Dados), Global Study primarily relies on its legitimate interests, described above, to process your Personal Data. Where we rely on legitimate interests to process your Personal Data, you can object to that processing by contacting us as described in the “Contacting Global Study” section below. In response to your objection, we will stop processing your information for the relevant purposes unless we have compelling grounds in the circumstances or the processing is necessary in the context of legal claims. Global Study may also process Other Information that constitutes your Personal Data for direct marketing purposes and you have a right to object to Global Study’s use of your Personal Data for this purpose at any time.
13. Your California Privacy Rights
This section provides additional details about the personal information we collect about California consumers and the rights afforded to them under the California Consumer Privacy Act or “CCPA,” as amended by the California Privacy Rights Actor “CPRA”.
- Identifiers/contact information;
- Commercial information;
- Internet or electronic network activity information;
- Financial information;
- Geolocation information;
- Professional or employment-related information;
- Audio and visual data;
- In limited circumstances where allowed by law, information that may be protected under California or United States law; and
- Inferences drawn from any of the above categories.
Global Study does not sell (as such term is defined in the CCPA or otherwise) the personal information we collect (and will not sell it without providing a right to opt out). We may also share personal information (in the form of identifiers and internet activity information) with third party advertisers for purposes after getting advertisements on non-Global Study websites, applications, and services. In addition, we may allow third parties to collect personal information from our sites or services if those third parties are authorized service providers who have agreed to our contractual limitations as to their retention, use, and disclosure of such personal information, or if you use our sites or services to interact with third parties or direct us to disclose your personal information to third parties.
Subject to certain limitations, the CCPA provides California consumers the right to request to know more details about the categories or specific pieces of personal information we collect (including how we use, disclose, or may sell this information), to delete their personal information, to opt out of any“ sales”, to know and opt out of sharing of personal information for delivering advertisements on non-Global Study websites, and to not be discriminated against for exercising these rights.
California consumers may make a request pursuant to their rights under the CCPA by contacting us at firstname.lastname@example.org. We will verify your request using the information associated with your account, including email address. Government identification may be required. Consumers can also designate an authorized agent to exercise these rights on their behalf. Authorized agents must submit proof of authorization.
If you would like to opt-out of sharing activity based on your cookie identifiers, turn on a Global Privacy Control in your web browser or browser extension. Please see the California Privacy Protection Agency’s website at https://oag.ca.gov/privacy/ccpa formore information on valid Global Privacy Controls. If you would like to opt-out of sharing activity based on other identifiers (like email address or phone number), contact us in accordance with the “Contacting Global Study” section, below.
For more information on Global Study’s role and obligations under the CCPA, please visit their website.
14. Data Protection Authority
Subject to applicable law, you also have the right to (i) restrict Global Study’s use of Other Information that constitutes your Personal Data and (ii) lodge a complaint with your local data protection authority. If, however, you believe that we have not been able to assist with your complaint or concern, and you are located in the European Economic Area or the United Kingdom, you have the right to lodge a complaint with the competent supervisory authority. If you work or reside in a country that is a member of the European Union or that is in the EEA, you may find the contact details for your appropriate data protection authority on the following website. If you are a resident of the United Kingdom you may contact the UK supervisory authority, the Information Commissioner’s Office.
15. Contacting Global Study
This privacy notice provides you with details of how we collect and process your personal data through your use of our site www.globalstudy.ai
By providing us with your data, you warrant to us that you are over 13 years of age.
Global Study Technology Limited is the data controller and we are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).
Our full details are:
Full name of legal entity: Global Study Technology Limited
Email address: email@example.com
Postal address: 25 Silverton Road, London W6 9NY
It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at firstname.lastname@example.org
We will only use your personal data for a purpose it was collected for or a reasonably compatible purpose if necessary. For more information on this please email us at email@example.com. In case we need to use your details for an unrelated new purpose we will let you know and explain the legal grounds for processing.
2. WHAT DATA DO WE COLLECT ABOUT YOU, FOR WHAT PURPOSE AND ON WHAT GROUND WE PROCESS IT
Personal data means any information capable of identifying an individual. It does not include anonymised data.
We may process the following categories of personal data about you:
- Communication Data that includes any communication that you send to us whether that be through the contact form on our website, through email, text, social media messaging, social media posting or any other communication that you send us. We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defence of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.
- Customer Data that includes data relating to any purchases of goods and/or services such as your name, title, billing address, delivery address email address, phone number, contact details, purchase details and your card details. We process this data to supply the goods and/or services you have purchased and to keep records of such transactions. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract.
- User Data that includes data about how you use our website and any online services together with any data that you post for publication on our website or through other online services. We process this data to operate our website and ensure relevant content is provided to you, to ensure the security of our website, to maintain back-ups of our website and/or databases and to enable publication and administration of our website, other online services and business. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business.
- Technical Data that includes data about your use of our website and online services such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is from our analytics tracking system. We process this data to analyse your use of our website and other online services, to administer and protect our business and website, to deliver relevant website content and advertisements to you and to understand the effectiveness of our advertising. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business and to grow our business and to decide our marketing strategy.
- Marketing Data that includes data about your preferences in receiving marketing from us and our third parties and your communication preferences. We process this data to enable you to partake in our promotions such as competitions, prize draws and free give-aways, to deliver relevant website content and advertisements to you and measure or understand the effectiveness of this advertising. Our lawful ground for this processing is our legitimate interests which in this case are to study how customers use our products/services, to develop them, to grow our business and to decide our marketing strategy.
We may use Customer Data, User Data, Technical Data and Marketing Data to deliver relevant website content and advertisements to you (including Facebook adverts or other display advertisements) and to measure or understand the effectiveness of the advertising we serve you. Our lawful ground for this processing is legitimate interests which is to grow our business. We may also use such data to send other marketing communications to you. Our lawful ground for this processing is either consent or legitimate interests (namely to grow our business).
We do not collect any Sensitive Data about you. Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We do not collect any information about criminal convictions and offences.
Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have ordered but if we do, we will notify you at the time.
We will only use your personal data for a purpose it was collected for or a reasonably compatible purpose if necessary. For more information on this please email us at firstname.lastname@example.org. In case we need to use your details for an unrelated new purpose we will let you know and explain the legal grounds for processing.
We may process your personal data without your knowledge or consent where this is required or permitted by law.
We do not carry out automated decision making or any type of automated profiling.
3. HOW WE COLLECT YOUR PERSONAL DATA
We may receive data from third parties such as analytics providers such as Google based outside the EU, advertising networks such as Facebook based outside the EU, such as search information providers such as Google based outside the EU, providers of technical, payment and delivery services, such as data brokers or aggregators.
We may also receive data from publicly available sources such as Companies House and the Electoral Register based inside the EU.
4. MARKETING COMMUNICATIONS
Our lawful ground of processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business).
Under the Privacy and Electronic Communications Regulations, we may send you marketing communications from us if (i) you made a purchase or asked for information from us about our goods or services or (ii) you agreed to receive marketing communications and in each case you have not opted out of receiving such communications since. Under these regulations, if you are a limited company, we may send you marketing emails without your consent. However you can still opt out of receiving marketing emails from us at any time.
Before we share your personal data with any third party for their own marketing purposes we will get your express consent.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you OR by emailing us at email@example.com at any time.
If you opt out of receiving marketing communications this opt-out does not apply to personal data provided as a result of other transactions, such as purchases, warranty registrations etc.
5. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below:
- Service providers who provide IT and system administration services.
- Professional advisers including lawyers, bankers, auditors and insurers
- Government bodies that require us to report processing activities.
6. DATA SECURITY
We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorisation. We also allow access to your personal data only to those employees and partners who have a business need to know such data. They will only process your personal data on our instructions and they must keep it confidential.
We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to.
7. DATA RETENTION
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
When deciding what the correct time is to keep the data for we look at its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.
For tax purposes the law requires us to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers.
In some circumstances we may anonymise your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
8. YOUR LEGAL RIGHTS
Under data protection laws you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent.
You can see more about these rights at: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.
If you wish to exercise any of the rights set out above, please email us at firstname.lastname@example.org
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive or refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you.
If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.
9. THIRD-PARTY LINKS
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 notice of every website you visit.