Updated: 29 Jan 2018
How do we handle your personal information?
Here we have set out:
- the general categories of personal information that we may process;
- in the case of personal information that we did not obtain directly from you, the source and specific types of personal information;
- the purposes for which we may process personal information; and
- the legal bases of the processing.
We may process information about your use of our website and our services (“usage information“). The usage information may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of service use. The sources of the usage information are our website analytics tracking systems (see below for more details). This usage information may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.
We may process your website account information (“account information“). The account information may include your name and email address. The account information may be processed for the purposes of operating our website, providing our services, ensuring the security of our website, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is consent.
We may process information relating to transactions, including purchases of our services, that you enter into with us and/or through our website (“transactional information“). The transactional information may include your contact details and card details. The transactional information may be processed for the purpose of supplying the services and keeping proper records of those transactions. The legal basis for this processing is our legitimate interests, namely our interest in properly administering our website and business.
We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification information“). The notification information may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent.
We may process information contained in or relating to any communication that you send to us (“correspondence information“). The correspondence information may include the communication content and metadata associated with the communication. Our website will generate metadata associated with communications made using the website contact forms. The correspondence information may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business, and communications with users.
In addition to the purposes specified elsewhere in this Section 2, we may process your personal information:
- to deal with enquiries and complaints made by or about you relating to our website;
- to keep our website secure and prevent fraud;
- to verify compliance with the terms and conditions governing the use of our website (including monitoring private messages sent through our website private messaging service); and
- where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
In addition to the personal information identified above, we may process personal information included in project proposals with respect to which we provide services (“project information“). We will process this information on behalf of our customer, and our customer (or our customer’s customer) will act as data controller with respect to the project information. We will act as a data processor (or sub-processor) with respect to that information, and our rights and obligations with respect to that information are set out in our non-disclosure and services terms and conditions.
If you would like more information about how we have balanced our legitimate interests against our interests when determining the legal basis for our processing, please get in touch.
Disclosure your personal information
In addition to the disclosures specified elsewhere in this policy, we may disclose your personal information to any of our employees, officers, insurers and professional advisers insofar as reasonably necessary for the purposes set out in this policy.
We may also disclose your personal information:
- to the extent that we are required to do so by law;
- in connection with any ongoing or prospective legal proceedings;
- in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk); and
- to any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.
Which services providers do we use?
We use Intercom, Inc. to help understand your usage of our services. We provide a limited amount of your information (such as your email address and sign-up date) to Intercom for analytics purposes when you visit our website or use our services. Intercom analyses your use of our website and services and tracks our relationship so that we can improve our services. We may also use Intercom as a medium for communications, either through email, or through messages sent via our website and services. Intercom may also collect publicly available contact and social information related to you, such as your email address, gender, company, job title, photos, website URLs, social network handles and physical addresses, to enhance your user experience. For more information on the privacy practices of Intercom, please visit https://www.intercom.com/terms-and-policies#privacy. If you would like to opt out of having this information collected by or submitted to Intercom, please contact us.
What personal information is transferred internationally?
Information that we collect may be stored and processed in and transferred between any of the countries within the European Economic Area in which we operate in order to enable us to use the information in accordance with this policy.
In addition to the United Kingdom and other countries within the European Economic Area, information that we collect may be transferred to Australia or New Zealand which do not have data protection laws equivalent to those in force in the European Economic Area. We will safeguard personal information in relation to such transfers by requiring relevant persons to enter into the standard contractual clauses for international data processing contracts.
You expressly agree to the transfers of personal information described in this Section 5.
What are our data retention and deletion policies?
This section sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal information.Personal information that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes. In particular, our standard policies for data retention are as follows:
- usage information is retained for a period of 12 months following collection, and notification information is retained for a period of 12 months following your notice that you no longer wish to received notifications from us; and
- account information, transactional information and correspondence information are retained for a longer period to ensure that we can comply with our legal record-keeping obligations and defend our legal rights; this information is retained for 6 years following the later of: (i) the date of collection; and (ii) the date that you close your account.
Notwithstanding the other provisions of this section, we will retain documents (including electronic documents) containing personal data:
- to the extent that we are required to do so by law;
- if we believe that the documents may be relevant to any ongoing or prospective legal proceedings; and
- in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).
How do we ensure the security of your personal information?
We will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information. We will store all the personal information you provide on our secure (password- and firewall-protected) servers. All electronic financial transactions entered into through our website will be protected by encryption technology. You acknowledge that the transmission of information over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet. You are responsible for keeping the password you use for accessing our website confidential; we will not ask you for your password (except when you log in to our website).
Amendments to this policy
We may update this policy from time to time by publishing a new version on our website. You should check this page occasionally to ensure you are happy with any changes to this policy.
You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to:
- the payment of a fee (currently fixed at GBP 10); and
- the supply of appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address).
We may withhold personal information that you request to the extent permitted by law. You may instruct us at any time not to process your personal information for marketing purposes. In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.
Third party websites
Our website includes hyperlinks to, and details of, third party websites. We have no control over, and are not responsible for, the privacy policies and practices of third parties.
Please let us know if the personal information that we hold about you needs to be corrected or updated.