Last updated 30/07/2021
1. IMPORTANT INFORMATION AND WHO WE ARE
Email address: firstname.lastname@example.org
Postal address: Harmony House, 34 High Street, Walsall, WS9 8LZ.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
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.
2. THE DATA WE COLLECT ABOUT YOU
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:
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender;
- Contact Data includes billing address, delivery address, email address and telephone numbers;
- Financial Data includes bank account, Direct Debit and payment card details;
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us, including contracts;
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug‐in types and versions, operating system and platform, and other technology on the devices you use to access this website;
- Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses;
- Usage Data includes information about how you use our website, products and services;
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences
We may have obtained your personal data from a third party, where:
- The third party is acting as a referrer either because you have specifically requested our services or goods via that third‐party or the referrer is otherwise permitted to share your personal data with us for the purposes of investigating whether jitterbyte can provide you with goods or services;
- Occasionally, we purchase marketing data from third-party data providers. We only do so where we have received assurances from the third party that they have permission to share the personal data with us for us to use for electronic and other marketing purposes;
We do not collect any Special Categories of Personal Data about you (this 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). Nor do we collect any information about criminal convictions and offences.
We carry out online credit checking and can access personal payment data which shows if you or your company is subject to a County Court Judgment or bankruptcy proceedings. We do not typically store this data but might make a note on the system as an indicator of credit risk.
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 or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity, Contact and Financial Data] by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- apply for our products or services;
- subscribe to our service or publications;
- request marketing to be sent to you;
- enter a competition, promotion or survey; or
- give us feedback or contact us.
- Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
Technical Data from the following parties:
- analytics providers such as Google based outside the EU;
- advertising networks such as Yell.com based inside the EU; and
- search information providers such as Lead Forensics based in EU;
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Creditsafe based inside the EU.
- Identity and Contact Data from data brokers or aggregators such as Experian based inside and outside the EU.
- Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.
4. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract, we are about to enter or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal obligation.
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.
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.
TYPE OF DATA
for processing inc. basis of legitimate interest
To register you as a new partner, customer or prospect
Preparation to perform a contract (provision of information, quotation etc) and or/ performance of a contract with you
To process and deliver your order including:
Performance of a contract with you
To manage our relationship with you which will include:
Performance of a contract with you
Asking you to leave a review or take a survey
To enable you to partake in a prize draw, competition or complete a survey
Performance of a contract with you
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
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)
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
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 use data analytics to improve our website, products/services, marketing, customer relationships and experiences
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
Necessary for our legitimate interests (to develop our products/services and grow our business)
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Promotional offers from us
We may use your Identity, Contact, 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 (marketing).
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.
We will get your express opt‐in consent before we share your personal data with any third party for marketing purposes.
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 contacting us at hello@mysecureworkspace at any time.
Where you opt-out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/ service experience or other transactions.
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 at the details outlined above.
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.
5. DISCLOSURES OF YOUR PERSONAL DATA
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 and as described below.
- Service providers acting as processors based in the EEA who provide Cloud Services, Telecommunications Services, IT and System Administration services;
- Service providers acting as processors based outside the EEA who provide Cloud Services. Telecommunications Services, IT and System Administration services where you have requested some or all of your services be performed outside the EEA. Similarly, we may need to transfer your personal data to regulators based outside the EEA where that is necessary, for example, to confirm your registration as owner/operator of a line based outside the EEA.
- Professional advisers including lawyers, bankers, auditors and insurers based in in the EEA who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.
- Administration proceedings where we must provide access to the appointed administrator or other legal representatives to allow them to manage the account and associated services.
- Where a change of ownership occurs on your account, we will liaise with you to arrange the transfer of your services to a new owner or business where instructed. To enable this process, we may share details of live services and telephone numbers to enable the new owner to contract for the services in their own right.
- Occasionally there are grants available for the provision of services. When you apply for a grant via jitterbyte we may ask you to complete an application form and provide supporting evidence to enable your grant application to be processed. We will share this information with the grant provider to further your application.
- Where you have been introduced to us by a referral Partner, we may share data (including detailed usage data) with that referrer and jointly manage your customer experience in order to ensure you receive appropriate and streamlined services from us both.
- Where required by law, regulation, order of a court or regulator or similar proceeding, requirement or request we will share your data with the relevant administrators, regulators, Government Department, judicial body, Government body, authority or partner requesting or entitled to receive that data.
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.
6. INTERNATIONAL TRANSFERS
Some of our external third parties are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA. If you have requested services or goods which are based or performed outside the EEA, we will have to transfer your data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy decisions. https://ec.europa.eu/info/law/lawtopic/data‐ protection/international‐dimension‐data‐protection/adequacy‐decisions_bg
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Standard Contractual Clauses. https://ec.europa.eu/info/law/law‐ topic/data‐protection/international‐dimension‐dataprotection/standard‐contractual‐clauses‐ scc_hu
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU‐US Privacy Shield. https://ec.europa.eu/info/law/law‐topic/data‐protection/international‐dimensiondata‐ protection/eu‐us‐data‐transfers_en
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA. There may be occasions on which you have requested services be performed in a country in which none of the above safeguards are implemented with the relevant in‐country provider, regulator or other third party. In those rare cases your data may have to be transferred if you wish to proceed with the relevant services and/or goods, but we will notify you that we do not have in place adequate safeguards and we will to the fullest extent possible minimise the personal data transferred in such circumstances.
7. DATA SECURITY
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, partners, 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.
8. DATA RETENTION
How long will we use your personal data?
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.
By law we must keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax and other regulatory purposes.
In some circumstances you can ask us to delete your data: see your legal rights section below for further information.
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.
9. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
- Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data’s accuracy.
- Where our use of the data is unlawful, but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine‐readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact our Privacy Manager whose details are set out above.
No fee usually required
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. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
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.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance using the contact details set out above.
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