Privacy Notice v2 Updated 30/03/2022
We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation (UK GDPR).
1. Key terms
It would be helpful to start by explaining some key terms used in this policy:
We, us, our: Software Acumen Limited
Personal data: Any information relating to an identified or identifiable individual
Special category personal data:
- Personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership
- Genetic and biometric data (when processed to uniquely identify an individual)
- Data concerning health, sex life or sexual orientation
Data subject: The individual who the personal data relates to
2. Personal data we collect about you
The personal data we collect about you depends on the particular services we provide to you. We will collect and use some of the following personal data about you:
- your name and contact information, including email address and telephone number and company details
- information to check and verify your identity, eg your date of birth
- your gender, if you choose to give this to us
- location data, if you choose to give this to us
- your billing information, transaction and payment card information
- your professional online presence, eg Twitter profile
- your contact history, purchase history and saved items
- information about how you use our website, IT, communication and other systems
- your responses to surveys, competitions and promotions
We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below. If you do not provide personal data we ask for, it may delay or prevent us from providing services to you.
3. How your personal data is collected
We collect most of this personal data directly from you—in person, by telephone, text or email and/or via our website. However, we may also collect information from a third party with your consent or from cookies on our website.
4. How and why we use your personal data
Under data protection law, we can only use your personal data if we have a proper reason, eg:
- where you have given consent;
- to comply with our legal and regulatory obligations;
- for the performance of a contract with you or to take steps at your request before entering into a contract; or
- for our legitimate interests or those of a third party.
A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own.
5. How and why we use your personal data—sharing
See ‘Who we share your personal data with’ for further information on the steps we will take to protect your personal data where we need to share it with others.
We will use your personal data to send you updates (by email, telephone or post) about our services, including exclusive offers, promotions or new services.
We have a legitimate interest in using your personal data for marketing purposes (see above ‘How and why we use your personal data’). This means we do not usually need your consent to send you marketing information. If we change our marketing approach in the future so that consent is needed, we will ask for this separately and clearly.
You have the right to opt out of receiving marketing communications at any time by contacting us or using the ‘unsubscribe’ link in emails.
We may ask you to confirm or update your marketing preferences if you ask us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.
We will always treat your personal data with the utmost respect and never sell it with other organisations for marketing purposes.
7. Who we share your personal data with
We routinely share personal data with:
- third parties we use to help deliver our services to you, eg payment service providers, platform providers;
- other third parties we use to help us run our business, eg marketing agencies or website hosts; cloud providers
- third parties approved by you, eg social media sites you choose to link your account to or third party payment providers.
We or the third parties mentioned above occasionally also share personal data with:
- our and their external auditors, eg in relation to the audit of our or their accounts, in which case the recipient of the information will be bound by confidentiality obligations;
- our and their professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations;
- law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations;
- other parties that have or may acquire control or ownership of our business (and our or their professional advisers) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised but this may not always be possible. The recipient of any of your personal data will be bound by confidentiality obligations.
8. Where your personal data is held
Personal data may be held at our offices and those of our third party agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal data with’).
Some of these third parties may be based outside the UK. For more information, including on how we safeguard your personal data when this happens, see below: ‘Transferring your personal data out of the UK’.
9. How long your personal data will be kept
We will not keep your personal data for longer than we need it for the purpose for which it is used. Different retention periods apply for different types of personal data.
10. Transferring your personal data out of the UK
It is sometimes necessary for us to transfer your personal data to countries outside the UK. In those cases we will comply with applicable UK laws designed to ensure the privacy of your personal data.
Under data protection laws, we can only transfer your personal data to a country outside the UK where:
- in the case of transfers subject to UK data protection law, the UK government has decided the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy regulation’) further to Article 45 of the UK GDPR; or
- there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you; or
- a specific exception applies under relevant data protection law.
11. Your rights
You have the following rights, which you can exercise free of charge:
The right to be provided with a copy of your personal data
The right to require us to correct any mistakes in your personal data
Erasure (also known as the right to be forgotten)
The right to require us to delete your personal data—in certain situations
Restriction of processing
The right to require us to restrict processing of your personal data in certain circumstances, eg if you contest the accuracy of the data
The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
The right to object:
- at any time to your personal data being processed for direct marketing (including profiling);
- in certain other situations to our continued processing of your personal data, eg processing carried out for the purpose of our legitimate interests unless there are compelling legitimate grounds for the processing to continue or the processing is required for the establishment, exercise or defence of legal claims
Not to be subject to automated individual decision making
The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you
The right to withdraw consents
- If you have provided us with a consent to use your personal data you have a right to withdraw that consent easily at any time
- Withdrawing a consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn
For more information on each of those rights, including the circumstances in which they apply, please contact us (see ‘How to contact us’ below) or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights.
If you would like to exercise any of those rights, please:
- email, call or write to us, see below: ‘How to contact us’; and
- provide enough information to identify yourself (eg your full name, address and customer or matter reference number) and any additional identity information we may reasonably request from you;
- let us know what right you want to exercise and the information to which your request relates.
12. Keeping your personal data secure
We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your personal data will do so only in an authorised manner and are subject to a duty of confidentiality. We also have procedures to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
If you want detailed information from Get Safe Online on how to protect your personal data and other information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
13. How to complain
Please contact us if you have any queries or concerns about our use of your personal data (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.
You also have the right to lodge a complaint with the Information Commissioner. The Information Commissioner may be contacted using the details at https://ico.org.uk/make-a-complaint or by telephone: 0303 123 1113.
We may change this privacy notice from time to time—when we do we will inform you via our website or email.
15. How to contact us
Our contact details are shown below:
Software Acumen Ltd, St Johns Innovation Centre, Cowley Road, Cambridge, CB4 0WS