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We may hold your personal information either for our own purposes or on behalf of our customers. Under European data protection laws, we are acting as a “data controller” where we use your information for our purposes and determine how and why we use your information. We are acting as a “data processor” where we hold personal information on behalf of a Customer Organisation (or, in certain circumstances, an Individual Customer). Whether we are acting as a data controller or a data processor will depend on the circumstances.
Some of the information stored by customers through our Services incorporates personal information about individuals. This includes information we hold on behalf of our Customer Organisations and information we hold on behalf of our Individual Customers, where we hold information on their behalf about other people.
Where we hold this information solely on behalf of our customers and do not use it for our own purposes, under European data protection laws we will be acting as a “data processor” and will hold that information in accordance with the terms of our contracts with our customers. In these circumstances, our customers will be acting as data controllers in respect of the information.
Personal data, or personal information means any information about an individual from which that individual can be identified.
We may collect, use and hold the following different kinds of personal information about you (depending on whether you are an Individual Customer or an individual user of our Services employed by one of our Customer Organisations):
In limited circumstances, where you are an Individual Customer, we may be a data controller in respect of special categories of data about you. This will only be the case if you upload or otherwise transmit these types of data about yourself when using our Services (for example, if you upload documents or send messages that contain special categories of data about yourself). Special categories of data attract a higher level of protection under data protection laws and include data concerning health and sexual orientation and data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership.
We use the following different methods to collect data from and about you including through:
Where we are a data controller in respect of your personal information, we are required by European data protection laws to be clear about the purposes for which we are processing that personal information and our lawful basis for doing so.
We set out below, in a table format, a description of the ways we plan to use your personal information in our capacity as a data controller.
Note that we may process your personal information using more than one lawful ground depending on the specific purpose for which we are using your information. Please contact us if you would like details about the specific legal ground we are relying on to process your personal information where more than one ground has been set out in the table below.
Where you are an Individual Customer, the provision of your personal information is necessary for us to enter into a contract with you and to perform that contract. Where you are an Individual Customer, we will also ask for your explicit consent to process any special categories of data about yourself that you upload to or otherwise transmit through our Services. You are not required to give your consent but, if you choose not to, you must not submit to our Services any information about yourself that incorporates special categories of data.
We are a provider of products and services and you are not obliged to provide your personal details to us. However, if you choose not to provide your personal information to us, we may not be able to respond to your queries or provide our products and services to you.
We want to provide you with choices regarding certain personal information uses, particularly around marketing and advertising. You can ask us at any time to stop sending you messages by unsubscribing from emails or otherwise contacting us to specify your marketing preferences.
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.
You will receive marketing communications from us where you have requested products or services from us as an Individual Customer or if you have requested information from us and, in each case, you have not opted out of receiving that marketing.
In addition, if we choose to sell, transfer, or merge parts of our business or our assets or if we seek to acquire other businesses or merge with them, we may need to share your personal information with those other businesses. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal information 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 information for specified purposes and in accordance with our instructions.
We will transfer your personal information outside of the European Economic Area (“EEA”) when we share the information with:
Whenever we transfer your personal data outside of the EEA, we ensure that safeguards are in place which meet the standards required by European data protection laws.
Where we transfer your personal data to corporate entities within the GetBusy group that are based outside of the EEA, we use specific contracts approved by the European Commission which ensure that your personal information is given the same protection it has in Europe. For further details and a copy of the relevant contracts, see the European Commission’s webpage on the model contracts for the transfer of personal data to third countries.
Where we transfer your personal data to our US based service providers or business partners, we ensure that they are certified under the EU-US privacy shield framework as having adequate safeguards in place. For further details on the privacy shield framework, you can go to the privacy shield website at https://www.privacyshield.gov/Program-Overview.
Please contact firstname.lastname@example.org if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third party service providers who have a business need to know. They will only process your personal information 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.
We will only retain your personal information 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.
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 requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax and legal purposes.
In some circumstances you can ask us to delete your data: see the “erasure” right in the section below for further information.
In some circumstances we may anonymise your personal information (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.
Under certain circumstances, you have rights under data protection laws in relation to your personal information. This may include the following rights:
If you wish to exercise any of the rights set out above, please contact email@example.com.
You will not have to pay a fee to access your personal information (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 may 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 information (or to exercise any of your other rights). This is a security measure to ensure that personal information 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 and keep you updated.
We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.
If you have any questions about this privacy notice, please contact firstname.lastname@example.org.
You are welcome to contact us. Our contact details are as follows:
GetBusy Privacy Team | email@example.com
Last updated May 2018.