Privacy Notice
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Privacy Notice

Last updated December 2019
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Welcome to the privacy notice for GetBusy which includes GetBusy UK Limited, GetBusyAustralia Pty Limited and GetBusy New Zealand Pty Limited, (referred to in this privacy notice as “we”, “us” or “our”). You can contact us to find out further information about our group structure.

This privacy notice is for the GetBusy Group products and services: GetBusy, and Virtual Cabinet.

We respect your privacy and are committed to protecting your personal data. This privacy notice describes how we collect, use and disclose your personal data, and what rights you have with respect to the use of it.

Personal data, also known as personal information, or personally identifiable information, means any information about an individual from which that individual can be identified.

By using our products and/or services you signify that you have read and understood this privacy notice.

Purpose of this privacy notice

This privacy notice sets what personal data, we hold about you, how we collect and use that data and other key information about your rights in respect of our use of your personal data.

We may hold your personal data either for our own purposes or on behalf of our customers. Under UK and European data protection laws, we are acting as a “data controller” where we use your personal data for our purposes and determine how and why we use your personal data.

We are acting as a “data processor” where we hold personal data 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.

In line with our obligations under relevant data protection laws, this privacy notice sets out how we will collect, hold and use your personal data where we are a data controller.  In particular the table in the section “How we use your personal data” below specifies the purposes for which we may use your personal data as a data controller.

Where we refer to “you” and “your” in this privacy notice, we are talking to the individual whose personal data we use as a data controller.

We have used the following terms in this privacy notice:

“Customer Organisation”: a customer organisation (such as company or professional firm)that has signed up for a product and/or service offered by the GetBusy group.

“Individual Customer”: an individual customer (for example, a sole trader) who has signed up for a product and/or service offered by the GetBusy group (this does not include an individual employed or otherwise engaged by a Customer Organisation, who is authorised by the Customer Organisation to use the product and/or service).

This privacy notice addresses our use of personal data about you as an individual(in relation to your use of our Services) rather than our use of information about our Customer Organisations, which is dealt with separately through our Terms of Service.

Our Contact Details:

By Email:
Privacy@GetBusy.com

By Post:
Privacy Team
GetBusy
Unit G
South Cambridgeshire Business Park
Sawston
Cambridge
CB22 3Jh
United Kingdom

By Phone:

UK: 01223 666880
Australia: 1300223090 
New Zealand: 09 950 8410(Option 1)
California: (855)279 7195

Personal data that we hold on behalf of our Customers:

Some of the data stored by customers through our products and services incorporates personal data about individuals. This includes data we hold on behalf of our Customer Organisations and data we hold on behalf of our Individual Customers and where we hold personal data on their behalf about other people.

Where we hold this data solely on behalf of our customers and do not use it for our own purposes, under UK and European data protection laws we will be acting as a “data processor” and will hold that personal data 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 personal data.

Though we will of course keep this personal data secure as a key feature of any product or service that we provide, this privacy notice does not address our use of personal data where we are acting as a data processor because in those circumstances it is our customers’ responsibility to provide this information to the people whose personal data we hold.

What types of personal data we have:

We may collect, use and hold the following different kinds of personal data about you (depending on whether you are an Individual Customer, or an individual user of our products and/or services employed by one of our Customer Organisations):

  • Identity Data including first name, last name, username or similar identifier, title, data of birth and gender.
  • Profile Data including your username and password, user preferences, comments feedback and other information that you submit to our products and/or services.
  • Contact Data including postal address, email address and telephone numbers.
  • Customer Content Data being personal data contained in documents, messages, comments, text and images that you upload to or transmit through the products and services that we provide.
  • Support Data being comments, feedback and information that you submit to us when using our support services.
  • Financial and Transaction Data including bank account, payment card details, billing address and other payment details.
  • Technical Data including unique user identifier, internet protocol(IP) address, 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 our products and services.
  • Usage Data being information about how you use our products and services (for example, through metadata, we log the areas, activity types, people, features, content and links you interact with, the type of files you share and what third party services you use, if any).
  • Marketing Data including your marketing preferences in relation to receiving marketing communications from us and, where relevant, third parties.

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 products or 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.

How we get personal data:

  • Direct interactions with you. For example, you may submit your personal data(including identity data and contact data) to us as part of submitting an enquiry form on our website or to set up an account for one of our products or services or we may send marketing materials and promotions to you (in accordance with your marketing preferences).
  • Automated technologies or interactions. As you interact with our products and/or services, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this data by using cookies, server logs and other similar technologies. You can control cookies through your browser’s settings and other tools. However, if you block certain cookies, you may not be able to register, login, or access certain parts or make full use of the products and services that you sign up for or are otherwise authorised to access. Please see our cookie policy [insert link] for further details.
  • Third parties. We may receive your name and contact details from an existing customer who invites you to use a product or service, messages you through a product or service or through a referral arrangement with our business partners. We may also source marketing lists from third parties which contain personal data (i.e. identity data and contact data) about those that might be interested in our products and services. (i.e. identity data and contact data) about those that might be interested in our products and services.

Please Note: that where we have received your personal data from a third party, we expect that all relevant and appropriate consents have been sought and granted.

What we do with personal data:

Where we are a data controller in respect of your personal data, we are required by UK and EU data protection law to be clear about the purposes for which we are processing that personal data 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 data in our capacity as a data controller.

Purpose/Activity Lawful basis for processing (Under UK and EU data protection law)
For account management and other administrative purposes including keeping track of billing and payments and alerting you to an incomplete account set-up. Necessary for our legitimate interests (where you are (i) an Individual Customer or (ii) a billing or other account management contact at the Customer Organisation) Necessary for the performance of our contract with you (where you are an Individual Customer)
For marketing and communication purposes such as making 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
To administer and protect our business and keep the Service working, safe and secure (by troubleshooting, data analysis, testing, system maintenance and monitoring and addressing other security/technical issues). Necessary for our legitimate interests for running and protecting our business, ensuring appropriate security, investigating and helping to prevent security issues and abuse, to prevent fraud and so on. Necessary to comply with a legal obligation
To improve our website, products/services, marketing, customer relationships and experiences (using data analytics etc.) 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
Where you are an Individual Customer, for providing the Service to you, notifying you about changes or updates to the Service and responding to your support queries. Necessary for the performance of our contract with you Necessary for our legitimate interests to develop our products/services and grow our business

Note: We may process your personal data using more than one lawful ground depending on the specific purpose for which we are using your personal data. Please contact us if you would like details about the specific legal ground we are relying onto process your personal data where more than one ground has been set out in the table above.

Where you are an Individual Customer, the provision of your personal data 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 products and services. You are not required to give your consent but, if you choose not to, you must not submit to our products and services any personal data 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, we may not be able to respond to your queries or provide our products and services to you.

Marketing:

We want to provide you with choices regarding certain uses of your personal data, 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 opted in to receiving that marketing.

International transfers:

Where you are based in the European Economic Area (“EEA”) we will transfer your personal data outside of the European Economic Area (“EEA”) when we share the personal data with:

  • The entities within our GetBusy group;
  • Our service providers (as specified in the section above) based outside of the EEA; and
  • Our business partners including integrators.

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 theGetBusy group or our service providers that are based outside of the EEA, we use specific contracts approved by the European Commission and/or ensure that they are certified under the EU-US privacy shield framework as having adequate safeguards in place which ensure that your personal data is given the same protection it has in the UK and 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.

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 privacy@getbusy.com if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

How we store your personal data:

Your personal data is securely stored either in our own servers hosted at our UKOffice or hosted by Amazon Web Services (AWS) in the UK, Republic of Ireland,Germany, Australia, and USA depending on the product or service and where you are based.

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, contractors and other third-party service providers 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. For more information about our security practices please see here.

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.

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.

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 data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this data indefinitely without further notice to you.

Your data protection rights:

Under certain circumstances, you have rights under data protection laws in relation to your personal data. This may include the following rights:

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 information we hold about you corrected.

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 exercised your right to object to processing (see below).

Object to processing of your personal data. This right applies where we are relying on our legitimate interests (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. You also have the right to object where we are processing your personal data for direct marketing purposes.

Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.

Request the transfer of your personal data to another party (known as the “right to data portability”).

Withdraw consent. This right applies only if we are relying on your consent to process any of your personal data. This will not affect the lawfulness of any processing carried out before you withdraw your consent.

Not be discriminated against if exercise rights. Should you exercise any of your data rights, we will not discriminate against you in any way.

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 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 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 and keep you updated. Please contact us at privacy@getbusy.com if you wish to make a request.

How to complain:

You have the right to make a complaint at any time to the UK supervisory authority for data protection issues. This is the Information Commissioner's Office (ICO) if you are unhappy with how we have used your data.

The ICO’s address:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Helpline number: 0303 123 1113

We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please do get in touch using the details in our “Contacting us” section above.

Personal data collected from children:

You must be at least 18 years old to use products and services We do not knowingly collect personal data from children under 18. If we learn we have collected or received personal data from a child under 18 years old, we will delete it without undue delay.

Changes to this privacy notice:

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 data.

If you have any questions about this privacy notice, please contact privacy@getbusy.com.

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