PRIVACY POLICY
Zivio respects your privacy and is committed to protecting your personal data. This Privacy Policy aims to give you information on how we collect and process your personal data and will inform you as to how we look after your personal data and tell you about your privacy rights.
We will process and protect your personal data as set out in this Privacy Policy, so please read it carefully.
IMPORTANT INFORMATION AND WHO WE ARE
Controller:
Talon Operating Ltd, (collectively referred to as “we”, “us” or “our”) is software development business.
Talon Operating Ltd are the controller and are responsible for your personal data, which means that we determine the purposes and ways of the processing of your personal data.
Contact Details:
Our full details are:
Company name: Talon Operating Ltd
Registered address: City Gates, 2-4 Southgate, Chichester, West Sussex, PO19 8DJ
Contact Name: Tim Williams
If you have any general enquiries related to this Privacy Policy please email us here:
[email protected]. This email address is monitored on a regular basis and we aim to respond to your query as soon as possible.
CHANGES TO THE PRIVACY NOTICE
We may modify this Privacy Policy at any time, however, if we make any material changes to it we will revise the date at the top of the policy and provide you with notice either via a message on our website or via sending you an email so that you have the opportunity to review the changes before they become effective.
YOUR RESPONSIBILITY TO INFORM US OF CHANGES
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.
THE DATA WE COLLECT ABOUT YOU
Personal data means any information about an you from which you can be identified. It does not include data where the identity has been removed (i.e. anonymous data).
We use different methods to collect data from and about you, including through:
• Direct interactions. This refers to personal data you provide directly to us by corresponding with us via post, phone or email or by completing our online enquiry forms.
• Automated interactions. As you interact with our website, we may automatically collect data about your equipment, browsing actions, which may include your IP address, the browser type, your location, language preferences device information and access times.
· Cookies. We may receive data about you if you visit other websites employing our cookies. Please see our cookie policy for more details about this.
• Third Parties: We may also receive data about you from third parties, as set out below.
Data Collected by Us
We may process different kinds of personal data about you which we have grouped together follows:
• Account/Profile Data includes data such as your first name, last name, password, email address, phone number and Skills Data;
• Marketing and Communications Data includes data such as your preferences in receiving marketing from us and our third parties and your preferred contact method (e.g. email);
• Technical Data includes data such as your 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 the website; and
• Usage Data includes data such information about how you use our website, products and services.
DATA WE DO NOT COLLECT
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.
This website is not intended for children and we do not knowingly collect data relating to children.
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.
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 via
[email protected] if you need details about the specific legal ground we are relying on to process your personal data.
(a) Consent: the individual has given clear consent for you to process their personal data for a specific purpose.
(b) Contract: the processing is necessary for a contract you have with the individual, or because they have asked you to take specific steps before entering into a contract.
(c) Legal obligation: the processing is necessary for you to comply with the law (not including contractual obligations).
(d) Vital interests: the processing is necessary to protect someone’s life.
(e) Public task: the processing is necessary for you to perform a task in the public interest or for your official functions, and the task or function has a clear basis in law.
(f) Legitimate interests: the processing is necessary for your legitimate interests or the legitimate interests of a third party unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests. (This cannot apply if you are a public authority processing data to perform your official tasks.)
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest
| To administer and protect our business and website (including security, troubleshooting, testing, system maintenance, support, reporting and hosting of data) | (a) Account/Profile Data (b) Technical Data (c) Usage Data | Legitimate interests (see below)
| To use data analytics to improve our website, products/services, marketing, customer relationships and experiences | (a) Technical (b) Usage | Legitimate interests (see below)
LEGITIMATE INTERESTS
We have a legitimate interest in processing your personal data for the purposes of administering and protecting our business and website (including security, troubleshooting, testing, system maintenance, support, reporting and hosting of data). We will only use the personal data that we consider to be necessary for these purposes such as Account/Profile Data, Technical Data and Usage Data. We consider that this does not impact on your rights and freedoms because it is important for us to keep the security of our website up to date to help protect your personal data. You can contact us
[email protected] for more details.
We have a legitimate interest in processing your personal data for the purposes of improving our products and website because we value your feedback as one of our users and we will use this to inform us as to how we can make such improvements. We will only use the personal data that we consider to be necessary for these purposes such as Technical data and Usage data. If you do not want us to process your data for these purposes, then please email
[email protected].
MARKETING FROM US
We may use your personal 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 (we call this marketing).
You will receive marketing communications from us (i) if you have requested information from us; or (ii) if you have signed up to use the services or created an account/profile; or (iii) registered for a promotion; and, in each case, you have not opted out of receiving that marketing.
THIRD-PARTY MARKETING
We will get your express consent before we share your personal data with any other company for marketing purposes.
OPTING OUT
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 you can Contact us
[email protected] at any time.
COOKIES
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.
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
[email protected].
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.
6. INTERNATIONAL TRANSFERS
We will use third party service providers that are based outside the European Economic Area (EEA) and this will involve the transfer of your personal data outside the EEA. As a result, the transferred data may not be processed and protected in the same way as set out in this Privacy Policy. You need to be aware that if your information is transferred to a country outside the EEA, that country may not have adequate data protection laws or appropriate safeguards.
Whenever we transfer your personal data out of the EEA, we will endeavour to ensure a similar degree of protection is afforded to it by aiming to have 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.
• Where we use certain service providers, we may use specific clauses approved by the European Commission which give personal data the same protection it has in Europe.
• 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 the Europe and the US.
Please Contact us
[email protected] if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
7. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being 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 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 YOU USE MY PERSONAL DATA FOR?
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 Account/Profile Data, Financial Data and Transaction Data) for six years after you cease being a customer (including for tax and accounting purposes).
In some circumstances you can ask us to delete your data: see below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for reporting and website analytical 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, as follows:
1. To request access to your personal data (commonly known as a “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.
2. To request confirmation as to whether or not your personal data is being processed.
3. To request the correction of your personal data that you consider to be inaccurate. This enables you to have any incomplete or inaccurate data we hold about you corrected. However, we may need to verify your identity and the accuracy of the new data you provide to us.
4. To request erasure of your personal data. This enables you to ask us to delete or remove personal data, including 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. These reasons will be notified to you at the time of your request.
5. To object to processing of your personal data. This enables you to object to thE processing of your personal data if you feel it impacts on your fundamental rights and freedoms. In some cases, we may have compelling legitimate grounds to process your information which can override your right to object.
6. To request restriction of processing your personal data. This gives you the option to ask us to suspend the processing of your personal data e.g. if you want us to establish the data’s accuracy or you do not want us to erase it.
7. To request transfer of your personal data. If you request us to do so, we will provide to you, or a third party of your choice, your personal data in a commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use.
8. To withdraw consent to the processing of your data. If you request us to do so, we will no longer process your data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we will not be able to provide the services for you.
9. To not have a decision made about you based solely on
automated processing. If you wish to exercise any of the rights set out above, in the first instance, please Contact us
[email protected].
We will respond to you within 30 days of receipt of your request. Occasionally it may take us longer than 30 days 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.
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
[email protected] in the first instance.
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 may 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.
