PRIVACY NOTICE
VERSION DATED: 14 September 2022
This privacy notice explains how Fire DNA Limited collects and uses personal data and provides information about privacy rights and how the law protects persons, including our customers, suppliers and users of the platform, whose personal data we use in our business.
This privacy notice is provided in a layered format so you can click through to the specific areas set out below. The Glossary at the end to understand the meaning of some of the terms used in this privacy notice.
1. Important information and who we are
This privacy notice aims to give you information on how Fire DNA collects and processes personal data through the Fire DNA software platform (“Platform”). It also provides information on how we collect and use data outside the Platform for purposes of our business.
Where you are an individual customer, a registered user of the Platform or a member of the public accessing the Platform, we may collect and process personal data about you arising from your use of the Platform, including any data you may provide when you register for an account, purchase a product or service through the Platform, or interact with the Platform to upload or download data.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements other notices and privacy policies and is not intended to override them.
Controller
Fire DNA Limited is the controller and responsible for your personal data (collectively referred to as “Fire DNA”, “we”, “us” or “our” in this privacy notice).
We have appointed a Data Privacy Manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the Data Privacy Manager using the details set out below.
Contact details
If you have any questions about this privacy notice or our privacy practices, please contact our Data Privacy Manager in the following ways:
Email address: info@fire-dna.com
Postal address: Fire DNA Limited, Ashcombe Court, Woolsack Way, Godalming, Surrey, United Kingdom, GU7 1LQ
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator 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 would encourage you to contact us in the first instance.
Changes to the privacy notice and your duty to inform us of changes
We keep our privacy notice under regular review – the date of last review is given at the start of this notice.
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 by updating your account details using the management tools on the Platform.
Third-party links
The Platform and our websites may include links to third-party websites, plug-ins and applications, including sites operated by product manufacturers, installers, maintainers or property owners. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements.
2. The data we collect about you
“Personal data” means any information about a living individual from which that person can be identified, whether by itself or when combined with other information. It does not include data about individuals which has been permanently altered so that an individual can no longer be identified. (anonymous or “anonymized” data).
We may collect, use, store and transfer different kinds of personal data about our customers and Platform users which we have grouped together as follows:
- Identity Data includes first name, last name (including previous names), username or similar identifier, title, date of birth and gender.
- Contact Data includes billing, contact and delivery addresses, email addresses, usernames, handles and other contact information for online or digital messaging services and social media, and telephone numbers.
- Financial Data for customers, including bank account and payment card details.
- Transaction Data includes details about payments to and from customers and details of products and services which customers have purchased from us.
- Technical Data includes internet protocol (IP) address, user 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 customers’ and users’ usernames and passwords, purchases or orders made or initiated by users, your interests, preferences, feedback and correspondence (including chat, helpdesk or technical queries).
- Usage Data includes information about how customers use our website, products and services.
- Marketing and Communications Data includes user and customer preferences in receiving marketing from us and your communication preferences.
We may collect, analyse, use and share Aggregated Data derived from use of the Platform by any user and based on the data uploaded onto the Platform by users (or obtained from other sources, such as public records) such as statistical or demographic data for any purpose, including (but not limited to) monitoring or improving Platform performance, identifying trends or patterns related to fire safety, certification standards, or the performance and maintenance characteristics of products and product categories.
Aggregated Data could be derived in part from personal data processed via the Platform, but is not considered personal data, since it will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any Special Categories of Personal Data about customers, users or members of the public (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). We do not collect any information about criminal convictions and offences.
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 a user or customer, 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, including access to Platform functions restricted to specific customers). In this case, we may have to cancel a product or service you have with us (which may include denying access to the Platform).
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 Identity, Contact and Financial Data by filling in forms, uploading data and documents to the Platform, using contact forms, chat windows, or other helpdesk functionality, or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- purchase or arrange the purchase of products or services through or relating to the Platform;
- create, activate or login to an account on the Platform;
- initiate or accept the transfer of any equipment via the Platform or subscribe to any monitoring or alert services;
- request marketing or service updates to be sent to you;
- enter a competition, promotion or survey; or
- give us feedback, ask for service or technical assistance, or contact us for other reasons.
- Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We may collect this personal data by using cookies, server logs, tracking pixels and other similar technologies. Please see our cookie policy for further details.
- Third parties or publicly available sources. We may receive personal data about you from customers and other users of the Platform and from various third parties and public sources as set out below:
- Technical Data from the following parties:
website analytics providers;
advertising networks such as LinkedIn Corporation based outside the UK; and
search information providers such as Google, Inc. and its affiliates based inside or outside the UK. - Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
- Identity and Contact Data from publicly available sources, such as the Registrar of Companies.
- Data of all kinds about you relating to your use of the Platform and about any individual customer from third parties (i) providing support and live chat functionality for the Platform, (ii) hosting data used by the Platform, or (iii) providing payment and accounting functionality for the Platform.
- Our customers and their users, who may provide data about you as part of using the Platform, including when uploading documents and records or receiving or transferring an asset, product or piece of equipment on the Platform or providing links or other information to allow you to use or subscribe to the Platform.
- Technical Data from the following parties:
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 into or have entered into with our customer (or any contract with a user of the Platform).
- 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.
- On the basis of consent, where you specifically ask us to provide you with news and updates about the Platform and our services.
We may provide marketing and promotional communications to customers and their users. In other circumstances, we will get your prior, informed consent before sending any direct marketing communications to you via email or text message. Individuals (but not companies) have the right to withdraw consent to direct 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 categories of your personal data for more than one purpose and may rely on a different lawful basis for each purpose. Please contact us if you need details about the specific legal basis we are relying on to process your personal data where more than one ground has been set out in the table below.
Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
To register you as a new customer or as a registered user of the platform. | (a) Identity (b) Contact | (a) Performance of a contract with you, where you are an individual customer (including a non-commercial user of the platform, a sole trader or an individual member of a partnership) (b) Performance of a contract with you, where you are a registered user of a customer who accesses the Platform subject to our standard End-User Licence Agreement (c) Necessary for our legitimate interests and those of a customer, where you are an employee, contractor, agent, officer or director of a customer (where the customer has a separate legal identity under English law) or a registered user otherwise acting on behalf of a customer |
To process and deliver orders for our services and for products supplied on the platform, including to: (a) Manage payments, fees and charges (b) Arrange the delivery of goods (c) Collect and recover money owed to us | (a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications | (a) Performance of a contract with you (where you are a customer) (b) Necessary for our legitimate interests and those of our customers, where you are an employee, contractor, agent, officer or director of a customer (to carry out our contracts with our customers) |
To manage our relationship with our customers and their registered users, which will include: (a) Notifying you about changes to our terms or privacy notice (b) Asking you to leave a review or take a survey | (a) Identity (b) Contact (c) Profile (d) Marketing and Communications | (a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests and those of our customers (to keep our records updated and to study how customers use our products/services) |
To enable you to partake in a prize draw, competition or complete a survey | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications | (a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, identify trends and priorities in the industry, and to develop our products and services and grow our business) |
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | (a) Identity (b) Contact (c) Technical | (a) 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) (b) Necessary to comply with a legal obligation |
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical | Necessary for our legitimate interests (to study how customers and registered users 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 and to develop understanding of trends and patterns within the industry and within fire safety products | (a) Technical (b) Usage | 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, which may be goods and services provided by us, by affiliates and related companies, or by third parties | (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications | Necessary for our legitimate interests (to develop our products/services and grow our business) |
To transfer data to another legal entity in connection with a restructuring, reorganisation, sale, transfer, investment, financing transaction or similar transaction relating to our business or the company or companies which carry on that business | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical | (a) Necessary for our legitimate interests (for running our business, and in the context of a business sale, transfer, reorganisation or group restructuring exercise) (b) To carry out a contract with you as a customer (c) Necessary to comply with a legal obligation (where we are required to transfer data to a third party)
|
Marketing
You can use the user account management features on the Platform to control how we contact you and use your data. This will include marketing and advertising uses of your data, to the extent and for such time as we use your data for these purposes.
Promotional offers from us
At all times, we may use customer and registered user Identity, Contact, Technical, Usage and Profile Data to form a view on what we think our customers may want or need, or what may be of interest to them.
You will receive marketing communications from us (i) if you have requested information from us, (ii) if you are a customer who has purchased goods or services from us and you have not opted out of receiving that marketing, or (iii) if you are a registered user of a customer and have not opted out of receiving marketing.
Third-party marketing
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes. We do not currently share personal data for these purposes.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time by logging into the , by following the opt-out links on any marketing message sent to you or by contacting us 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 purpose and that purpose is not incompatible 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.
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
- Customers and registered users of the Platform, where your personal data is contained in records uploaded to or available via the Platform, or where you designate or are designated by a user of the platform in relation to assets recorded on the Platform.
- Sage Group plc and its affiliates
- LiveChat, Inc. for customer and user support.
- HubSpot, Inc. for customer management and support.
- Microsoft Corporation and its affiliates inside and outside of the UK for hosting and services related to the Platform.
- Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. 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 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 – they will process your personal data only for specified purposes and in accordance with our instructions.
6. International transfers
Many of our external third party service providers are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK. Where practicable, we designate the UK as the location for any processing by third party providers.
Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- Where practicable, ensuring that data is processed in a country that has been deemed by the Information Commissioner or UK government to provide an adequate level of protection for personal data.
- Using approved international data transfer agreements and other specific contracts approved for use in the UK which are intended to give personal data the same protection it has in the UK. For further details, see https://ico.org.uk/for-organisations/uk-gdpr-guidance-and-resources/international-transfers/international-data-transfer-agreement-and-guidance/.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
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, except in respect of personal data forming part of fire safety records, 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.
Personal data may be included in fire safety records and documents accessible via the Platform to customers and their registered users. Customers and registered users do not process these records and documents on our behalf – to the extent that they use and retain copies of personal data contained in such records and documents, they will do so as independent controllers of that personal data. If you have concerns about the use by a customer or other registered user of personal data about you in records and documents obtained from the Platform, you should contact the relevant customer directly. Further information about your rights in this respect can be obtained from the Information Commissioner’s Office at https://ico.org.uk.
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
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 and, where personal data forms part of fire safety records and documentation, for so long as such information is necessary for fire safety, compliance and related purposes.
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 or with a customer.
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 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 purposes).
In some circumstances you can ask us to delete your data: see your legal rights below for further information.
In some circumstances we will anonymise and/or aggregate your personal data (so that it can no longer be associated with you) for research or statistical purposes. Such data is no longer personal data and 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. Please click on the links below to find out more about these rights:
You may exercise these rights, in most situations, by using the account management tools on the Platform or (where we conduct electronic marketing) by opting out of any electronic marketing using the link or instructions contained in the marketing message. In most situations, the account management tools on the Platform will be the easiest and quickest way to manage our use of your data.
Should you wish to do so, you can also contact our Data Privacy Manager:
Email address: info@fire-dna.com
Postal address: Fire DNA Limited, Ashcombe Court, Woolsack Way, Godalming, Surrey, United Kingdom, GU7 1LQ
You will not usually have to pay a fee to access your personal data or to exercise any of your other rights. However, we are permitted by law to 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.
Time limit to respond
We try to respond to all legitimate requests as soon as reasonably practicable and in any event within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In such a case, we will notify you and keep you updated.
10. Cookie Policy
We use cookies for a variety of purposes, including to distinguish you from other users of the Platform. Certain cookies are necessary for the functioning of the Platform, others are intended to enhance the user experience, allow integration with other sites, or to provide data on how the Platform is used which helps us to improve it.
A “cookie” is a small file of letters and numbers that we store on your browser, computer or mobile device.
We may use the following types of cookies:
- Strictly necessary cookies. These are cookies that are required for the operation of the Platform. They include, for example, cookies that enable users to log into secure areas of the Platform and perform operations, purchase products, or upload or retrieve data which is restricted to a particular customer.
- Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around the Platform. This helps us to improve the way the Platform works, for example, by ensuring that users are finding what they are looking for easily.
- Functional cookies. These are used to recognise you when you return to the Platform. This enables us to personalise our content for customers and remember user preferences.
- Targeting cookies. These cookies record your visit to our websites, the pages you have visited and the links you have followed. We will use this information to improve the functionality of the Platform.
You can find more information about the individual cookies we use and the purposes for which we use them in the table below:
Cookie | Description |
---|---|
__cf_bm | This cookie, set by Cloudflare, is used to support Cloudflare Bot Management. |
__hssc | HubSpot sets this cookie to keep track of sessions and to determine if HubSpot should increment the session number and timestamps in the __hstc cookie. |
__hssrc | This cookie is set by Hubspot whenever it changes the session cookie. The __hssrc cookie set to 1 indicates that the user has restarted the browser, and if the cookie does not exist, it is assumed to be a new session. |
__hstc | This is the main cookie set by Hubspot, for tracking visitors. It contains the domain, initial timestamp (first visit), last timestamp (last visit), current timestamp (this visit), and session number (increments for each subsequent session). |
__lc_cid | This is an essential cookie for the website live chat box to function properly. |
__lc_cst | This cookie is used for the website live chat box to function properly. |
__oauth_redirect_detector | This cookie is used to recognize the visitors using live chat at different times inorder to optimize the chat-box functionality. |
_ga | The _ga cookie, installed by Google Analytics, calculates visitor, session and campaign data and also keeps track of site usage for the site's analytics report. The cookie stores information anonymously and assigns a randomly generated number to recognize unique visitors. |
_ga_2M88SK7S77 | This cookie is installed by Google Analytics. |
_gat_gtag_UA_194390511_1 | Set by Google to distinguish users. |
_gid | Installed by Google Analytics, _gid cookie stores information on how visitors use a website, while also creating an analytics report of the website's performance. Some of the data that are collected include the number of visitors, their source, and the pages they visit anonymously. |
cookielawinfo-checkbox-advertisement | Set by the GDPR Cookie Consent plugin, this cookie is used to record the user consent for the cookies in the "Advertisement" category . |
cookielawinfo-checkbox-analytics | This cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category "Analytics". |
cookielawinfo-checkbox-functional | The cookie is set by GDPR cookie consent to record the user consent for the cookies in the category "Functional". |
cookielawinfo-checkbox-necessary | This cookie is set by GDPR Cookie Consent plugin. The cookies is used to store the user consent for the cookies in the category "Necessary". |
cookielawinfo-checkbox-others | This cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category "Other. |
cookielawinfo-checkbox-performance | This cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category "Performance". |
CookieLawInfoConsent | Records the default button state of the corresponding category & the status of CCPA. It works only in coordination with the primary cookie. |
hubspotutk | HubSpot sets this cookie to keep track of the visitors to the website. This cookie is passed to HubSpot on form submission and used when deduplicating contacts. |
viewed_cookie_policy | The cookie is set by the GDPR Cookie Consent plugin and is used to store whether or not user has consented to the use of cookies. It does not store any personal data. |
vuid | Vimeo installs this cookie to collect tracking information by setting a unique ID to embed videos to the website. |
Please note that the following third parties may also use cookies, over which we have no control. These named third parties may include advertising networks and providers of external services like web traffic analysis services. These third party cookies are likely to be analytical cookies or performance cookies or targeting cookies:
- Hubspot
- Google Inc
- Vimeo
- Livechat
We allow users to manage cookies by popups upon navigating to our websites. You can choose which analytical, functionality and targeting cookies we can set by using the popup menu when you visit our site or login to the Platform.
Your browser settings may also permit you to limit or prevent the setting of cookies. If you block all cookies (including essential cookies) you may not be able to access the Platform.
11. Glossary
LAWFUL BASIS
Legitimate Interest means, in relation to Fire DNA Limited, our interest in conducting and promoting our business in a legal and profitable manner. When making decisions about the use of personal data, we are also permitted to consider the legitimate interests of other persons (for example, the interests of our other customers in accessing records or transferring or receiving assets on the Platform). We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests or those of any third party. We do not use your personal data for activities where the legitimate interests in favour of processing are overridden by the impact of that processing on you, unless we have your consent or are otherwise required or permitted to by law. You can obtain further information about how we assess legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. These could include contracts with our customers or any end-user licence agreement with a customer’s registered users.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
THIRD PARTIES
External Third Parties may include:
- Service providers acting as data processors, based in the United Kingdom and overseas, who provide hosting, helpdesk, CRM, IT and system administration services.
- Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom, 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.
YOUR LEGAL RIGHTS
You have the right to:
Request access to copies of information comprising your personal data (commonly known as a “data subject access request”). This enables you to review 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 valid legal reason for us 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. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. You also have a separate and unconditional legal right to object to the use of your personal data for direct marketing purposes.
Request restriction of processing of your personal data. This enables you to ask us to limit or 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 information processed in an automated way which you initially provided consent for us to use or where we used the information to perform a contract with you. Please be aware that personal data contained in records and documents accessible via the Platform will not be subject to automated processing in this way and therefore is not subject to this right.
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.