Last Updated: 19 January 2021
1. IMPORTANT INFORMATION AND WHO WE ARE
DPO: Manuel Martinez Chamorro
Address: Privasee Group LTD, Entrepreneurship Institute, Room 1.01 (N), Bush House – North Wing, Strand Campus, 30 Aldwych, London WC2B 4BG
Telephone number: +44 (0) 7476391313
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) if you are unhappy with how we have used your data. The ICO’s address is:
Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF
We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
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.
2. THE TYPE OF DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We identify a user only by a serial id, and e-mail and a user name. We may also collect your first and last names to create your user account. You will not be identified if you are not a registered user.
If you choose to share your data with a third party and instruct us to do so, we may need to process some additional personal data in order to identify your content.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
Identity Data includes first name, last name, username or similar identifier.
Contact Data includes email address and telephone numbers.
Financial Data includes bank account and payment details for you or your organisation.
Technical Data includes 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 this website.
Profile Data includes your username and hashed password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
Usage Data includes information about how you use our website, products and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
Service Data includes data type, data storage, list of attributes of data and the legal basis for processing.
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.
Where we need to collect personal data by law, or under the terms of a contract we have with you, 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). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
3. HOW YOU PERSONAL DATA IS COLLECTED
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Contact and Financial Data and the contact details of your DPO by filling in forms or by corresponding with us by post, phone, email, via our website or otherwise. This includes personal data you provide when you:
apply for our products or services;
create an account with us;
subscribe to publications;
request marketing to be sent to you; or
give us feedback or contact us.
Automated technologies or interactions. As you interact with our website and services, we will automatically collect Technical, Profile and Usage Data about your equipment, browsing actions and patterns.
Visitor Recordings. Visitor Recordings is an additional feature to Visitor Analytics (described above) in the form of a simple website replay tool that records in statistics where our website visitors scrolled to and what they clicked on our website. We can see this information in playbacks and so-called “heatmaps”. Collecting these statistics helps us to make our website more user-friendly as well as to reproduce and fix technical errors. Basically, as a website operator using Visitor Recordings, we are using a snippet of tracking code to collect data about our visitors’ journey on our websites, which subpages they visit, what they clicked on, where they moved their mouse cursor to and where they scrolled. All this data is pseudonymized and Visitor Analytics will not use the collected data to identify individual users or to match it with additional information on an individual user.
Third parties or publicly available sources. We will receive personal data about you from various third parties as set out below.
analytics providers such as Hotjar based in the EU and Wix (based outside the EU).
file storage providers such as Google Drive based outside the EU.
customer service and relationship management solutions such as Hubspot (based outside the EU), Mailchimp (based outside EU) and Intercom (based outside EU).
website hosting and analytics providers such as Wix based outside the EU.
database as a service providers like mLab (based in EU) and MongoDB Atlas (based in EU).
online communication services like Google Meet (based outside EU), Zoom (based outside EU), Slack (based outside EU) and Whatsapp (based outside EU).
authentication and authorization providers like Auth0 (based in EU).
company management software like Trello (based outside EU) and GANTT Chart (based outside EU) and GSuite (based outside EU).
forms and other data collection services like Typeform based in the EU.
talent searching and recruitment services like AngelList based outside the EU.
professional services like accountants based in the UK and lawyers based in the UK.
Identity and Contact Data from publicly available sources such as Companies House based inside the EU.
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 you or your organisation.
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 or regulatory obligation.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. Whenever we process your personal data under the ‘legitimate interest’ lawful basis, we make sure that we take into account your rights and interests and balance any potential impact on you (both positive and negative) before we process your personal data for our legitimate interests. We will not process your personal information if we feel that there is an imbalance.
Generally, we do not rely on consent as a legal basis for processing 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 your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
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. We may send you marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving marketing. You can ask us to stop sending you marketing messages by contacting us at any time.
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 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.
5. DISCLOSURES OF YOUR PERSONAL DATA
We may share your personal data with the parties set out below:
Service providers acting as processors based in the United Kingdom who provide 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 acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
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 and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. INTERNATIONAL TRANSFERS
Some of our external third parties are based outside the UK and EEA so their processing of your personal data will involve a transfer of data outside the UK and EEA. Whenever we transfer your personal data out of the UK and EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
the country to which personal data is being transferred has been deemed to provide an adequate level of protection for personal data by the European Commission; or
we use specific contracts approved by the European Commission which give personal data the same protection it has in the UK and Europe.
7. DATA SECURITY
We store all your personal data on secure servers using standard symmetric encryption.
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 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.
Where you have chosen a password that enables you to access certain parts of our WebApp, you are responsible for keeping this password confidential. We ask you not to share the password with anyone.
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. 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.
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.
9. YOUR LEGAL RIGHTS
You have the right to:
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 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 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 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. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to 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 automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
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.
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 could 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 could 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.
10. THIRD-PARTY LINKS
If you have any questions, we are happy to answer!