- Important information and who we are
- The data we collect about you
- How is your personal data collected?
- How is your customer data collected?
- How we use your personal data and customer data
- Disclosures of your personal data/a>
- International transfers
- Data security
- Data Retention
- Your legal rights
1. Important information and who we are
This website is not intended for children and we do not knowingly collect data relating to children through this website.
We may also process your customer data as a data processor during the course of the provision of our services to you.
Full name of legal entity: Trusted Interactions Group Limited
Email address: email@example.com
Postal address: Eagle House, Joule Road, Andover, SP10 3UX
Telephone number: 0333 800 2828
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 us in the first instance if at all possible.
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 data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. Your customer data may include personal data. Personal data does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you and your customers which we have grouped together as follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Contact Data includes billing address, delivery address, email address and telephone numbers.
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
- Technical Data includes 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 this website.
- Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our website and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
- Customer Data includes any other data that you have permitted us to collect about your customers as part of the provision of a service to you and for which you are the data controller.
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 offenses.
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 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 service you have with us but we will notify you if this is the case at the time.
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 your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- apply for our services;
- create an account on our website;
- subscribe to our service or publications;
- request marketing to be sent to you;
- enter a competition, promotion or survey; or,
- give us feedback or contact us.
- Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.
- Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
- Technical Data from the following parties:
(a) analytics providers such as Google based outside the EU; and
(b) search information providers based inside or outside the EU.
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
- Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.
4. How is your customer data collected?
Your customer data may be collected as a result of the provision of our services to you from time to time, which includes but may not be limited to:
- Telephone Interactions. We may collect information about a caller according to instructions from you (or based on our understanding of what information is required to effectively carry out the service), and such information may then be stored and sent to you by an agreed mode of communication.
- Managed livechat Interactions. We may collect information about a livechat visitor on your website according to instructions from you (or based on our understanding of what information is required to effectively carry out the service), and such information may then be stored and sent to you by an agreed mode of communication.
- Social Media Interactions. We may collect information about a social media interaction we have conducted on your behalf according to instructions from you (or based on our understanding of what information is required to effectively carry out the service), and such information may then be stored and sent to you by an agreed mode of communication.
- Email Interactions. We may collect information about an email interaction we have conducted on your behalf according to instructions from you (or based on our understanding of what information is required to effectively carry out the service), and such information may then be stored and sent to you by an agreed mode of communication.
- Administrative Service. We may collect and store information received by you pursuant to our service as an administrative assistant. This may be over any form of communication used between us and you.
We only use your customer data for the provision of our service to you. We absolutely do not use this data for our own marketing purposes to any customer or to contact your customers on our own behalf.
5. How we use your personal data and customer data
We will only use your personal data and customer data when the law allows us to. Most commonly, we will use your personal data and customer data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- 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.
Click here to find out more about the types of lawful basis that we will rely on to process your personal data.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third-party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data as a controller
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.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as a new customer|| (a) Identity |
|Performance of a contract with you|
|To process and deliver your order including: |
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
| (a) Identity |
(e) Marketing and Communications
| (a) Performance of a contract with you |
(b) Necessary for our legitimate interests (to recover debts due to us)
|To manage our relationship with you which will include: |
(b) Asking you to leave a review or take a survey
| (a) Identity |
(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 (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 |
(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, to develop them 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 |
| (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 |
(e) Marketing and Communications
|Necessary for our legitimate interests (to study how customers 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|| (a) Technical |
|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|| (a) Identity |
(f) Marketing and Communications
|Necessary for our legitimate interests (to develop our products/services and grow our business)|
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Promotional offers from us
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 call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us or third parties to stop sending you marketing messages by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, service experience or other transactions.
Change of purpose
We will only use your personal data or customer 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.
If we need to use your personal data or customer 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. Disclosures of your personal data or customer data
We may share your personal data with the parties set out below for the purposes set out above.
- Internal Third Parties as set out in the Glossary.
- External Third Parties as set out in the Glossary.
- We require all third parties to respect the security of your personal data and customer data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data or customer data for their own purposes and only permit them to process your personal data or customer data for specified purposes and in accordance with our instructions.
7. International transfers
Some of our external third parties are based outside the EEA so their processing of your personal data or customer data may involve a transfer of data outside the EEA.
Whenever we transfer your personal data or customer data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data or customer data to countries that have been deemed to provide an adequate level of protection for such data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data and your customer data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
- 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 Europe and the US. For further details, see European Commission: EU-US Privacy Shield.Please contact us if you want further information on the specific mechanism used by us when transferring your personal data and customer data out of the EEA.
8. Data security
We have put in place appropriate security measures to prevent your personal data and customer data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data and customer data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data and customer data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
9. Data retention
How long will you use my personal data and customer data for?
We will only retain your personal data and customer data for as long as reasonably necessary to fulfill 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 and customer 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 and customer data, we consider the amount, nature and sensitivity of the personal data and customer data, the potential risk of harm from unauthorised use or disclosure of your personal data and customer data, the purposes for which we process your personal data and customer data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
10. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data and customer data. Please click on the links below to find out more about these rights:
- Request access to your personal data and customer data.
- Request correction of your personal data and customer data.
- Request erasure of your personal data and customer data.
- Object to processing of your personal data and customer data.
- Request restriction of processing your personal data and customer data.
- Request transfer of your personal data and customer data.
- Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us.
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 could 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 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.
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. 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 and customer data for our legitimate interests. We do not use your personal data and customer data for activities where our interests are overridden by the impact 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 our 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.
Comply with a legal obligation means processing your personal data and customer data where it is necessary for compliance with a legal obligation that we are subject to.
Internal Third Parties
Other companies in the Cymphony Group acting as joint controllers or processors and who are based in the UK and provide services to Cymphony or on Cymphony’s behalf.
External Third Parties
- Service providers based in the UK who provide IT and system administration services.
- Professional advisers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities in the UK who require reporting of processing activities in certain circumstances.
YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal data and customer data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data and customer data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data and customer data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you or your customers corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data or customer data. This enables you to ask us to delete or remove personal data or customer 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 or customer 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 or customer 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 or customer 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 or those of your customers. You also have the right to object where we are processing your personal data or customer 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 or customer data. This enables you to ask us to suspend the processing of your personal data or customer 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 or customer data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data or customer 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 or customer 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.