Introduction
SecurEnvoy Limited (“SE”) is committed to safeguarding an individual’s personal and sensitive personal data and is bound to comply with the UK Data Protection Act 2018 (“DPA”) and EU General Data Protection Regulation (“GDPR”), along with similar and applicable laws in other countries around the world. This Privacy Notice forms part of SE’s obligation to be fair and transparent with all individuals whose personal and sensitive personal data it processes, whilst visiting the SE Website, and to provide details around how it processes such data.
Who we are?
SE provides access management and data protection services. Its registered company number is 04866711 and its registered address is 22 Great James Street, London, WC1N 3ES.
SE is part of The Shearwater Group plc (“SWG”), an Alternative Investment Market (“AIM”) listed company, whose UK registered company number is 05059457 and registered address is 22 Great James Street, London, WC1N 3ES.
What personal data do we process?
We may collect and process the following data about you:
- Information you give us about you by filling in forms on our Website or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you register to use our Website, buy products via our Website and when you report a problem with our Website. The information you give us may include your name, business address, business e-mail address and phone number.
- Information we may automatically collect about you with regard to each of your visits to our Website including technical information (e.g. the Internet protocol (IP) addresses, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform); and information about your visit (e.g. the full UR clickstream to, through and from our site; products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number).
- Information we receive from other sources about you if you use any of the other websites we operate or the other services we provide. We are also working closely with third parties (including, for example, business partners (resellers and distributors), sub-contractors in technical, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about your company from them.
Why do we process your personal data?
We use personal data that you give to us, for the following purposes:-
- to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
- to send you notifications about your order (if you place one);
- to provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about;
- to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you. If you are an existing customer, we will only contact you by electronic means with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you. If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you if you have consented to this. If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please let us know when we collect your data;
- to ensure that content from our Website is presented in the most effective manner for you and for your computer.
- By providing us with your e-mail address you consent to our using the e-mail address to provide you with e-mail alert services. If at any time you do not wish to be contacted by us by e-mail please use the link provided on any e-mail sent to you to unsubscribe. Alternatively, write to the Data Protection Officer (please see details below).
We use personal data that we collect about you, for the following purposes to administer and improve our Website and for internal operations:-
- as part of our efforts to keep our Website safe and secure;
- to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you; or
- to make suggestions and recommendations to you and other users of our Website about goods or services that may interest you or them.
If you cannot provide personal data
- In some instances, we need to collect your data in order to provide you with our whitepapers, or other thought leadership and insights. If you do not provide your data then we would be unable to provide you with such content.
We may combine information we receive from other sources with information you give to us and information we collect about you and use the combined information for the purposes set out above.
Who do we share your data with?
We only disclose your personal data in ways set out in this Privacy Notice or subject to any contractual agreements that are in place with us. The following circumstances may apply: –
- We may share your information with the Shearwater Group plc, company Number 05059457.
- We may share your information with trusted third parties who provide us with support services including:
- Business partners, and sub-contractors for the performance of any contract we enter into with them or you.
- Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers, but we may provide them with aggregate information about our users.
- Analytics and search engine providers that assist us in the improvement and optimisation of our site.
- Credit reference agencies for the purpose of assessing your business credit score where this is a condition of us entering into a contract with you.
- We may disclose your personal information to third parties in the following circumstances:
- In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
- If we are, or substantially all of our assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
- If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms or terms and conditions of supply and other agreements; or to protect the rights, property, or safety of SecurEnvoy Limited, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
We do not sell, rent or trade any of your personal data.
Data retention
We hold your personal data for as long as necessary in line with any legislative, regulatory or business need.
You have the right to request we erase your data, where we do not have any overriding legal, regulatory or contractual obligations.
How do we protect your data?
We aim to ensure that your personal data is secure. In order to prevent unauthorised access, loss, misuse or alteration, we have put in place appropriate physical, technical and organisational measures to safeguard and secure the personal data we collect. Our service providers are required to do the same. They will only process your personal data on our instructions and they are subject to a duty of confidentiality and oversight.
In addition, we limit access to your personal data on a least privilege, need to know basis. We also carry out regular security testing to ensure that your personal data is protected.
Any personal data sent to us, either in writing or email, may be insecure in transit and we cannot guarantee its delivery.
International data transfers
Personal data that we collect is only stored in countries, which have adequate security controls in place, notably the UK, Germany and the USA.
Your legal rights
You may instruct us to provide you with any personal data we hold about you as part of a Subject Access Request. The provision of such information will be subject to evidencing your identity.
In certain instances, where exemptions exist, we may withhold personal data that you request, and which are permissible by law.
You have the right to rectification and may wish to contact us if the personal data that we hold about you needs to be corrected or updated.
You have the right to object to us processing your data, and the right to request we restrict the processing of your data.
You may instruct us at any time not to process your personal data for marketing and communications purposes. Please contact marketing@securenvoy.com if you wish to opt out.
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 admin fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex. In such instances, we will notify you and keep you updated.
Links to other organisations on our website.
Our Website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy notices and that we do not accept any responsibility or liability for these policies. Please check these notices before you submit any personal data to these websites.
Updates to this policy
In order to remain compliant with any legal and regulatory obligations, or as part of our evolving business practices, we may update this Privacy Notice from time to time by publishing a new version. In certain instances, we may notify you.
Data Protection Registration
We are registered as a data controller with the UK Information Commissioner’s Office and our data protection registration number is: ZA229874.
How to contact us
You can contact us as follows: –
Making a complaint
If you feel your rights have not been respected, or do not feel a situation was resolved satisfactorily, you have the right to raise a complaint to the UK Information Commissioner.
You can contact them as follows: –
Web: https://ico.org.uk/make-a-complaint/
Telephone: +44 (0)303 123 1113
Contact: https://ico.org.uk/global/contact-us/
In writing:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
