1. Important Information and Who We Are
Purpose of this
privacy policy
This privacy policy aims to give you
information on how we collect and process your personal data through your use
of this website or when dealing with us as a client or supplier.
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
policy together with any other privacy policy 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 policy supplements other notices and privacy policies and is
not intended to override them.
Controller
Right Thing Right Now Tech Ltd (a limited
company incorporated in England and Wales with company number 14926075, whose
registered office is at Holborn Studios, 49/50 Eagle Wharf Road,
London, United Kingdom, N1 7ED) is the controller and responsible for your
personal data (referred to as "we", "us" or "our"
in this privacy policy). We have appointed a data protection officer (DPO)
who is responsible for overseeing questions in relation to this privacy policy.
If you have any questions about this privacy policy, including any requests to
exercise your legal rights, please
contact the DPO using the details set out below.
Contact
details
If you have any questions about this privacy
policy or our privacy practices, please contact our DPO by emailing dpo@rtrntech.com.
Right to make a compliant
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 please contact us in the first instance. We are registered with the ICO under
registration number ZB603092.
Changes
to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular
review. This version was last updated on 3 October 2023. 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.
Third-party
links
This website may include links to
third-party websites, plug-ins and applications. 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. When you leave our website, we encourage you to
read the privacy policy of every website you visit.
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. It 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 which we have grouped together as
follows:
Identity Data
includes first name, maiden name, last
name, username or similar identifier, job title, job location.
Contact Data
includes email address and telephone
numbers.
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.
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.
We also collect, use and share
Aggregated Data
such as statistical or
demographic data for any purpose. Aggregated Data could be derived from your
personal data but is not considered personal data in law as this data 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 policy.
We do not collect any Special Categories of Personal Data about you in our capacity as a
data controller (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.
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 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 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 Data and
Contact Data by filling in forms or by corresponding with us by post, phone,
email or otherwise. This includes personal data you provide when you:
contact
us, or are contacted by us, in your capacity as an employee or other
representative of a client or potential client for our services, or as a
supplier or potential supplier or goods or services to us
create
an account on our website;
subscribe
to our publications;
request
marketing to be sent to you
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, server logs and other
similar technologies. Please see our cookie policy for further details.
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
analytics providers such as Google based
outside the UK;
Identity
and Contact Data from publicly available sources such as Companies House and
the Electoral Register based inside the UK.
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 process 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;
Where
it is necessary for our legitimate interests (or those of a third party).
Legitimate interests
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 for our legitimate interests. We do not use your personal 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
;
or
Where
we need to comply with a legal obligation.
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
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 market our services to an existing or new client
(a) Identity
(b) Contact
(c) Marketing and Communications
Necessary for our legitimate interests (to further our business by
concluding contracts with clients)
To process and deliver an order placed by a client, or to manage our
relationship with a supplier
(a) Identity
(b) Contact
(c) Marketing and Communications
Necessary for our legitimate interests (to further our business by
fulfilling contracts with clients and suppliers)
To manage our relationship with you which will include notifying you
about changes to our website terms or privacy policy
(a) Identity
(b) Contact
(c) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
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 use data analytics to improve our website, products/services,
marketing, client relationships and experiences
(a) Technical
(b) Usage
Necessary for our legitimate interests (to define types of clients
and/or website visitors for our 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 services that may
be of interest to you
(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Marketing and Communications
Necessary for our legitimate interests (to develop our services and
grow our business)]
Promotional
offers from us
We may use your Identity, Contact, Technical
and Usage 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 services 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.
Third-party
marketing
We will get your express opt-in consent
before we share your personal data with any third party 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 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 service purchase, service experience or other transactions].
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.
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
We may share your personal data with the
parties set out below for the purposes set out in the table [Purposes for which we will use your personal
data] above.
Service providers based in the UK who provide IT
and system administration services.
Professional advisers including lawyers,
bankers, auditors and insurers 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.
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 policy.
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
We do not transfer your personal data
outside 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, 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 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.
By law we have to keep basic information
about our clients (including Contact, Identity, Financial and Transaction Data)
for six years after they cease being clients 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 your
personal data (so that it can no longer be associated with you) for research or
statistical purposes, in which case we may use this information indefinitely
without further notice to you.
9.
Your Legal Rights
Under certain circumstances, data protection laws give you the rights described
below in relation to your personal data.
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.
Right to 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.
Right to 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.
Right to 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.
Right to 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; or
you
have objected to our use of your data but we need to verify whether we have
overriding legitimate grounds to use it
Right to 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.
Right to 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 also have the right to ask us not to continue to process your
personal data for marketing purposes.
You can exercise any of these rights at any time by contacting us using
the contact details at the beginning of this notice.
10.
GENERAL
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.
RIGHT THING RIGHT NOW TECHNOLOGIES LTD
