- Information About Us
Our Site is owned and operated by Symilarity Ltd, a limited company registered in England under company number 10545402, whose registered address is 71-75 Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ.
- What Does This Policy Cover?
- What Is Personal Data?
Personal data is defined by the UK GDPR and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
- What Are My Rights?
Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:
b) The right to access the personal data we hold about you. Part 9 will tell you how to do this.
c) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 10 to find out more.
d) The right to be forgotten, i.e., the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 10 to find out more.
e) The right to restrict (i.e., prevent) the processing of your personal data.
f) The right to object to us using your personal data for a particular purpose or purposes.
g) The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
h) The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
i) Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 10.
It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves however, so please contact us first, using the details in Part 10.
- What Personal Data Do You Collect and How?
Personal data that you provide by filling in forms on Our Site and/or by contacting us through email or any additional information that we may request, and you provide to us. We may also ask you for information when you report a problem with Our Site. If you contact us, we may keep a record of that correspondence. This might include:
• business and/or residential address;
• email address;
• telephone number;
• profession, occupation or job title;
• information about your interactions with us;
• information about the products and services you have purchased from us or which you have enquired about, together with any additional information necessary to deliver those products and services or to respond to your enquiries;
• information relating to you that you provide to us directly through our network or indirectly through use of our network or online presence through our representatives or otherwise;
• information you provide to us through our service centre, customer surveys or calls by our representatives from time to time; and/or
• other personal information we may require from time to time to manage your business relationship with us.
Our Site may collect certain information automatically, including your IP address, the type of browser you are using, and certain other non-personal data about your computer or device such as your operating system type or version, and display resolution. We do not place cookies on your computer or device.
The lawful basis under the Data Protection Legislation that allows us to use such information is article 6(1)(f) of the UK GDPR which allows us to process personal data when it is necessary for the purposes of our legitimate interests, in this case, the proper operation and functionality of Our Site.
- How Do You Use My Personal Data?
Where we collect any personal data, it will be processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with our obligations and safeguard your rights under the Data Protection Legislation at all times. For more details on security see Part 7, below.
We collect, hold, use and disclose your personal information for the following purposes:
• to provide products and services to you and deliver the best possible quality of customer experience (such as by gaining an understanding of your needs);
• to provide you with news, information or advice about our existing and new products and services, including for marketing;
• to communicate with you, including but not limited to, by email, mail, SMS or telephone;
• to manage and enhance our products and services (such as for research and development);
• to provide as part of statistics or insights to third parties or to use internally in our business;
• to conduct business processing functions for operation of our Website, or our business;
• to manage our sales or other business relationships with you;
• for our administrative, promotional, planning, product/service development, quality control and research purposes;
• to investigate any complaints about or made by you, or if we have reason to suspect that you are in breach of any of our terms and conditions or that you are or have been otherwise engaged in any unlawful activity; and/or
• as otherwise required or permitted by any law.
For the purposes of the Data Protection Legislation, We are the data controller responsible for such personal data.
The other technical data referred to above is necessary for the technical operation of Our Site and will not normally be used in any way to personally identify you.
- How and Where Do You Store My Data?
Symilarity operates in the UK and Australia. We store some or all of your personal data in countries outside of the UK. These are known as “third countries”. We will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation as follows:
We will only store or transfer personal data in or to countries that are deemed to provide an adequate level of protection for personal data. For further information about adequacy decisions and adequacy regulations, please refer to the Information Commissioner’s Office.]
Please contact us using the details below in Part 10 for further information about the particular data protection safeguards used by us when transferring your personal data to a third country.
Personal data security is essential to us, and to protect personal data, we take the following measures:
• limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;
• procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so.
- Do You Share My Personal Data?
We may disclose your personal data to third parties if we are under a duty to disclose or share your personal data in order to comply with any legal obligation.
We also share anonymised information about your use of our Site with our analytics partner who may combine it with other information that you have provided to them or that they have collected from your use of other services.
If any personal data is transferred outside of the UK, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation, as explained above in Part 7.
- How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 10.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
- How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details
Email address: firstname.lastname@example.org.
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.