Definitions and interpretation
|Data||collectively all information that you submit to Secrutiny Limited via the Website. This definition incorporates, where applicable, the definitions provided in the Data Protection Laws.|
|Data Protection Laws||any applicable law relating to the processing of Personal Data, including but not limited to the Directive 96/46/EC (Data Protection Directive) or the GDPR, and any national implementing laws, regulations and secondary legislation, for as long as the GDPR is effective in the UK.|
|GDPR||the General Data Protection Regulation (EU) 2016/679.|
|Secrutiny Limited, we or us||Secrutiny Limited, a company incorporated in England and Wales with registered number 9530575 whose registered office is at Suite 11, Penhurst House, 352-356 Battersea Park Road, London SW11 3BY.|
|any third party that accesses the Website and is not either (i) employed by Secrutiny Limited or acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to Secrutiny Limited and accessing the Website in connection with the provision of such services.|
|Website||the website that you are currently using, https://secrutiny.com, and any sub-domains of this site unless expressly excluded by their own terms and conditions.|
a. the singular includes the plural and vice versa;
c. a reference to a person includes firms, companies, government entities, trusts and partnerships;
d. “including” is understood to mean “including without limitation”;
e. reference to any statutory provision includes any modification or amendment of it;
4. For purposes of the applicable Data
5. We may collect the following Data, which includes from you:
c. job title;
d. contact information such as email addresses and telephone numbers;
in each case, in accordance with this policy.
How we collect Data
5. We collect data in the following ways:
a. data given to us by you;
b. data collected automatically.
Data that is given to us by you
7. Secrutiny Limited will collect your Data in a number of ways, for example:
a. when you contact us through the Website, by telephone, post, email or through any other means;
b. when you complete surveys that we use for research purposes (although you are not obliged to respond to them);
c. when you enter a competition through a social media channel;
d. when you elect to receive marketing communications from us;
f. when you use our services;
Data that is collected automatically
8. To the extent that you access the Website, we will collect your Data automatically, for example:
a. we automatically collect some information about your visit to the Website. This information helps us to make improvements to Website content and navigation and includes your IP address, the date, times and frequency with which you access the Website and the way you use and interact with its content.
Our use of your Data
9. Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Website. Specifically, Data may be used by us for the following reasons:
a. internal record keeping;
b. For direct marketing communications and related profiling to help us to offer you relevant products and services, including deciding whether or not to offer you certain products and service. We will send marketing to you by email, phone, post and social media.
10. We may use your Data for the above purposes if we deem it necessary to do so for our legitimate interests. If you are not satisfied with this, you have the right to object in certain circumstances (see the section headed “Your rights” below).
11. For the delivery of direct marketing to you via email and/or telephone, we’ll need your consent, whether via an opt-in or soft-opt-in:
a. soft-opt-in consent is a specific type of consent which applies when you have previously engaged with us (for example, you contact us to ask us for more details about a particular product/service, and we are marketing similar products/services). Under soft-opt-in consent, we will take your consent as given unless you opt-out.
b. for other types of e-marketing, we are required to obtain your explicit consent; that is, you need to take positive and affirmative action when consenting by, for example, checking a box that we’ll provide.
c. if you are not satisfied with our approach to marketing, you have the right to withdraw consent at any time. To find out how to withdraw your consent, see the section headed “Your rights” below.
Who we share Data with
12. We may share your Data with the following groups of people for the following reasons:
a. our employees, agents and/or professional advisors – to respond to enquiries and provide relevant updates and marketing.
Keeping Data secure
13. We will use technical and organisational measures to safeguard your Data, for example:
a. we store your Data on secure servers.
b. access to Data is protected by security measures, for example, two-factor authentication and encryption.
14. Technical and organisational measures include measures to deal with any suspected data breach. If you suspect any misuse or loss or unauthorised access to your Data, please let us know immediately by contacting us via this email address: [email protected].
16. Even if we delete your Data, it may persist on backup or archival media for legal, tax or regulatory purposes.
17. You have the following rights in relation to your Data:
|a. Right to access||the right to request (i) copies of the information we hold about you at any time, (ii) that we modify, update or delete such information. If we provide you with access to the information we hold about you, we will not charge you for this, unless your request is “manifestly unfounded or excessive”. Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.|
|b. Right to correct||the right to have your Data rectified if it is inaccurate or incomplete.|
|c. Right to erase||the right to request that we delete or remove your Data from our systems.|
|d. Right to restrict our use of your Data||the right to “block” us from using your Data or limit the way in which we can use it.|
|e. Right to data portability||the right to request that we move, copy or transfer your Data.|
|f. Right to object||the right to object to our use of your Data including where we use it for our legitimate interests.|
18. To make enquiries, exercise your rights set out above, or withdraw your consent to the processing of your Data (where consent is our legal basis for processing your Data), please contact us via this email address: [email protected].
19. If you are not satisfied with the way a complaint you make in relation to your Data is handled by us, you may be able to refer your complaint to the relevant data protection authority. For the UK, this is the Information Commissioner’s Office (ICO). The ICO’s contact details can be found on their website at https://ico.org.uk/.
20. It is important that the Data that we hold about you is accurate and current. Please keep us informed if your Data changes during the period for which we hold it.
Links to other websites
Changes of business ownership and control
23. We may also disclose our Data to a prospective purchaser of our business or any part of it.
24. In the above instances, we will take steps with the aim of ensuring your privacy is protected.
27. Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.
28. This Agreement will be governed by and interpreted according to the law of England and Wales. All disputes arising under the Agreement will be subject to the exclusive jurisdiction of the English and Welsh courts.
You may contact Secrutiny Limited by email at [email protected]