SigMacity respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit the SigMacity General Site (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you. It also sets out some information about your rights and how you can complain, either to us or to the Information Commissioner’s Office.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice 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 notice supplements the other notices and is not intended to override them.
We will comply with Data Protection Legislation. “Data Protection Legislation” means for the United Kingdom, the Data Protection Act 1998 (or, where applicable if the our services are provided by us from outside of the United Kingdom, other transpositions of Directive 95/46/EC into domestic legislation of Member States of the European Economic Area) as amended, replaced or superseded from time to time, including without limitation by the EU General Data Protection Regulation 2016/679 of the European Parliament and of the Council when that comes into full legal force and effect (the “GDPR”) and in respect of the United Kingdom, any data protection laws substantially amending, replacing or superseding the GDPR following any exit by the United Kingdom from the European Union or the European Economic Area (as applicable).
A. DATA PROTECTION AND PRIVACY
SigMacity is a data controller for the purposes of any personal data that you provide to us on or ancillary to, the SigMacity General Site. SigMacity will hold and process that personal data in accordance with Data Protection Legislation. Where you are using the SigMacity General Site under a Customer Contract, SigMacity may also be a data processor on behalf of the Customer, who is the Data Controller. In such circumstances SigMacity will have agreed terms with the Customer as to how it complies with Data Protection Legislation with personal data, arising as from its data processing under that Customer Contract. Details of that can be found by you contacting the Customer.
SigMacity stores all personal data on servers located in the UK, but you hereby agree that SigMacity may export that personal data to within the European Economic Area or outside of the European Economic Area, if it does so in accordance with Data Protection Legislation and your consent to SigMacity exporting both within and outside of the European Economic Area, is hereby expressly given by you.
B. YOUR RIGHTS
Under certain circumstances, you have rights under the Data Protection Legislation in relation to your personal data. You have a right to access your Personal Information to check that the information we hold about you is accurate and that it is being processed lawfully, and to request that it is corrected if you think it is inaccurate (see below).
You have the following rights:
(i) to ask us to restrict the processing of your data (meaning that we could store it but not use it);
(ii) to object to how we use your data; and
(iii) to request that we delete your data.
Our response will depend on the circumstances and our legal obligations including under Data Protection Legislation.
You also have the right to ask us to “port” (transfer in an electronic format) personal data to another service provider, if it is stored electronically, we received it from you and if we are processing it on the grounds of your consent.
At any time you have the right to require us to stop using your Personal Information for marketing purposes.
You have the right to object to receiving direct marketing communications. If you decide that you do not want to receive direct marketing communications, you can inform us at the time of registration or you can change your marketing preferences at any time by contacting us by email, telephone or writing using our contact details below.
For more information about your rights please see: https://ico.org.uk/for-the-public/is-my-information-being-handled-correctly/
Subject Access Requests
You are entitled to apply for a copy of the information we hold about you (for which we may charge a small administration fee). This is called a data subject access request.
Erasure/Right to be Forgotten
In certain circumstances having provided that personal data, you may 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 Data Protection Legislation. 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.
Processing Objections
You may also 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.
Withdrawing Consent
If you no longer wish that SigMacity contact you, then you can contact SigMacity at the address below, to withdraw your consent to our processing of your personal data and such withdrawal will be made as soon as possible following SigMacity being told by you. These rights may be subject to a Customer Contract which you acknowledge by your use of the SigMacity General Site. SigMacity reserves the right to validate such a request before implementing it. Such a request 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.
If your contact with SigMacity is made under a Customer Contract or as an Authorised User appointed from the operation of that Customer Contract, your contact with SigMacity arises as a result of the use by the SigMacity Customer of the SigMacity Services which are provided as from the SigMacity General Site. In order to stop contact under those arrangements, you must also contact the relevant SigMacity Customer organisation. If you have any questions about this, please contact us at the address below.
Correcting Inaccurate information
You also have the right to have any inaccurate information about you corrected. We want to make sure that your information is accurate and up to date. You may ask us to correct or remove any information that you think is no longer up to date. Please contact us using the contact details below if you would like any corrections made to your information.
Transfer Requests
You may 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.
We may require further information from you in order to verify your identity before disclosing any personal information to you under a data subject access request, any withdrawal of consent, any objection to processing, any request to restrict processing and any request to transfer your personal data. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.
C. CONTACT DETAILS
Our full contact details are:
SigMacity Limited
Attention: Steve Warbrick
Email address: steve.warbrick@sigmacity.com
Postal address: Gemini House, 136-140 Old Shoreham Road, Brighton BN3 7BD
Telephone: 01273 741777
All email messages sent to and from SigMacity may be monitored to ensure compliance with our internal policies and to protect our business.
D. INFORMATION WE MAY COLLECT FROM YOU
For the purposes of these Terms, and the Data Protection Legislation, personal data, or personal information does not include data where the identity has been removed (anonymous data).
SigMacity may collect and process personal data about you which includes information you provide when you register to use the SigMacity General Site including any associated services or information or materials or feedback or otherwise arising as from your visit, access or use of our SigMacity General Site and/or the provision of Other Services to you.
The information you give us may include your name, address, e-mail address and telephone number(s), where you work or for whom you are enquiring or using the SigMacity General Site, your work role and job title and other information you chose to input to the SigMacity General Site, which for the purposes of Data Protection Legislation may be regarded as personal data and you hereby expressly authorise us to process that personal data in accordance with these Terms.
We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but is not considered personal data in law as this data does 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 notice.
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 offences.
With regard to each of your visits to the SigMacity General Site we may also automatically collect technical information, including the Internet Protocol (IP) address used to connect your computer to the Internet, 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, including the full URL clickstream to, through and from our SigMacity General Site (including date and time); services 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 or other means used to call or otherwise contact our customer service.
Where you have provided personal data by completing registration and application forms on the SigMacity General Site, 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.
Where we need to collect personal data by law, or you fail to provide data when requested, we may not be able to provide you with goods or 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.
E. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
1. Direct interactions. You may give us your identity 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:
1. apply for our products or services;
2. create an account on the SigMacity General Site;
3. subscribe to our service or publications;
4. request marketing to be sent to you;
5. enter a competition, promotion or survey; or
6. give us some feedback.
2. Automated technologies or interactions. As you interact with the SigMacity General Site, we may 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. We may also receive technical data about you if you visit other websites employing our cookies. Please see information on how we use cookies below for further details.
3. Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
1. Technical data from the following parties:
1. analytics providers such as Google based outside the EU;
2. advertising networks based inside or outside the EU; and
3. search information providers such as Thomson Reuters based inside or outside the EU.
2. Contact, financial and transaction data from providers of technical, services such as Dealogic based inside or outside the EU.
3. Customers.
4. Identity and contact data from publicly available sources such as company/firm web sites, Companies House and the Electoral Register based inside the EU.
F. HOW WE USE YOUR PERSONAL DATA AND WHO WE SHARE IT WITH
We will only use your personal data when the Data Protection Legislation allows us to. Most commonly, we will use your personal data 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 and where we need to comply with a legal or regulatory obligation.
In particular, we may use your personal information to:
1. conduct administrative or operational processes within our business;
2. process and respond to requests, enquiries or complaints received by you;
3. to provide products and services requested by you;
4. to identify products and services you may be interested in;
5. to communicate with you about our products and services;
6. to invite you to events;
7. to monitor and analyse our business;
8. to form a view of you as an individual and to identify, develop or improve our services and/or products that may be of interest to you and to carry out market research;
9. to send you marketing information.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to 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.
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.
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.
We may have to share your personal data with:
(i) service providers acting as processors based in the EEA or outside of the EEA who provide IT and system administration services, such as, for example, helpdesk services, where it is necessary for our legitimate interests; and
(ii) our employees; and
(iii) insurers, brokers; and
(iv) credit or checking agencies; and
(v) our other service providers; and
(vi) organisations such as the Financial Conduct Authority and other regulatory authorities where we are required to do so by law; and
(vii) prospective buyers in the event We wish to sell all or part of Our business; and
(viii) other companies within our group of companies, for the purposes of (a) developing our services and enhancing them; (b) reporting, management control, audit and accounting purposes and (c) for corporate governance purposes.
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 Data Protection Legislation.
*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 and in accordance with Data Protection Legislation. 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 Data Protection Legislation). 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.
G. USE OF YOUR DATA FOR MARKETING PURPOSES
We may ask whether you wish to receive marketing from us and this will be presented to you as an option on the relevant application form or page on the SigMacity General Site where necessary. We will not send you marketing if you ask us not to. If you have agreed to receive marketing but then later change your mind and no longer wish to receive marketing, please let us know so we can remove you from our distribution lists. You can contact us via our contact details noted in section C.
H. HOW LONG WILL WE USE YOUR PERSONAL DATA FOR?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. 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 requirements. Typically we retain personal data for anywhere between 3 months and seven years. If you would like more details of our personal data retention policy, please contact us at the address given in this policy.
I. THIRD-PARTY LINKS
The SigMacity General Site 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 notice of every website you visit.
J. YOUR ACCOUNT AND PASSWORD
If you are asked to register on the SigMacity General Site and choose to do so, then you confirm that you have the full authority to do so and that all information that you give is true, accurate, current and complete in all respects and, for so long as you are a Visitor to the SigMacity General Site, you shall maintain and promptly update such information to keep it true, accurate, current and complete.
If you are provided with a user identification code, password or any other piece of information as part of SigMacity’s security procedures, you must treat such information as confidential. You must not disclose it to any third party and it is for your personal use only. SigMacity will not be liable for any loss that you may incur, or may create, as a result of someone else’s use of your password or account, either with or without your knowledge or assent. You may not use any other user’s account at any time or for any reason.
You are solely responsible for the content of any data and information which you share with the SigMacity General Site and for the purposes of all Data Protection Legislation, you hereby give your express consent to SigMacity being able to use such data for the purposes intended by the SigMacity General Site, including but not limited to contacting you for the purpose of advising you about the SigMacity Services and the progress of SigMacity and if agreed with us, the provision of Other Services to you.
SigMacity has the right to disable any user identification code or password, whether chosen by you or allocated by SigMacity, at any time, if in our reasonable opinion you have failed to comply with any of the provisions of these Terms or otherwise.
K. FURTHER COMMUNICATIONS FROM SIGMACITY
The SigMacity General Site may result in certain communications from SigMacity being made to a Visitor and Authorised User, such as service announcements, administrative messages, newsletters and other offers or marketing activity. You understand that these communications shall be considered part of using the SigMacity General Site. As part of our policy to provide you total privacy, we also provide you the option of opting out from receiving these communications from us as described above.
L. DATA OWNERSHIP
All data supplied by SigMacity on the SigMacity General Site is owned by and/or licensed to SigMacity. Any data that you input onto the SigMacity General Site is provided by you and may be used by SigMacity on a perpetual royalty-free licence basis for use anywhere in the world and upon any medium. None of the foregoing shall grant rights to personal data to SigMacity, where such rights would be in breach of Data Protection Legislation.
M. VISITOR GENERATED CONTENT
You shall be solely responsible for any content that you display on the SigMacity General Site and the consequences of its transmission or publication. Any content made public will be publicly accessible through the internet and may be crawled and indexed by search engines. You are responsible for ensuring that you do not accidentally make any private and/or confidential content publicly available, including personal data. You agree not to use, copy, reproduce, distribute, transmit, broadcast, display, sell, license or otherwise exploit any third party owned content without the applicable licence rights and permissions to do so and you shall indemnify SigMacity in full in the event that in any of your use of the SigMacity General Site, you infringe the rights of others, including under Data Protection Legislation or other privacy rights. SigMacity will have the right to block access to or remove such content made available by you, with or without reason.
N. DATA SECURITY
SigMacity will maintain commercially reasonable administrative, physical and technical safeguards to protect the security, confidentiality and integrity of any personal data (in accordance with Data Protection Legislation) and for all other information that you provide to SigMacity which has not been published by you on the SigMacity General Site and is not otherwise in the public domain and which any reasonable person would regard as confidential information of yours. 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.
Information sent through the internet is subject to the security standards on the internet generally but we shall use all reasonable endeavours to ensure that, for SigMacity systems, reasonable security measures have been implemented. Although we will do our best to protect your personal data, we cannot guarantee the security of your personal data when being transmitted to our site: any transmission from you to us is at your own risk. Once we have received your personal data, we will use strict procedures and security features in accordance with Data Protection Legislation, to try to prevent unauthorised access.
If SigMacity becomes aware of any security breach in respect of your personal data, SigMacity will comply with its obligations under Data Protection Legislation. SigMacity records and documents its processes for the collection and storage of personal data in compliance with Data Protection Legislation. We will notify you and any applicable regulator of a breach where we are legally required to do so.
O. COOKIES
Our SigMacity General Site may use cookies to distinguish you from other users of the SigMacity General Site. This helps us to provide you with a good experience when you use the SigMacity General Site and also allows us to improve the SigMacity General Site.
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.
We may choose to use the following cookies:
Strictly necessary cookies.
These are cookies that are required for the operation of our SigMacity General Site. They include, for example, cookies that enable you to log into secure areas of the SigMacity General Site.
Analytical/performance cookies.
They allow us to recognise and count the number of visitors and to see how visitors move around the SigMacity General Site when they are using it. This helps us to improve the way the SigMacity General Site works, for example, by ensuring that users are finding what they are looking for easily.
Functionality cookies.
These are used to recognise you when you return to the SigMacity General Site. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
Targeting cookies.
These cookies record your visit to the SigMacity General Site, the pages you have visited and the links you have followed. We will use this information to make the SigMacity General Site more relevant to you, if applicable. We may also share this information with third parties for this purpose.
You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.
SigMacity Limited 2018