Privacy - Datasense

GDPR Privacy Policy

1. Introduction

We protect your personal data in line with the requirements of the General Data Protection Regulation (GDPR). The GDPR requires data controllers such as ourselves to document our lawful basis for processing personal data. It also gives you rights over how your data is processed. This privacy policy documents the data we collect, why and how we process it, and how to exercise your rights.

2. Data controller

The data controller responsible for this website is Datasense Consulting Ltd, registered in England 12086506. Our Data Protection Officer is Gayle Parker, who can be contacted at 1 Purser Road, Northampton, NN1 4PG.

ICO Registration No. A8446890

This website contains links to third-party websites, which have their own data controllers and privacy policies.

3. What Is Personal Data?

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “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.

4. What Are My Rights?

Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:

a) The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 14.

b) The right to access the personal data we hold about you. Part 10 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 14 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 14 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.

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 https://ico.org.uk/make-a-complaint/, we would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first.

5. What Personal Data Do You Collect and How?

We may collect and hold some or all of the personal data set out in the table below, using the methods also set out in the table. We do not collect any ‘special category’ or ‘sensitive’ personal data, or personal data relating to children, or data relating to criminal convictions and/or offences.

Data Collected	How we Collect the Data
Identity Information including name, title.	Direct from the source or via a form on our website.
Contact information including address, telephone number, email address.	Direct from the source or via a form on our website.
Business information including Business name, Job Title and Profession.	Direct from the source or via a form on our website.
Comments on this website	Direct from the source or via a form on our website.

6. How Do You Use My Personal Data?

Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes how we may use your personal data, and our lawful bases for doing so:

What We Do	What Data We Use	Our Lawful Basis
Supplying our services to you.	Identity Information including name, title. Contact information including address, telephone number, email address. Business information including Business name, Job Title and Profession.	Contract
Communicating with you.	Identity Information including name, title. Contact information including address, telephone number, email address. Business information including Business name, Job Title and Profession.	Consent. Legitimate Interest (where you have given us a business card and asked for further information), details of our Legitimate Interest Assessment are available on request.
Comments on the website	Identity Information including name, title.	When you submit a comment through a ‘Leave a comment’ form on our site we collect your name, e-mail address, and comment. We may choose to publish your name and comment on our site. Comments are submitted to the Akismet anti-spam service in order to detect and block spam. For more information on how Automattic (the operator of Akismet) handles the data it collects, see Automattic’s privacy policy.

With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email or telephone, or post with information, news, and offers on our services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.

We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us.

If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.

In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.

7. How Long Will You Keep My Personal Data?

We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):

Type Of Data – Contract	How Long We Keep It
Identity Information including name, title.	2 years post contract.
Contact information including address, telephone number, email address.	2 years post contract.
Business information including Business name, Job Title and Profession.	2 years post contract.

Type Of Data – Leads (Business Cards, Networking Events)	How Long We Keep It
Identity Information including name, title.	1 year
Contact information including address, telephone number, email address.	1 year
Business information including Business name, Job Title and Profession.	1 year

8. How and Where Do You Store or Transfer My Personal Data?

We may store or transfer some or all of your personal data in countries that are not part of the European Economic Area (the “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein). These are known as “third countries” and may not have data protection laws that are as strong as those in the UK and/or the EEA. This means that 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 share your data with external third parties, as detailed below in Part 9, that are based outside of the EEA. The following safeguards are applied to such transfers:

We will only transfer your personal data to third countries whose levels of data protection are deemed ‘adequate’ by the European Commission. More information is available from the European Commission.

Where we transfer your data to a third party based in the US, the data may be protected if they are part of the EU-US Privacy Shield. This requires that third party to provide data protection to standards similar levels of data protection to those in Europe. More information is available from the European Commission.

Please contact us using the details below in Part 11 for further information about the particular data protection mechanism[s] used by us when transferring your personal data to a third country.

The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:

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.

9. Do You Share My Personal Data?

We will not share any of your personal data with any third parties for any purposes, subject to the following exception[s]:

If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Policy.

In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

Recipient	Activity Carried Out	Location
Harvest	We use this to help us with project management, view their privacy policy.	USA – DPA
WordPress	Our site is hosted by WordPress see their privacy policy here.	USA -DPA
Xero	We use Xero for issuing quotes and invoices, please see their privacy policy here.	Australia – DPA
Hubspot CRM	Your details maybe stored in our Customer Relationship Management software hosted by Hubspot, we use this to provide you with a better service and for sending out email newsletters. See Hubspots privacy policy.	USA – DPA

If any of your personal data is shared with a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law.

10. 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. 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 within 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.

11. Security

The GDPR requires us to implement appropriate technical measures to protect data. We verify the identity of any individual who requests access to data before granting access. We use Transport Layer Security (TLS, also known as SSL) to encrypt any data you supply to us through our website. Additional technical measures are described at the relevant points in this privacy policy.

12. Changes to this privacy policy

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.

This Privacy Notice was last updated on 22nd August 2019.

13. Cookies

Cookies are small pieces of text that are stored by your browser. Each cookie has a name and is associated with a particular site. When your browser sends a request to a site (for example, to download a page, image, or video), the computer that responds (known as a server) may tell your browser to set one or more cookies. When your browser makes further requests to the same site it sends the cookies back to the server. This allows the server to remember you as you browse the site, and provide features such as shopping baskets or password-protected areas. For more information on the cookies we use, see our cookie policy.

14. 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 (for the attention of Gayle Parker):

• Email address: info@datasense.ltd.

• Telephone number: 01604 372355.

• Postal Address: 1 Purser Road, Northampton, NN1 4PG.

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