1.             Introduction

1.1          We are committed to safeguarding the privacy of our website visitors, service users, individual customers and customer personnel.

1.2          This policy applies where we are acting as a data controller with respect to the personal data of such persons; in other words, where we determine the purposes and means of the processing of that personal data.

1.3          We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website and services, we will ask you to consent to our use of cookies when you first visit our website.

1.4          In this policy, "we", "us" and "our" refer to Techfinity Ltd. For more information about us, see Section 17.

2.             The personal data that we collect

2.1          In this Section 2 we have set out the general categories of personal data that we process and, in the case of personal data that we did not obtain directly from you, information about the source and specific categories of that data.

2.2          We may process data enabling us to get in touch with you ("contact data"). The contact data may include your name, email address, telephone number, and postal address. The source of the contact data is you and/or your employer. If you log into our website using a social media account, we will obtain elements of the contact data from the relevant social media account provider.

2.3          We may process information relating to our customer relationships (" customer relationship data "). The customer relationship data may include your name, the name of your business or employer, your job title or role, your contact details, your classification / categorisation within our customer relationship management system and information contained in or relating to communications between us and you, or between us and your employer. The source of the customer relationship data is you and/or your employer.

2.4          We may process your personal data that are provided in the course of the use of our services and generated by our services in the course of such use (" service data "). The service data may include: name, phone number, address, email address, services account identifier, account creation and modification dates, last activity date, account settings, marketing preferences, profile image, job title, role title, department name, team name, employer, GPS coordinates and address of then-current location. The source of the service data is you and/or your employer and/or our services.

2.5          We may process information relating to transactions, including purchases of goods and/or services, that you enter into with us and/or through our website (" transaction data "). The transaction data may include your name, your contact details, your payment card details (or other payment details) and the transaction details. The source of the transaction data is you and/or our payment services provider.

2.6          We may process information contained in or relating to any communication that you send to us or that we send to you ("communication data"). The communication data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms.

2.7          We may process data about your use of our website and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system.

2.8          Please do not supply any other person's personal data to us, unless we prompt you to do so.

3.             Purposes of processing and legal bases

3.1          In this Section 3 , we have set out the purposes for which we may process personal data and the legal bases of the processing.

3.2          Operations - We may process your personal data for the purposes of operating our website and mobile applications, the processing and fulfilment of orders, providing our services, supplying our goods, generating invoices, bills and other payment-related documentation, and credit control. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

3.3          Relationships and communications - We may process contact data, customer relationship data, transaction data and/or communication data for the purposes of managing our relationships, communicating with you (excluding communicating for the purposes of direct marketing) by email, SMS, post, fax and/or telephone, providing support services and compliant handling. The legal basis for this processing is our legitimate interests, namely communications with our website visitors, service users, individual customers and customer personnel, the maintenance of our relationships, enabling the use of our services, and the proper administration of our website, services and business.

3.4          Direct marketing – Where we obtain your consent, we may process contact data, customer relationship data and/or transaction data for the purposes of creating, targeting and sending direct marketing communications by email, SMS, post and/or fax and making contact by telephone for marketing-related purposes. The legal basis for this processing is consent.

3.5          Research and analysis - We may process usage data, service data and/or transaction data for the purposes of researching and analysing the use of our website and services, as well as researching and analysing other interactions with our business. The legal basis for this processing is our legitimate interests, namely monitoring, supporting, improving and securing our website, services and business generally.

3.6          Record keeping - We may process your personal data for the purposes of creating and maintaining our databases, back-up copies of our databases and our business records generally. The legal basis for this processing is our legitimate interests, namely ensuring that we have access to all the information we need to properly and efficiently run our business in accordance with this policy.

3.7          Security - We may process your personal data for the purposes of security and the prevention of fraud and other criminal activity. The legal basis of this processing is our legitimate interests, namely the protection of our website, services and business, and the protection of others.

3.8          Insurance and risk management - We may process your personal data where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks and/or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

3.9          Legal claims - We may process your personal data where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

3.10       Legal compliance and vital interests - We may also process your personal data where such processing is necessary for compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person.

4.             Providing your personal data to others

4.1          We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice.

4.2          Your personal data will be stored on the servers of our hosting services provider, Microsoft Ireland Operations Limited.

4.3          We may disclose the personal data we collect to the following suppliers or subcontractors insofar as reasonably necessary for the purposes set out in Section 3 : (1) Microsoft Ireland Operations Limited, and (2) Google Ireland Limited.

4.4          Financial transactions relating to our website and services are handled by our payment services providers: (1) GoCardless Ltd for payments made using direct debit; (2) PayPal (Europe) S.à r.l. et Cie, S.C.A. for payments made using PayPal; and (3) Stripe Payments Europe Ltd for payments made by debit or credit card. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers' privacy policies and practices at the links below:

(a)       GoCardless Ltd - https://gocardless.com/privacy/payers/

(b)       PayPal (Europe) S.à r.l. et Cie, S.C.A - https://www.paypal.com/uk/webapps/mpp/ua/legalhub-full?locale.x=en_GB

(c)       Stripe Payments Europe Ltd - https://stripe.com/gb/privacy

4.5          In addition to the specific disclosures of personal data set out in this Section 4 , we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

5.             International transfers of your personal data

5.1          In this Section 5 , we provide information about the circumstances in which your personal data may be transferred to countries outside the United Kingdom and the European Economic Area (EEA).

5.2          We will not transfer your personal data outside of the EEA.

5.3          You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

6.             Retaining and deleting personal data

6.1          This Section 6 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

6.2          Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

6.3          We may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

7.             Security of personal data

7.1          We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.

7.2          We will store your personal data on secure servers, personal computers and mobile devices, and in secure manual record-keeping systems.

7.3          The following personal data will be stored by us in encrypted form: your name, contact information, password(s) and cardholder data.

7.4          Data relating to your enquiries, financial transactions and use of our services that is sent from your web browser to our web server, or from our web server to your web browser, or between our servers and our mobile applications, will be protected using encryption technology.

7.5          You should ensure that your password is not susceptible to being guessed, whether by a person or a computer program. You are responsible for keeping the password you use for accessing our website confidential and we will not ask you for your password (except when you log in to our website).

8.             Your rights

8.1          In this Section 8 , we have listed the rights that you have under data protection law.

8.2          Your principal rights under data protection law are:

(a)       the right to access - you can ask for copies of your personal data;

(b)       the right to rectification - you can ask us to rectify inaccurate personal data and to complete incomplete personal data;

(c)       the right to erasure - you can ask us to erase your personal data;

(d)       the right to restrict processing - you can ask us to restrict the processing of your personal data;

(e)       the right to object to processing - you can object to the processing of your personal data;

(f)        the right to data portability - you can ask that we transfer your personal data to another organisation or to you;

(g)       the right to complain to a supervisory authority - you can complain about our processing of your personal data; and

(h)       the right to withdraw consent - to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.

8.3          These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by visiting https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/ .

8.4          You may exercise any of your rights in relation to your personal data by written notice to us, using the contact details set out below.

9.             Third party websites

9.1          Our website includes hyperlinks to, and details of, third party websites.

9.2          In general we have no control over, and are not responsible for, the privacy policies and practices of third parties.

10.         Personal data of children

10.1       Our website and services are targeted at persons over the age of 18.

10.2       If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.

11.         Updating information

11.1       Please let us know if the personal information that we hold about you needs to be corrected or updated.

12.         About cookies

12.1       A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

12.2       Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

12.3       Cookies may not contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.

13.         Cookies that we use

13.1       We use cookies for the following purposes:

(a)       authentication and status - we use cookies to identify you when you visit our website and as you navigate our website, and to help us determine if you are logged into our website;

(b)       shopping cart - we use cookies to maintain the state of your shopping cart as you navigate our website;

(c)       personalisation - we use cookies to store information about your preferences and to personalise our website for you;

(d)       security - we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally;

(e)       advertising - we use cookies to help us to display advertisements that will be relevant to you;

(f)        analysis - we use cookies to help us to analyse the use and performance of our website and services; and

(g)       cookie consent - we use cookies to store your preferences in relation to the use of cookies more generally.

14.         Cookies used by our service providers

14.1       Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

14.2       We use Google Analytics. Google Analytics gathers information about the use of our website by means of cookies. The information gathered is used to create reports about the use of our website. You can find out more about Google's use of information by visiting https://www.google.com/policies/privacy/partners/ and you can review Google's privacy policy at https://policies.google.com/privacy .

15.         Managing cookies

15.1       Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

(a)       https://support.google.com/chrome/answer/95647 (Chrome);

(b)       https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);

(c)       https://help.opera.com/en/latest/security-and-privacy/ (Opera);

(d)       https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);

(e)       https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac (Safari); and

(f)        https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).

15.2       Blocking all cookies will have a negative impact upon the usability of many websites.

15.3       If you block cookies, you will not be able to use all the features on our website.

16.         Amendments

16.1       We may update this policy from time to time by publishing a new version on our website.

16.2       You should check this page occasionally to ensure you are happy with any changes to this policy.

17.         Our details

17.1       This website is owned and operated by Techfinity Ltd.

17.2       We are registered in England and Wales under registration number 8324213, and our registered office is at Suite 81, 105 London Street, Reading, RG1 4QD.

17.3       Our principal place of business is at our registered office.

17.4       You can contact us:

(a)       by post, to the postal address given above;

(b)       using our website contact form;

(c)       by telephone, on the contact number published on our website; or

(d)       by email, using the email address published on our website.