Cygnet IT Services CIC is the controller and responsible for your personal data.
Cygnet IT Services CIC cares about your privacy and is committed to protecting your personal data. For this reason, we collect and use personal data only as it might be needed for us to deliver to you our products and services (collectively, our “Services”).
We will respond to all requests, inquiries or concerns within 30 days. Occasionally it could take us longer than 30 days if your request is particularly complex or you have made a number of requests. In this case we will notify you and keep you updated.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Personal data means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you:
We also collect, use and share aggregated data such as statistical or demographic data for any purpose.
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 or offences.
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel a Service you have with us, but we will notify you if this is the case at the time.
We use different methods to collect data from and about you including through:
Should we receive personal data from an additional third party or publicly available source, we will provide you with a separate notification within a reasonable period after obtaining the data.
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Please contact us if you wish to obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities.
We have set out below, in a table format, a description of the ways we plan to use your personal data, and which of the legal bases we rely on. We have also identified what our legitimate interests are where appropriate.
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 where more than one ground has been set out in the table below.
|Purpose / Activity||Lawful basis for processing|
To register you as a new customer
Performance of a contract with you
To process and deliver the Services including:
To manage our relationship with you which will include:
To enable you to partake in a prize draw, competition or complete a survey
To use data analytics to improve our website, Services, marketing, customer relationships and experiences
Necessary for our legitimate interests (to define types of customers for our Services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about Services that may be of interest to you
Necessary for our legitimate interests (to develop our Services and grow our business)
We have set out some further detail on these purposes below:
1. Delivering, improving, updating and enhancing the Services we provide to you: We collect various information relating to your contracted services, use and/or interactions with our Services. We utilise this information to:
Often, much of the data collected is aggregated or statistical data about performance of our Services, and is not linked to any personal data, but to the extent it is itself personal data, or is linked or linkable to personal data, we treat it accordingly.
2. Communicating with you: We may contact you directly or through a third-party service provider regarding products or services you have signed up to or purchased from us, such as necessary to deliver transactional or service related communications. We may also contact you with offers for additional services we think you’ll find valuable if you give us consent, or where allowed based upon legitimate interests.
You don’t need to provide consent as a condition to purchase our goods or services. These contacts may include:
You may also update your subscription preferences with respect to receiving communications from us and/or our partners by accessing your Customer Login or emailing email@example.com.
If you believe that anyone has provided us with your personal information and you would like to request that it be removed from our database, please contact us at firstname.lastname@example.org.
3. Compliance with legal, regulatory and law enforcement requests: We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We will disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (such as subpoena requests), to protect our property and rights or the property and rights of a third party, to protect the safety of the public or any person, or to prevent or stop activity we consider to be illegal or unethical.
To the extent we are legally permitted to do so, we will take reasonable steps to notify you in the event that we are required to provide your personal information to third parties as part of legal process.
4. Website analytics: We use web analytics tools provided by service partners such as Google Analytics and Facebook Insights to collect information about how you interact with our website or social channels, including what pages you visit, how much time you spend on each page, and network and IP information. We use the information provided by these tools to improve our Services.
These tools place persistent cookies in your browser to identify you as a unique user the next time you visit our website. Each cookie cannot be used by anyone other than the service provider (e.g.: Google for Google Analytics and Facebook). The information collected from the cookie may be transmitted to and stored by these service partners on servers in a country other than the country in which you reside.
Though information collected does not include personal data such as name, address, etc., the information collected is used and shared by these service providers in accordance with their individual privacy policies.
You can control the technologies we use by managing your settings when you first visit our web pages, or by utilising settings in your browser.
5. Cookies and how we use them: A cookie is a small file placed on your computer's hard drive. It enables our website to identify your computer as you view different pages on our website. Cookies allow websites and applications to store your preferences in order to present content, options or functions that are specific to you. They also enable us to see information like how many people use the website and what pages they tend to visit.
7. Third party marketing: We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
Change of purpose
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.
Please note that we may process your personal data without your knowledge or consent where this is required or permitted by law.
Disclosures of your personal data
We may share your personal data with the parties set out below for the purposes set out in the table above:
We only share your personal data as necessary for these third parties to perform Services as requested or on our behalf, such as:
These third parties (and any subcontractors) are subject to strict data processing terms and conditions and are prohibited from utilising, sharing or retaining your personal data for any purpose other than as they have been specifically contracted for (or without your consent).
On occasion, we may use external third parties who are based outside the European Economic Area (EEA) and their processing of your personal data may involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
In some circumstances you have rights under data protection laws in relation to your personal data:
To easily access, view, update or delete your personal data (where available), or to update your subscription preferences, please sign in with your Customer Log in.
If you are unable to access your Customer Log in or do not have an account with us, you may also contact us by one of the methods described in the “Contact Us” section below.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. 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.
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.
We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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, regulatory, tax, accounting or other requirements.
In some circumstances you can ask us to delete your data (see above for your legal rights). If you have any questions about the security or retention of your personal data, you can contact us at email@example.com