Veropath Limited (“Veropath“, “we“, “us“, “our“) 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 our website at www.veropath.com (“Website“) and tell you about your privacy rights. This notice is provided in a layered format so you can click through to the specific areas set out below.
- IMPORTANT INFORMATION AND WHO WE ARE
- THE DATA WE COLLECT ABOUT YOU
- HOW IS YOUR PERSONAL DATA COLLECTED
- HOW WE USE YOUR PERSONAL DATA
- DISCLOSURES OF YOUR PERSONAL DATA
- INTERNATIONAL TRANSFERS
- DATA SECURITY
- DATA RETENTION
- YOUR LEGAL RIGHTS
1. IMPORTANT INFORMATION AND WHO WE ARE
PURPOSE OF THIS PRIVACY NOTICE
It is important that you read this privacy notice together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data you may provide us 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.
Our Website is not intended for children and we do not knowingly collect data relating to children.
Veropath Limited, registered in Scotland with company no. SC225788 and our registered office at 8 Walker Street, Edinburgh, EH3 7LH, is the data controller and responsible for your personal data.
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions, comments or requests about this privacy notice, please contact the data privacy manager using the details set out below.
Name of data privacy manager: Aaron Philip.
Email address: DataProtection@veropath.com.
Postal address: Veropath Limited, 7 Castle Street, Edinburgh EH2 3AH.
Telephone: 0131 514 6186.
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.
CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
It is important that the personal data we hold about you is accurate and current. Please keep us informed if the personal data you have provided to us, whether about yourself or about a co-worker, changes during your relationship with us.
Our Website 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.
2. THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, 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 which we have grouped together as follows:
- Identity Data includes first name, last name, username or similar identifier, title, employee ID, position within company
- Contact Data includes email address and telephone numbers.
- Technical Data includes internet protocol (IP) address, your login data, page requests, errors, timings, data volume, browser type and version, time zone setting and location, traffic data, weblogs, browser plug-in types and versions, operating system and platform and other technology and communications data on the devices you use to access the Website.
- Usage Data includes information about how you use our Website and the resources that you access.
- Marketing and Communications Data includes your marketing and communication preferences.
We also collect, use and share Aggregated Data about the use of the Website, such as statistical or demographic data including about browsing actions and patterns on the Website, for any purpose, including system administration and to report aggregate information to our advertisers. 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.
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.
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 (for example, to provide you with services). 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.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your data, and the data of your co-workers and others, by filling in forms on the Website or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- request marketing to be sent to you;
- apply for and book a demonstration of our products or services;
- contact us using the form or contact details on the Website and interact with our customer support;
- Automated technologies or interactions. As you interact with our Website, we may automatically collect Technical Data about your equipment, browsing actions and patterns.
4. HOW WE USE YOUR PERSONAL 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:
- Performance of a contract with you or in order to take steps at your request prior to entering into a contract with you.
- 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.
- Where we need to comply with a legal or regulatory obligation.
You can find out more about these legal bases here: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/lawful-basis-for-processing/#ib3.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications. You have the right to withdraw consent to marketing at any time by contacting us.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below a description of all the ways we plan to use your personal data, and the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Please note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we use your data.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To book and arrange a demonstration||
||Performance of a contract with you or in order to take steps at your request prior to entering into a contract with you.|
|To manage our relationship with you which will include:
(b) Carrying out our obligations arising from any contracts entered into with you
(c) Handling customer contacts, queries, claims, complaints or support requests
||(a) Performance of a contract with you or in order to take steps at your request prior to entering into a contract with you.
(b) Necessary to comply with a legal obligation.
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services).
|To administer and protect our business and the Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||
||(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise).
(b) Necessary to comply with a legal obligation.
|To use data analytics to improve our Website, products/services, marketing, customer relationships and experiences and assess trends within the Website||
||Necessary for our legitimate interests (to keep our Website updated and relevant, to ensure that content from our site is presented in the most effective manner for you and for your computer, to develop our business and to inform our marketing strategy).|
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.
PROMOTIONAL OFFERS FROM US
You will receive marketing communications from us if you have requested information from us and you have not opted out of receiving that 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 contacting us. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase, product/service experience or other transaction.
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.
5. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the following parties for the purposes in the table in paragraph 4 above:
- Service providers acting as data processors who provide customer services, IT and email management such as the Pulsant Group within Europe.
- Professional advisers including lawyers, bankers, auditors and insurers who provide banking, legal, insurance and accounting services.
- HMRC, regulators and other authorities who require reporting of processing activities in certain circumstances.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. INTERNATIONAL TRANSFERS
Some of our external service providers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA. Whenever your personal data is transferred out of the EEA, we take steps to ensure a similar degree of protection is afforded to it by ensuring that the following safeguard is implemented:
- Where we use service providers based outside the EEA, we enter into a data processing agreement with them and use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, please see European Commission: Model contracts for the transfer of personal data to third countries.
If you wish to know more about international transfers of your personal data, you may contact our data privacy manager at DataProtection@veropath.com.
7. DATA SECURITY
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 have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. DATA RETENTION
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. Details of retention periods for different aspects of your personal data are available in our retention policy which you can request by contacting us.
9. YOUR LEGAL RIGHTS
In certain circumstances, you have rights under data protection laws in relation to your personal data. These include:
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
You can find out more about your rights here: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.
If you wish to exercise any of these rights, please contact us by email at DataProtection@veropath.com.
You will not have to pay a fee to access your personal data (or to exercise the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month 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.