Tenzor Geo Ltd, registered in Scotland with company number SC587661 are committed to protecting your personal data.
When collecting and using personal data, our policy is to be transparent about why and how we process personal data.
This privacy statement describes the personal data we collect from you, what we do with it, how you might access it and who it might be shared with. Please read it carefully.
Data protection principles
We will comply with data protection law and the fundamental data protection principles, which state that the personal information we hold about you must be:
· used lawfully, fairly and in a transparent way;
· collected only for valid purposes that we have clearly explained to you, and not used in any way that is incompatible with those purposes;
· relevant to the purposes we have told you about and limited only to those purposes;
· accurate and kept up to date;
· kept only as long as necessary for the purposes we have told you about; and
· kept securely.
Information we collect and use
· Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include anonymised data.
· When you use the Website or any of our subscription products, we will automatically collect device data including IP addresses and details about your browsing history whilst on the platform, browser type, session frequency and cookies.
Why we Process Personal Data
Customer Product and Services:
We process personal data related to the above data subject in order to:
· provide access to our products and services – examples of such services include access to our online applications, subscription products, reports, newsletters or consulting services;
· manage customer relationships;
· develop our business services;
· maintain and use IT systems;
· to comply with legal, regulatory and corporate governance requirements; and
· administer and manage our website, systems and applications, including confirming and authenticating identity and preventing unauthorised access to restricted areas, premium content or other services limited to registered users and to aggregate data for website analytics and improvements.
Suppliers and Contractor management:
We collect and process personal data related to the above data subject:
· to administer and manage supplier and contractor relationships;
· to enter into contracts;
· to receive services from our supplier and to support the provision of services to our customers where relevant;
· for security and risk management, controlling access to IT systems,
· for travel or customer engagement management and
· to comply with legal, regulatory and corporate governance requirements.
Unless we are asked not to, we use corporate business contact details to provide information that we think will be of interest to you about us and our services. We will keep your information confidential and we will only use your information within Genzor Geo.
Where we require explicit opt-in consent for direct marketing to private email addresses in accordance with the Privacy and Electronic Communications Regulations we will ask for your consent. You can withdraw your consent to such processing at any time, however, you should be aware that if you choose to withdraw your consent we will tell you more about the possible consequences, including if this means that certain services (in particular where you have applied for newsletter updates to a private email address) can no longer be provided). Otherwise, for marketing where the Privacy and Electronic Communications Regulations or where we can rely on the soft opt-in exemption under the Privacy and Electronic Communications Regulations, we will be relying on our ‘Legitimate Interests’ for the purposes of GDPR.
You can opt-out of receiving marketing from us at any stage. Should visitors subsequently choose to unsubscribe from mailing lists or any registrations, we will provide instructions on the appropriate webpage, in our communication to the individual, or the individual may contact us by email to firstname.lastname@example.org
Tenzor Geo will retain Personal Data for as long as is reasonably necessary for the purposes listed above.
In the absence of other specific legal, regulatory or contractual requirements, our baseline retention period for records and other documentary evidence created in the provision of services is 6 years. Records may however be archived earlier where there has been no interaction with a data subject for 2 years.
Personal data may be held for longer periods where extended retention periods are required by law or regulation and in order to establish, exercise or defend our legal rights.
Who do we share your personal data with?
We will share the data with third parties, to help manage our business and deliver services. These third parties may from time to time need to have access to your personal data, and include:
· service providers, who help manage our IT and back office systems, in particular Microsoft, Apple, Dropbox, Rackspace and Intercom.
· Contact Relationship Management and marketing tools such as Salesforce, Xero, Mailchimp, Sendbloom, ActiveCampaign and iContact.
· Payment management tools and service Sage (UK), Worldpay and Stripe.
· our regulators, which include the ICO, as well as other regulators and law enforcement agencies in the E.U. and around the world,
· solicitors and other professional services firms (including our auditors).
· Also, if we were to sell part of our businesses we would need to transfer your personal data to the purchaser.
Transfer of Personal Data
We share your personal data with of our third parties service providers are based outside the European Union so their processing of your personal data will involve a transfer of data outside the European Union. Countries outside of the European Union do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.
Accordingly, whenever we transfer your personal data out of the EEA, we will ensure at least one of the following safeguards is in place:
· transfer to countries that the European Commission have approved as providing an adequate level of protection for personal data by; or
· Where we use certain service providers, we may use the Standard Contractual Clauses, other specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or
· If we use US-based providers that are part of EU-US Privacy Shield, we may transfer data to them, as they have equivalent safeguards in place.
In those cases you will have the right to ask us for more information about the safeguards we have put in place as mentioned above (e.g. to request a copy where the safeguard is documented, which may be redacted to ensure confidentiality).
How is your personal information collected?
We collect most personal information from you, in a variety of ways:
· during the provision of services to you;
· during our business relationship with you;
· when you sign up for information via our website; and
We may sometimes collect additional information from publicly available information including Companies House as well as third parties such as credit reference agencies, government agencies or other third party organisations that you have had or have a relationship with.
Your rights of access, correction, erasure, and restriction
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.
Under certain circumstances, by law you have the right to:
· request access to your personal information. This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it;
· request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected;
· request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing;
· object to processing of your personal information 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;
· withdraw your consent to processing, where we are processing on this basis of your prior consent;
· request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example, if you want us to establish its accuracy or the reason for processing it; and
· request the transfer of your personal information to another party.
If you wish to exercise any of these rights, please email us at email@example.com
You will not have to pay a fee to access your personal information or to exercise any of the other rights. However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is an appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
You have the right to complain at any time to the Information Commissioner’s Office, the UK supervisory authority for data protection issues. https://ico.org.uk/.
Subscribing to our website
You can subscribe on our website to receive information from us, including legal updates, event and seminar details or news. You can unsubscribe at any time by clicking on the “click here to unsubscribe” link provided in our emails or by contacting us direct at firstname.lastname@example.org