Privacy and Cookies Policy

Part 1: Privacy Policy

This privacy notice was last updated on: 19th June 2018

INTRODUCTION

Welcome to NotSoSecure Global Services Limited’s privacy notice.

NotSoSecure 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, about your privacy rights and how the law protects you.

Please also use the Glossary in paragraph 10 to understand the meaning of some of the terms used in this privacy notice.

1. IMPORTANT INFORMATION AND WHO WE ARE

1.1 Purpose of this privacy notice

This privacy notice aims to give you information on how NotSoSecure collects and processes your personal data through your use of our website www.notsosecure.com (website), including any data you may provide through the website when you sign up to our e-mail notifications and/or newsletter, or purchase a service from us. We can also collect and process personal data through the contact we have with you when you fill out any forms, for example, our order form, and when we correspond with you via telephone, email and post.

We do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you 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.

1.2 Controller

NotSoSecure Global Services Limited is the controller and responsible for your personal data (collectively referred to as “NotSoSecure”, “we”, “us” or “our” in this privacy notice). Our data protection registration number is ZA119309.

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights (see paragraph 9), please contact the data privacy manager using the details set out below.

1.3 Contact details

Our full details are:

Full name of legal entity: NotSoSecure Global Services Limited, company number 09600047. Our registered office is at 75 Springfield Road, Chelmsford, Essex, CM2 6JB.
Person who correspondence should be addressed to in respect of data protection: Data Privacy Manager.
Email address: contact@notsosecure.com
Postal address: CB1 Business Centre, Twenty Station Road, Cambridge, CB1 2JD
Telephone number: +44 1223 653 193

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.

1.4 Changes to the privacy notice and your duty to inform us of changes

This version was last updated on the date stated at the beginning of this privacy notice.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

1.5 Third-party links, plug-ins and applications on our website

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). For the full definition of personal data see paragraph 10.3.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
Identity Data includes first name, last name, username or similar identifier and title.
Contact Data includes billing address, delivery address, email address and telephone numbers.
Financial Data includes bank account and payment card details.
Transaction Data includes details about payments to and from you and other details of services you have purchased from us including the timing, frequency and pattern of service use.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website (including communication content and meta data associated with the communication).
Profile Data includes your username and password, purchases, orders or enquiries made by you and profiles completed by you on our website or when ordering our services, your interests, preferences, feedback and survey responses and any other information you choose to send to us.
Usage Data includes information about how you use our website, products and services, any training records that we hold in relation to your training with us, any communications you send to us or send through our website or post on our website.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

Before you disclose to us personal data about any other person, you must obtain that person’s consent to both the disclosure and the processing of that personal data in accordance with the terms of this policy.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. 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. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

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.

2.1 If you fail to provide personal data

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 training services). In this case, we may have to cancel a product or 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 Identity, Contact, Profile and Financial Data by filling in forms or by corresponding with us by post, phone, e-mail or otherwise. This includes personal data you provide when you:

  • apply for our services;
  • create an account or profile on our website;
  • subscribe to our service or publications;
  • request marketing to be sent to you;
  • enter a competition, promotion or survey; or
  • give us some feedback.

Automated technologies or interactions. When and if you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns and your Usage Data in respect of your use of our website. We collect this personal data by using cookies and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our Cookie Policy, which can be accessed via our website https://www.notsosecure.com/privacy-and-cookies-policy/#cookiessection for further details.

Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below]:

  • Technical Data from the following parties:
    • (a) analytics providers;
    • (b) advertising networks; and
    • (c) search information providers.
  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services.

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:

• Where we need to perform the contract we are about to enter into or have entered into 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.

See paragraph 10.2 to find out more about the types of lawful basis that we will rely on to process your personal data.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us (please see paragraph 1.3 for how to contact us).

4.1 Purposes for which we will use your personal data

We use your personal data in the following ways:

personal data that you provide to us is used to:

  • provide you with the information and services that you request from us
  • provide you with marketing information in accordance with your marketing preferences (see paragraph 4.2)
  • manage and administer our business and website
  • review and improve our services
  • send statement, invoices and payment reminders to you, and collect payments from you
  • send you non-marketing commercial communications
  • send you e-mail notifications that you have specifically requested
  • send you our e-mail newsletter, if you have requested it (you can inform us at any time if you no longer require the newsletter)
  • send you marketing communications relating to our business or the businesses of carefully-selected third parties which we think may be of interest to you, by post or, where you have specifically agreed to this, by e-mail or similar technology (you can inform us at any time if you no longer require marketing communications)
  • deal with enquiries and complaints made by or about you relating to our website
  • verify compliance with the terms and conditions governing the use of our website (including monitoring private messages sent through our website private messaging service)

personal data that we receive from third parties is combined with the personal data that you provide to us and used for the purposes described above.

personal data about your use of our website is used to:

  • administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes
  • to improve our website to ensure that content is presented in the most effective manner for you and for your computer or mobile device
  • to allow you to participate in interactive features of our website, when you choose to do so
  • to provide support services to us and you
  • as part of our efforts to keep our site safe and secure and prevents fraud
  • to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you
  • to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them

4.2 If you submit personal information for publication on our website, we will publish and otherwise use that information in accordance with the licence you grant to us.

4.3 How we use your personal data for marketing

We will add your details to our marketing database if:

  • you make an enquiry about our services
  • you buy our services
  • you have told a third party that you would like them to pass us your contact details so that we can send you updates about our services
  • you have registered an account on our website and have indicated during the sign up process that you are happy to receive marketing communications

We may send you marketing communications by e-mail, telephone, automated calls, text message, post, other.

You can ask us to only send you marketing communications by particular methods (for example, you may be happy to receive emails from us but not telephone calls), or you may ask us not to send you any marketing communications at all.

We may ask you to indicate your marketing preferences when you first register an account on our website. You can check and update your current marketing preferences at any time by logging into your account on our website or by contacting us (see paragraph 1.3 for how to contact us).

We will only share your personal data with third parties for marketing purposes if you provide us with your consent to do so by ticking a box on a form we use to collect your personal data.

4.4 Cookies

Our website uses cookies to distinguish you from other users of the website. This helps us to provide you with a good experience when you browse the website and also allows us to improve the website. For detailed information on the cookies we use and the purposes for which we use them see our Cookie Policy, which can be accessed via our website https://www.notsosecure.com/privacy-and-cookies-policy/#cookiessection.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy, which can be accessed via our website https://www.notsosecure.com/privacy-and-cookies-policy/#cookiessection.

4.5 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 (see paragraph 1.3 for how to 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. If this requires your consent, you are not required to give your consent just because we ask for it. If you do give your consent, you can change your mind and withdraw it at a later date by contacting us (see paragraph 1.3 for how to contact us).

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below for the purposes set out in paragraph 4 above.

External Third Parties

  • Service providers acting as processors [based in the EEA] who provide IT and system administration services, website development services, website maintenance services, server and hosting services.
  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors/accountants and insurers [based in the EEA] who provide consultancy, banking, legal, insurance and accounting services.
  • HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
  • Payment service providers who handle website financial transactions. We will share information with them only to the extent necessary for the purposes of processing payments you make via our website, refunding payments and dealing with complaints and queries relating to payments.

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 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

6.1 We may share your personal data within the NotSoSecure Group being NotSoSecure Inc. (San Francisco, USA) and NotSoSecure India Private Limited (Mumbai, India). This will involve transferring your data outside the European Economic Area (EEA).

6.2 Some of our external third parties are based outside the EEA or their processing operations are based outside of the EEA (for example their servers), so their processing of your personal data will involve a transfer of data outside the EEA.

6.3 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:

6.3.1 Subject to paragraphs 6.3.2 – 6.3.5 (inclusive) below, We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries (https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en).

6.3.2 Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries (https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en).

6.3.3 Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield (https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/eu-us-privacy-shield_en).

6.3.4 We will only transfer your personal data to countries in respect of which there is no adequacy decision referred to in paragraph 6.3.1 or in respect of transfers to the US, where the provider is not a part of the Privacy Shield under paragraph 6.3.3, if we, or our processor, has provided appropriate safeguards in relation to the transfer, and enforceable data subject rights and effective legal remedies are available. If you would like to know what the relevant safeguards are, please contact us (please see paragraph 1.3 for how to contact us).

6.3.5 Where there is no adequacy decision referred to in paragraph 6.3.1 or safeguards referred to in paragraph 6.3.4, or, in respect of transfers to the US, the provider is not a part of the Privacy Shield under paragraph 6.3.3, we will only transfer your personal data if:

6.3.5.1 you have explicitly consented to the proposed transfer, and have been informed of the risks of such transfer due to the absence of an adequacy decision and appropriate safeguards;

6.3.5.2 the transfer is necessary for the performance of a contract between us or due to pre-contractual measures taken at your request;

6.3.5.3 the transfer is necessary for the conclusion or performance of a contract concluded in your interests between us and a third party; or

6.3.5.4 we are otherwise in compliance with applicable law.

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

How long will you use my personal data for?

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.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see request for erasure in paragraph 9.1.3 below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

If you have any queries about how long your personal data will be stored for, please contact us (please see paragraph 1.3 for how to contact us).

9. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data, these are as follows:

9.1.1 Request access to your personal data (commonly known as a “data subject access request”):

9.1.1.1 This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

9.1.2 Request correction of your personal data:

9.1.2.1 This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

9.1.3 Request erasure of your personal data:

9.1.3.1 This enables you to ask us to delete or remove personal data 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 data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

9.1.4 Object to processing of your personal data:

9.1.4.1 You can object to processing of your personal data 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

9.1.5 Request restriction of processing your personal data:

9.1.5.1 This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

9.1.6 Request transfer of your personal data:

9.1.6.1 If requested, we will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

9.1.7 Right to withdraw consent:

9.1.7.1 You can withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us (please see paragraph 1.3 for how to contact us).

9.2 No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of 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.

9.3 What we may need from you

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.

9.4 Time limit to respond

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.

10. GLOSSARY

10.1 Controller means, unless otherwise provided by law, the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.

10.2 Lawful Basis

Legitimate Interest means conducting and managing our business in our interests, or the interests of a third party. Our interests could include, for example, our internal administrative purposes, ensuring network and information security or for direct marketing. Whether a particular legitimate interest may exist can also depend on the relationship we have with you (for example, where you are a customer of ours).

We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests or the interests of a third party. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us (please see paragraph 1.3 for how to contact us).

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

10.3 Personal data means any information relating to an identified or identifiable natural person (data subject); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

10.4 Processing means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

10.5 Processor means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

Part 2: Cookies

  1. About cookies

1.1 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.

1.2 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.

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

1.4 Cookies can be used by web servers to identity and track users as they navigate different pages on a website and identify users returning to a website.

  1. Our cookies

2.1 We use both session and persistent cookies on our website.

  1. Analytics cookies

3.1 We use Google Analytics to analyse the use of our website.

3.2 Our analytics service provider generates statistical and other information about website use by means of cookies.

3.3 We use the analytics cookies on our website.

3.4 The information generated relating to our website is used to create reports about the use of our website.

3.5 Our analytics service provider’s privacy policy is available at: http://www.google.com/policies/privacy/.

  1. Third party cookies

4.1 Our website may use third party cookies.

  1. Blocking cookies

5.1 Most browsers allow you to refuse to accept cookies; for example:

(a) in Internet Explorer (version 10) you can block cookies using the cookie handling override settings available by clicking “Tools”, “Internet Options”, “Privacy” and then “Advanced”;

(b) in Firefox (version 24) you can block all cookies by clicking “Tools”, “Options”, “Privacy”, selecting “Use custom settings for history” from the drop-down menu, and unticking “Accept cookies from sites”; and

(c) in Chrome (version 29), you can block all cookies by accessing the “Customise and control” menu, and clicking “Settings”, “Show advanced settings” and “Content settings”, and then selecting “Block sites from setting any data” under the “Cookies” heading.

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

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

  1. Deleting cookies

6.1 You can delete cookies already stored on your computer; for example:

(a) in Internet Explorer (version 10), you must manually delete cookie files (you can find instructions for doing so at http://support.microsoft.com/kb/278835);

(b) in Firefox (version 24), you can delete cookies by clicking “Tools”, “Options” and “Privacy”, then selecting “Use custom settings for history”, clicking “Show Cookies”, and then clicking “Remove All Cookies”; and

(c) in Chrome (version 29), you can delete all cookies by accessing the “Customise and control” menu, and clicking “Settings”, “Show advanced settings” and “Clear browsing data”, and then selecting “Delete cookies and other site and plug-in data” before clicking “Clear browsing data”.

6.2 Deleting cookies will have a negative impact on the usability of many websites.

Part 3: Our details

  1. Data protection registration

1.1 We are registered as a data controller with the UK Information Commissioner’s Office.

1.2 Our data protection registration number is ZA119309.

  1. Our details

2.1 This website is owned and operated by NotSoSecure Global Services Limited.

2.2 We are registered in England and Wales under registration number 09600047, and our registered office is at Office 75 Springfield Road, Chelmsford, Essex, CM2 6JB, UK.

2.3 Our principal place of business is at CB1 Business Centre, Twenty Station Road, Cambridge, CB1 2JD, UK.

2.4 You can contact us by writing to the business address given above, by using our website contact form, by email to contact@notsosecure.com or by telephone on +44 1223 653193.