This privacy policy sets out how UWI Technology uses and protects any information that you give UWI Technology when you use this website.

UWI Technology is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using this website, then you can be assured that it will only be used in accordance with this privacy statement. It is also 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.

UWI Technology may change this policy from time to time by updating this page. You should check this page from occasionally to ensure that you are happy with any changes.

This policy is effective from 01/10/2018. Historic versions of this policy can be obtained by Contacting us.

Who we are

We are UWI Technology Limited. We are a company incorporated and registered in Scotland. Our company number is SC364169. Our registered address is 5th Floor 125 Princes Street, Edinburgh, EH2 4AD.

When we refer to “UWI Technology” or “we”, “us” or ”our” in this policy, we are referring to UWI Technology Limited. We are the data ‘controller’ in relation to the personal data we collect or that you provide to us, which means we determine the purposes and the way in which your personal data is, or will be, processed.

Purpose of this privacy policy

This privacy policy aims to give you information on how we collect and process your personal details so that you can be confident when you visit our website that you know what your personal data is being used for and that it is being kept safe.

It is important that you read this privacy policy, 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 policy supplements the other notices and is not intended to replace them.

How your personal data is collected

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your personal data by corresponding with us by email, by phone, social media, by post or otherwise.

• Automated technologies or interactions.As you interact with our website, we may automatically collect Technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our Cookie Declaration for further information.

• Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources. For example, analytics providers such as Google or social media platforms.

What we collect

We may collect the following information:

• Contact details. Name and contact information, such as email address.
• Company information. Company information such as address, postcode, job title, and industry sector.
• Survey information. Other information relevant to customer surveys and/or offers.
• Marketing data. Your name, email address and marketing preferences.
• Correspondence data. If you contact us, we may keep a record of that correspondence.
• Technical data. When you browse our website, we automatically collect some technical information about your visit to our website, including, but not limited to, the IP address used to connect your computer to the internet, your browser type and version and your browser plug-in types and version.

What we do with the information we gather

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 (i.e. non disclosure agreement, new customer enquiry form, when you purchase something from us).
• Where we have your prior consent to use your personal data (for example, where you have consented to receiving marketing).
• 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. 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. We do not use your personal data for activities where our interests are superceded 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.
• Where we need to comply with a legal or regulatory obligation.

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of 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 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.

Disclosure of your information

We may have to share your personal information with the following third parties:

• External third-party service providers acting as processors who provide the following services:
• Web hosting;
• Metrics and analytics; and
• Customer Relationship Management systems.
• Professional advisers, including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
• In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
• If UWI Technology or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.

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.

International transfers

If 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:

• The country has 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.
• If we use certain service providers based outwith the EEA, 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.
• If 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 the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
• In any other case, we will obtain your explicit consent before any transfer takes place.

Some of our service providers are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA. The table below sets out details of transfers to such third parties and the relevant safeguards.

Security

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.

Cookies

Our website uses cookies to help it function and to improve it. Most web browsers allow some control of cookies through the browser settings. For more detailed information about the cookies we use, please see our Cookie Declaration.

Links to other websites

Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other websites. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.

How long we store your 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.

We normally delete personal identifiable information we hold on you within 7 years but in some circumstances you can ask us to delete your data sooner: see Deleting personal data below for further information.

Where we anonymise your personal data (i.e. so that it can no longer be associated with you) for further research or statistical purposes, then we may use this information indefinitely without further notice to you.

Controlling your information

Under certain circumstances you have rights under data protection laws in relation to your personal data. We have set out more detail on your rights below. However, most importantly, you may choose to restrict the collection or use of your personal information for direct marketing purposes in the following ways:

• Whenever you are asked to fill in a form on the website, look for the box that you can click to indicate that you do not want the information to be used by anybody for direct marketing purposes.
• If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by Contacting us.

Your rights

We have set out some detail of rights you may have under data protection laws in relation to your personal data. [Please click on the links below to find out more about these rights:]

• Access to your information
• Request correction of your personal data
• Request deletion 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
• Right to review by an independent authority

If you wish to exercise any of the rights set out above, please Contact us. 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.

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 this may take longer 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.

Access to your information

You have the right to ask for a copy of the information which we hold about you (commonly known as a ‘data subject access request’). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Correcting personal data

You have the right to request that we correct personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold corrected, although we may need to verify the accuracy of the new data that you provide to us.

Deleting personal data

You may ask us to delete or remove personal data where there is no good reason for us continuing to process it. This is more commonly known as the ‘right to be forgotten’. 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.

Please note, however, that we may not always be able to comply with your request to delete or remove personal data for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Objecting to processing

You have the right to stop us processing your personal data for direct marketing purposes. We will always inform you if we intend to use your personal data for such purposes, or if we intend to disclose your information to any third party for such purposes. You can usually exercise your right to prevent such marketing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by Contacting us.

You may also object to us processing 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. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Restriction of processing

This enables you to ask us to suspend the processing of your personal data in the following scenarios:

• if you want us to establish the data’s accuracy;
• where our use of the data is unlawful but you do not want us to erase it;
• 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
• you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Transferring your personal data

In certain circumstances, you may request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format.

Please 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.

Withdrawing consent

Where we are relying on consent to process your personal data you can withdraw your consent at any time. Please note that this will not affect the lawfulness of any processing carried out before you withdraw your consent.

Review by an independent authority

You will always have the right to lodge a complaint with a supervisory body. The relevant authority in the UK is the Information Commissioner’s Office. If you do have a complaint, we would appreciate the chance to deal with your concerns before you approach the ICO, so please do Contact us in the first instance if possible.

Contact us

Questions, comments and requests regarding this policy are welcomed and should be addressed to our Data Protection Manager at:

• UWI Technology Limited, Codebase, Argyle House, 3 Lady Lawson Street, Edinburgh EH3 9DR or
• [email protected]