Privacy Policy

 

Introduction

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”).

Our Privacy Policy is intended to describe to you how and what data we collect, and how and why we use your personal data. It also describes options for you to access, update or otherwise take control of your personal data that we process.

If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us using the following details:

  • Post: Data Protection, Cygnet IT Services CIC, BTS House, 69-73 Manor Road, Wallington, Surrey, SM6 0DD
  • Phone: 020 8619 1200
  • Email: info@cygnet.it

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.

What information do we collect

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:

  • Identity data: including first name, maiden name, last name, username or similar identifier, title, date of birth and gender;
  • Contact data: including address, email address and telephone number;
  • Financial data: including bank account and payment card details;
  • Transaction data: including details about payments to and from you and other details of products and services you have purchased from us;
  • Technical data: including 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 the website;
  • Usage data: including information about how you use our website, products and services;
  • Marketing and communications data: including your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share aggregated data such as statistical or demographic data for any purpose.

Aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. 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 policy.

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.

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. 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.

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 identity, contact and financial data by filling in forms or by corresponding with us by post, phone, email or otherwise.  This includes personal data you provide when you:
    • Apply for our Services;
    • Create an account on our website;
    • Subscribe to our service or publications;
    • Request marketing to be sent to you;
    • Enter a competition, promotion or survey; or
    • Give feedback or contact us.
  • Automated technologies or interactions: if you use our website, we will automatically collect technical data about your equipment, browsing actions and patterns.  We collect this personal data by using cookies and other similar technologies.
  • Third parties or publicly available sources: we may receive some of the above personal data about you from various third parties and public sources as set out below:
    • Analytics providers including Google Analytics
    • Social media providers including Facebook, Twitter and LinkedIn
    • Online service providers including Mail Chimp and Survey Monkey

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.

How we utilise information

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 you have provided consent;
  • 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.  A legitimate interest is where the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience.  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 of our legitimate interests.  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);
  • where we need to comply with a legal obligation.

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:manage payments, fees and charges, collect and recover money owed to us, diagnose any problems with and identify any security risks, errors or needed enhancements to the services Performance of a contract with you Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include: notifying you about changes to our terms or privacy policy asking you to leave a review or take a survey Performance of a contract with you Necessary to comply with a legal obligation Necessary for our legitimate interests (to keep our records updated and to study how customers use our Services)
To enable you to partake in a prize draw, competition or complete a survey Performance of a contract with you Necessary for our legitimate interests (to study how customer use our Services, to develop them and grow our business)
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:

  • Improve and optimise the operation and performance of our Services
  • Diagnose problems with and identify any security risks, errors, or needed enhancements to the Services
  • Detect and prevent fraud and abuse of our Services and systems
  • Collecting aggregate statistics about use of the Services
  • Understand and analyse how you use our Services and what products and services are most relevant to you

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:

  • Email
  • Text (SMS) messages
  • Telephone calls
  • Automated phone calls or text messages

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 info@cygnet.it.
If we collect information from you in connection with a co-branded offer, it will be clear at the point of collection who is collecting the information and whose privacy policy applies. In addition, it will describe any choice options you have in regards to the use and/or sharing of your personal data with a co-branded partner, as well as how to exercise those options.
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 info@cygnet.it.

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.

We may use cookies to:

  • Analyse our web traffic using an analytics package: Aggregated usage data helps us improve the website structure, design, content and functions.
  • Identify whether you are signed in to our website: A cookie allows us to check whether you are signed in to the site.
  • Test content on our website: For example, 50% of our users might see one piece of content, the other 50% a different piece of content.
  • Store information about your preferences: The website can then present you with information you will find more relevant and interesting.
  • To recognise when you return to our website: We may show your relevant content or provide functionality you used previously.
  • Cookies do not provide us with access to your computer or any information about you, other than that which you choose to share with us.

You can use your web browser’s cookie settings to determine how our websites uses cookies. If you do not want our website to store cookies on your computer or device, you should set your web browser to refuse cookies. However, please note that doing this may affect how our website functions. Some pages and services may become unavailable to you. Unless you have changed your browser to refuse cookies, our website will issue cookies when you visit it.

6. Third-party websites: Our website contains links to third-party websites. We are not responsible for the privacy practices or the content of third-party sites. Please read the privacy policy of any website you 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.

Opting-out

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:

  • Internal third parties [any companies in the group]
  • External third parties [i.e. service providers acting as processors (e.g. who provide IT/admin services), professional advisers (e.g. lawyers, bankers, auditors, insurers), HMRC/regulators/other authorities]
  • 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 policy.

We only share your personal data as necessary for these third parties to perform Services as requested or on our behalf, such as:

  1. Processing credit card payments
  2. Serving advertisements
  3. Conducting contests or surveys
  4. Performing analysis of our Services and customers demographics
  5. Communicating with you, such as by way of email or survey delivery
  6. Customer relationship management

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).

International transfer

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:

  • 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.
  • 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.

8. Cygnet uses Google Adwords Remarketing to advertise our services and create brand awareness across the internet. Remarketing allows Cygnet to display relevant ads to you based on parts of our website you visited and interacted with by placing a cookie on your machine. This means we could advertise to visitors who have not completed a task like completing a contact form. This cookie does not in anyway identify you or give access to your computer. The cookie is only used to say “this person visited this page” so Google and third-party vendors can personalise our online advertisement to reflect your interests. Advertisements may appear on a Google Search Results page, or a third-party site in the Google Display Network. Any data collected will be used in accordance with our own privacy policy and Google’s privacy policy. 

If you do not wish to receive this type of advertising from us in the future you can opt out using the DoubleClick opt-out page or the Network Advertising Initiative opt-out page.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

How you can access, delete or update your data

In some circumstances you have rights under data protection laws in relation to your personal data:

  • request access to your personal data: This enables you to receive a copy of the personal data we hold about you and check that we are lawfully processing it;
  • request correction of the personal data we hold about you:  You can 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;
  • request erasure of your personal data: You can ask us to delete or remove personal data where there is no good reason for us continuing to process it.  You may also 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 by law.  We may not be able to comply with your request of erasure for specific legal reasons which we will notify you of, if applicable, at the time of your request;
  • object to processing of your personal data: You have the right to object where we are relying on a legitimate interest (or those of a third party) and there is something about your situation which makes you wish 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 circumstances, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms;
  • request restriction of processing of your personal data: You can 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;
    • you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it;
  • request the transfer of your personal data to you or 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.  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;
  • withdraw consent at any time: This right only applies where we are relying on consent to process your personal data.  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 Services to you.  We will advise you if this is the case at the time you withdraw your consent.

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.

How we secure your data

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.

Data retention

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 info@cygnet.it

Changes in our Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we decide to change our Privacy Policy, we will post those changes to this Privacy Policy and any other places we deem appropriate, so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. If we make material changes to this Privacy Policy, we will notify you here, by email, or by means of a notice on our home page, at least thirty (30) days prior to the implementation of the changes.