Introduction

Welcome to the privacy policy of Spotta Ltd (the “Supplier”), a company incorporated in England and Wales with registered number 11240610 and having its registered office at 1 Bennell Court, Comberton West Street, Comberton, Cambridge, United Kingdom CB23 7EN.
 

The Supplier respects your privacy and is committed to protecting your personal data.  This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

This privacy policy is the one referred to in our terms and conditions of business on and subject to which the Supplier has agreed to provide services to the entity (the “Customer”) that appointed you as an Authorised User of the Portal at [web address] (the “Portal”).
 

This privacy policy is provided in a layered format so you can click through to the specific areas set out below.  [Alternatively, you can download a pdf version of the policy here: [LINK].] Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.
 

1. [IMPORTANT INFORMATION AND WHO WE ARE]

2. [THE DATA WE COLLECT ABOUT YOU]

3. [HOW IS YOUR PERSONAL DATA COLLECTED?] 

4. [HOW WE USE YOUR PERSONAL DATA] 

5. [DISCLOSURES OF YOUR PERSONAL DATA] 

6. [INTERNATIONAL TRANSFERS]

7. [DATA SECURITY]

8. [DATA RETENTION]

9. [YOUR LEGAL RIGHTS]
    

1. Important information and who we are.
 

Purpose of this privacy policy

This privacy policy aims to give you information on how the Supplier collects and processes your personal data through your use of this website, including any data you may provide through this website when you log on to the Portal.

Controller

The Customer is the data controller and responsible for your personal data.  The Supplier is a processor of it.

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

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact our data privacy manager in the following ways:

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Full name of data privacy manager: [DETAILS]

Email address: [DETAILS]

Postal address: [DETAILS]

Telephone number: [DETAILS]

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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 ().  We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

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Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review.  This version was last updated on [DATE]. 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.

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Third-party links

The portal does not include links to third-party websites, plug-ins or applications.  
 

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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 only 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,

• Contact Data includes email address and work and mobile telephone numbers.

• Technical Data includes internet protocol (IP) address, your login data, browser type and version, operating system and platform, and other technology on the devices you use to access this website.

• Profile Data includes feedback uploaded by you in connection with your use of the Portal.

• Usage Data includes [information about how you use the Portal].

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.
 

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of the contract we have with the Customer, and you fail to provide that data when requested, we may not be able to perform that contract.  In this case, we may have to suspend your access to the Portal but we will notify you if this is the case at the time.
 

3. How is your personal data collected?

We only collect data from and about you by means of your uploading it via the Portal or by receiving it from the Customer.

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 have with the Customer.

• 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 obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data and we will not send third party direct marketing communications to you via email or text message. 

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Purposes for which we will use your personal data

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.
 

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.

1 - Purpose / Activity

2 - Type of Data

3 - Lawful basis for processing including basis of legitimate interest

Marketing

We do not use data provided to the Portal for marketing purposes.

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Third-party marketing

We will not share your personal data with any third party for marketing purposes.

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Cookies

We do not use cookies on the Portal.

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Change of purpose

We will only use your personal data for the purposes for which we collected it.

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.

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5. 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 [Purposes for which we will use your personal data] above.
 

• The Customer.

• 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 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.
 

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6. International transfers

We do not transfer your personal data outside the European Economic Area (EEA).

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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 who have a business need to know.  
 

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.

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8. Data retention

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How long will you use my personal data for?

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.

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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 [your legal rights] below for further information.

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9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data.  Please click on the links below to find out more about these rights:
 

• [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].

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

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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 could refuse to comply with your request in these circumstances.

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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.

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Time limit to respond

We try to respond to all legitimate requests within one month.  Occasionally it could 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.