Privacy Notice

We are an organisation that provides help advice to other organisations regarding data privacy and information security. We gather and process information for the purpose of providing our services and as part of marketing those services to interested parties.

This Privacy Policy applies to information that we collect about individual when:

1. Using our websites (such as www.safedatagov.com and www.compliance-pro.co.uk)
2. Using our mobile applications (including Compliance-Pro Monitor );
3. Using other products and services that are available on or through our websites
4. Having personal interactions via various forms of electronic messaging, voice and video communication or face to face.
5. Communication of relevant marketing information that you have either consented to or otherwise expect from us as part of communication you have initiated or an established relationship.
6. Out of contractual necessity such as in the delivery or products or services.
7. From 3rd parties with whom you have previously agreed that they can share your data with us.

Throughout this Privacy Policy we’ll refer to our website, mobile applications and other products and services collectively as “Services.”

Below we explain how we collect, use, and share information about you, along with the choices that you have with respect to that information.

Please note that this Privacy Policy does not apply to any of our products or services that have a separate privacy policy. These will be presented to you as appropriate should these specific products or services relate to you.

If you have any questions about this Privacy Policy, please contact us as described in the Contact Section below.

We do not collect any sensitive information about you such as political opinions, religious beliefs, information about your health or sex life, genetic or biometric data. Also, we do not gather or process any information regarding criminal convictions, trade union membership or information about children.

Our primary business is in the Business to Business (B2B) environment, however we recognise that there may be individuals or sole traders that are interested in our services too. As such, to provide similar products and services we gather and process the following information:

1. For marketing purposes (Under Legitimate Interests)

• Names of Data Subjects
• Personal and business contact emails and addresses
• Data privacy and information security interests and preferences to ensure marketing remains relevant

2. To deliver our products and services (Under Contractual Necessity)

Business to Business, personal data:

• Business contact details, including email addresses and telephone numbers
• Roles and responsibilities
• Business address details

   

Business to Consumer, personal data:

• Personal contact details, including personal email addresses and telephone numbers
• Personal address details

We only collect information about you if we have a reason to do so–for example, to provide our Services, to communicate with you, or to make our Services better.

We collect information in three ways: if and when you provide information to us, automatically through operating our services, and from outside sources. Let’s go over the information that we collect in the next section.

We may also get information about you from other sources. For example, if you create or log into your account through another service (like Google) or if you connect your website or account to a social media service (like Twitter), we will receive information from that service (such as your username, basic profile information, and friends list) via the authorization procedures used by that service. The information we receive depends on which services you authorize and any options that are available.

We may also obtain information from third party services about individuals who are not yet our users (…but we hope will be!), which we may use, for marketing and advertising purposes. For example, Contact details from event organisers who have already received consent from you or have notified you of their sharing activities prior to sharing your data with us. (Under Legitimate Interest and Consent)

We use information about you as mentioned above and as follows:

1. To provide our Services
• Data Privacy and Information Security Training
• Communicating regular information notices and newsletters
• Providing our Compliance-Pro Platform
• Maintaining our products and services
• Providing customer service and support
 
2. To further develop our Services - for example by adding new features that we think our users will find of benefit;
 
3. To monitor and analyse trends and better understand how users interact with our Products and Services, which helps us improve our Services and make them easier to use;
 
4. To monitor and protect the security of our Services, detect and prevent fraudulent transactions and other illegal activities, fight spam, and protect the rights and property of Safe Data Governance Limited and others;
 
5. To communicate with you about special offers and promotions offered by Safe Data Governance Limited and other related service providers that we have determined will be of interest to you, to solicit your feedback, or keep you up to date on Safe Data Governance Limited and our products; and
 
6. To personalise your experience using our online Services, provide content recommendations and serve relevant advertisements based on your preferences.

Firstly, we do not sell our users’ private personal information.

We share your personal data in the limited circumstances spelled out below and only with appropriate safeguards on your data privacy:

Subsidiaries, Employees, and Independent Contractors: We may disclose information about you to our subsidiaries, our employees, and individuals who are our independent contractors that need to know the information in order to help us provide our Services or to process the information on our behalf. We require our subsidiaries, employees, and independent contractors to follow this Privacy Policy for personal information that we share with them. (Under Legitimate Interests or Consent for Marketing Purposes and Under Contractual Necessity for the provision of our Services) 

With Your Consent: We may share and disclose information with your consent or at your direction. For example, we may share your information with third parties with which you authorize us to do so. Where we require your consent to share your data with 3rd parties you will find these listed under Sharing with Third Parties. (Under Consent)

We may also request your consent to process limited elements of your data in specific ways. Where we require this consent, it will be presented to you in a way that allows you to have a clear understanding of what you are consenting to and enable you to agree to this in a clear and positive way. (Under Consent)

Sharing with Third Parties: We may share information about you with third party vendors who need to know information about you in order to provide their services to us. This group includes vendors that help us provide our Services to you (like payment providers that process your credit and debit card information) and those that help us understand and enhance our Services (like analytics providers). We require vendors to agree to privacy commitments in order to share information with them.

With your consent, we may also share your data with other third parties. These third parties and the reason for sharing your data with them is listed below: (Contractually required to offer our services)

• Web Hosting Providers such as email hosts and domain hosts to enable us to send and respond to emails, host our website and our online service platform (Under Contractual Requirement)
• As Required by Law: We may disclose information about you in response to a legal instruction such as a court order, or other governmental request. (Under Legal Requirement)
• To Protect Rights and Property: We may disclose information about you when we believe in good faith that disclosure is reasonably necessary to protect the property or rights of Safe Data Governance Limited, third parties, or the public at large. For example, if we have a good faith belief that there is an imminent danger of death or serious physical injury, we may disclose information related to the emergency without delay. (Under Vital Interests, Legitimate Interest and Legal Requirements)
• Business Sale or Transfers: In connection with any merger, sale of company assets, or acquisition of all or a portion of our business by another company, or in the unlikely event that Safe Data Governance Limited goes out of business or enters bankruptcy, user information would likely be one of the assets that is transferred or acquired by a third party. If any of these events were to happen, this Privacy Policy would continue to apply to your information and the party receiving your information may continue to use your information, but only consistent with this Privacy Policy. (Under Legitimate Interest, Contractual Requirement and Legal Requirement)
• Aggregated and De-Identified Information: We may share information that has been aggregated or reasonably de-identified, so that the information could not reasonably be used to identify you. For instance, we may publish aggregate statistics about the use of our Services. (This data would have no bearing upon your data privacy).
• Published Support Requests: If you send us a request (for example, via a support email or one of our feedback mechanisms), we reserve the right to publish a sanitised version of the request in order build a library of Frequently Asked Questions’ to help us support other users. This request would have all information pertaining to you or your organisation removed so as to become a generic statement. (This data would have no bearing upon your data privacy).
• Sale or Transfer: If we're discussing selling or transferring part or all of a business, we may share information about you to prospective purchasers - but only so they can evaluate that business. If we are reorganised or sold to another organisation, we may transfer information we hold about you to them so they can continue to provide the services to you. (Under Legitimate Interest, Contractual Requirement and Legal Requirement)

Information that you choose to make public is, you guessed it, disclosed publicly. That means, of course, that information like your public profile, posts, other content that you make public on our system. Public information may also be indexed by search engines or used by third parties. Please keep all of this in mind when deciding what you would like to share.

While no online service is 100% secure, we work very hard to protect information about you against unauthorized access, use, alteration, or destruction, and take reasonable measures to do so.

To enhance the security of your account, we encourage you to observe good security best practices with your account information, such as choosing strong passwords when registering with our systems and keeping this information secret.

We employ a range of security controls throughout our organisation to ensure that we look after your personal data and protect it from loss, corruption or unauthorised access. Our Data and Information Security Policy which outlines our commitment to protecting your data can be found -->Here<--

We only retain data for as long as is necessary to satisfy the following requirements:

Contained in Legal Information: We are required to meet legal obligations in terms of retention periods for some data, such as financial records and information. Our legal requirements are predominantly financial and so we would retain this type of information for a period of 7 years after the end of the financial year in which the transaction took place. (Under Legal Requirement)

Contained in Contractual Information: Your data will be retained for the duration of your contract, as required by us to fulfil our contractual obligations. Following the end of the contract term we retain your information for a period of 5 years business analysis purposes and may use your information for up to 2 years to contact you regarding products or services related to your previous purchases with us. (Under Legitimate Interest)

Data Used for Marketing Purposes: Where data is held solely for marketing purposes then we hold this for up to 2 years of inactivity prior to destruction. (Under Legitimate Interest)

Data Used for Business Analysis: Where data is held for business analysis purposes, data is limited to only that necessary to perform the analysis. We retain business analysis data for a period of 5 years. (under Legitimate Interest)

We always aim to keep the amount of personal data we hold to a minimum and so, unless we have received a specific request from you to erase any of your data before the retention periods expire, we will destroy/erase with an expired retention period as soon as the retention period has expired.

Where data is supplied by you as a Data Controller under contractual obligations the relevant Data Processing Agreement clauses will be observed regarding data return or erasure.

You have several choices available when it comes to information about you:

Limit the Information that You Provide: If you have an account with us, you can choose not to provide the optional account information, profile information, and transaction and billing information. Please keep in mind that if you do not provide this information, certain features of our Services may not be accessible (contact us for more information).

Limit Access to Information on Your Mobile Device: Your mobile device operating system should provide you with the ability to discontinue our ability to collect stored information or location information via our mobile apps. If you do so, you may not be able to use certain features (like adding a location to a photograph, for example).

Opt-Out of Electronic Communications: You may opt out of receiving promotional messages from us. Just follow the instructions in those messages. If you opt out of promotional messages, we may still send you other messages, like those about your account and legal notices.

Change Your Cookie Settings: At this time, Safe Data Governance Limited does not respond to “do not track” signals across all of our Services. However, you have the ability to adjust the settings using the cookie manager on our website or you can choose to set your browser to remove or reject browser cookies before using Safe Data Governance Limited’s websites. The drawback with restricting certain cookies is that certain features of Safe Data Governance Limited’s websites may not function properly without the aid of cookies.

When it comes to personal data you have defined rights regarding how your data is collected, processed and shared. These rights are explained below:

The Right of Access: You have the right to request that we show you what personal data of yours we hold and process. 

The Right to Erasure: In specific circumstances, you have the right to request that any data we hold on you be erased. This includes where:

• Your personal data is no longer necessary in relation to the purpose for which it was originally collected/processed.
• You withdraw consent.
• You object to the processing and there is no overriding legitimate interest for continuing the processing.

The Right to Object: There are cases where we may process some of your data in order to help us assess and improve our business. This type of processing may not be supported by a contractual requirement or your consent, but would have been carefully assessed to ensure that we have a clear legitimate interest in doing so that does not adversely affect you as an individual.

In these instances, we make you aware of these activities along with your right to object to this kind of processing should you wish.

The Right to rectification: If you become aware that any data we hold is incorrect you have the right to request that this data be corrected

The Right to Data Portability: You have the right to request that we provide you with an electronic copy of any data you have given to us as part of a contractual relationship or following your consent. This also includes any data about you that has been generated automatically as part of these agreements.

The Right to Restrict Processing: In some situation you may require us to restrict processing, such as following an objection or if data accuracy is in question. Where you exercise your right to restrict processing we shall not recommence processing without first notifying you.

Automated Decision Making: We do not currently employ any automated decision making processes that would adversely affect you as part of the personal data processing activities we perform.

Transfer of Information outside of the EEA

We currently do not transfer any personal data outside of the EEA. 

Should this situation change you will be notified, and this Privacy Notice will be updated. If we do this your personal information will continue to be subject to one or more appropriate safeguards set out by law.  These might be the use of model contracts in a form approved by regulators, or having our suppliers sign up to an independent privacy scheme approved by regulators (like the US ‘Privacy Shield’ scheme).

In some situations, we may seek your consent prior to any data transfers and you will be informed of the reasons for the transfer and the safeguards that have been applied in order for you to make and informed decision on consent.

Ads and Analytics Services Provided by Others

Ads appearing on any of our Services may be delivered by advertising networks.

Other parties may also provide analytics services via our Services. These ad networks and analytics providers may set tracking technologies (like cookies) to collect information about your use of our Services and across other websites and online services. These technologies allow these third parties to recognize your device to compile information about you or others who use your device.

This information allows us and other companies to, among other things, analyse and track usage, determine the popularity of certain content, and deliver advertisements that may be more targeted to your interests.

Please note this Privacy Policy only covers the collection of information by Safe Data Governance Limited and does not cover the collection of information by any third-party advertisers, social media platforms or analytics providers. 

There are options you can take to prevent this level of tracking, such as turning off third party cookies in your browser or utilising custom browser add-ons, however these options are outside of the scope of this notice and we would advise properly researching these options in order to get the best possible experience from your browsing activities.

If you have any complaints about the way in which your personal data is being handled, then please contact us using the contact details below.

Alternatively, you may also contact the national supervisory authority to register a complaint, their details can be found at https://ico.org.uk