Your privacy is critically important to us. At Safe Data Governance Limited, we have a few fundamental principles:
- We limit the collection of data for specific purposes and ensure that we have legitimate and lawful grounds for processing that data.
- We store personal information for only as long as we have a reason to keep it.
- We aim to ensure that the data we hold is accurate and up to date.
- We aim for full transparency on how we gather, use, and share your personal information.
- We implement security controls specifically to protect personal and sensitive data.
Who We Are and What This Policy Covers
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.
- Using our websites (such as safedatagov.com and www.compliance-pro.co.uk)
- Using our mobile applications (including Compliance-Pro Monitor );
- Using other products and services that are available on or through our websites
- Having personal interactions via various forms of electronic messaging, voice and video communication or face to face.
- 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.
- Out of contractual necessity such as in the delivery or products or services.
- From 3rd parties with whom you have previously agreed that they can share your data with us.
Below we explain how we collect, use, and share information about you, along with the choices that you have with respect to that information.
Information We Collect
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:
- 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
- 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.
Information You Provide to Us
It’s probably no surprise that we collect information that you provide to us. The amount and type of information depends on the context and how we use the information. Here are some examples:
- Basic Online Account Information: We ask for basic information from you in order to set up your account. For example, to activate an online account we require a username and email address, and that’s it. You may provide us with more information, like your name, but we don’t require that information to create your account. (Under Contractual Necessity)
- Business Account Information: If you have a business account with us we will require certain information in order to fulfil our obligations to you. This information will include contact details such as email, phone number and mailing address for individuals associated with your account as well as account preferences and service history in order to provide you with the best service possible. (Under Contractual Necessity)
- Transaction and Billing Information:If you buy something from us, you will provide additional personal and payment information that is required to process the transaction and your payment, such as your name, credit card information, and contact information. (Under Contractual Necessity)
- Communications with us: You may also provide us information when you respond to surveys, communicate with our Helpdesk about a support question, or post a question in our public forums. (Under Legitimate Interests and Contractual Necessity)
Information We Collect Automatically
We also collect some information automatically:
Log Information: Like most online service providers, we collect information that web browsers, mobile devices, and servers typically make available, such as the browser type, IP address, unique device identifiers, language preference, referring site, the date and time of access, operating system, and mobile network information. We collect log information when you use our Services in order to assess the performance of our systems. (Under Legitimate Interests and where Contractually Required)
Usage Information: We collect information about your usage of our Services. For example, we collect information about the actions that administrators and users perform – in other words, who did what, when and to what thing on our system (e.g. User Login credentials, time stamps and activities that may be used to identify and eradicate software bugs) along with information about your device (e.g., mobile screen size, name of cellular network, and mobile device manufacturer). We use this information to, for example, provide our Services to you, as well as get insights on how people use our Services, so we can make our Services better. (Under Legitimate Interests and where Contractually Required)
Location Information: We may determine the approximate location of your device from your IP address. We collect and use this information to, for example, calculate how many people visit our Services from certain geographic regions. We may also collect information about your precise location via our mobile apps if you allow us to do so through your mobile device operating system’s permissions. (Under Legitimate Interests for marketing purposes or Consent for Mobile Devices)
Mobile Application Access to Stored Information: We may access information stored on your mobile device via our mobile app. We access this stored information through your device operating system’s permissions that we can only do if you give us permission. For example, if you give us permission to access the photographs on your mobile device’s camera roll, our Services may access the photos stored on your device in order for you to upload it to our system through the app. (Under Consent and a Contractual Requirement for us to provide this service)
Information We Collect from Other Sources
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)
How We Use Information
We use information about you as mentioned above and as follows:
- 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
- To further develop our Services – for example by adding new features that we think our users will find of benefit;
- 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;
- 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;
- 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
- To personalize your experience using our online Services, provide content recommendations and serve relevant advertisements based on your preferences.
Sharing of Personal Data
How We Share Personal Data
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:
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.
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
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)
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.
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)
Publicly Shared Information
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:
Legal: 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)
Contractual: 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)
Marketing: 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)
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.
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.
Set Your Browser to Reject Cookies: 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 how you 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: As part of our ongoing efforts to improve the speed and quality of our service we use some automated decision-making processes. These processes are designed to provide fast, consistent results based on information contained within your personal data. If you are unhappy with having automated decisions made based on your personal data then you have the right to request that these decisions are conducted by one of our staff instead.
Other Things You Should Know (Keep Reading!)
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.
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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
To contact us about your personal data, you may contact our Data Privacy Representative at:
Data Privacy Representative: