- Important information and who we are
- Data we collect about you
- How we collect data
- How we use your data
- Disclosures of your personal data
- International Transfers
- Data Security
- Data Retention
- Your legal rights
1. Important information and who we are
For the purpose of the applicable data protection legislation (meaning, prior to 25 May 2018 the Data Protection Act 1998 and from 25 May 2018 the General Data Protection Regulation and any legislation which implements it) (the “Data Protection Legislation”), the data controller is Sigma-HSE of Unit 2, Point, Moorside, Moorside Rd, Winchester SO23 7RX.
2. Data we collect about you
We may collect and process the following personal data about you:
Identity Data includes first name, middle name, last name, username or similar identifier.
Contact Data includes email address.
Financial Data includes bank account and payment card details.
Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
Technical Data includes 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 this website.
Usage Data includes information about how you use our website.
Profile Data includes your interests, feedback and survey responses.usage data, interests, preferences, feedback and survey responses.
Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity.
We do not collect or have access to 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.
3. How we collect data
Information you give us. You may give us information about you when you register with our website or by communicating with us by phone, email or otherwise. This also includes information you provide when you subscribe to our services, provide us with feedback, participate in surveys, and when you report a problem with our website. The information you give us may include your name, address, email address, phone number, job title and company information. If you engage with us through social media then this may also include your social media contact details, such as your LinkedIn, Facebook, YouTube address or Twitter username.
Information we collect about you when you communicate with us by phone, email, in person when you use our products and services. We collect engagement metric information such as information about how, when and how often you contacted us, and how, when and how often you responded to communications from us and about how and when you use our products and services.
Information we collect about you if you use our website or interact with us over the internet, including via social media. Each time you visit our website or interact with us we may automatically collect the following information: (a) technical information, including the Internet protocol (IP) address used to connect your device to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; (b) information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our website (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.
Information we receive from other sources. We may receive further information about you if you use any of the services we provide. We work closely with third parties (including, for example, business partners, service providers, identity verification providers) and may receive information about you from them. We may combine information we receive from these other sources with information you give to us and information we collect about you.
4. How we use your personal data
|Purpose/Activity||TYPE OF DATA||Lawful basis for processing including basis of legitimate interest|
|To register you or your organisation as a new customer||(a) Identity (b) Contact||Performance of a contract with you (if our contract is with you).|
|To process and deliver the products and/or services you or your organisation have requested including: (a) Managing payments, fees and charges (b) Collecting and recovering money owed to us||(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications||(a) Performance of a contract with you (if our contract is with you) (b) Necessary for our legitimate interests (to recover debts due to us)|
|To enable you to complete a survey||(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications||Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)|
|To administer and protect our business and our websites (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity (b) Contact (c) Technical||(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation|
|To deliver relevant website content to you and measure or understand the effectiveness of the advertising we serve to you or your organisation||(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical||Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences||(a) Technical (b) Usage||Necessary for our legitimate interests (to define types of customers for our products and 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 or your organisation about products or services that may be of interest to you or your organisation||(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile||Necessary for our legitimate interests (to develop our products/services and grow our business)|
|To provide the products and/or services you have requested from Sigma-HSE’s clients where our clients have engaged us to provide these on their behalf||(a) Identity (b) Contact (c) Financial (d) Transaction (e) Technical (f) Usage (g) Profile||(a) Consent (b) Necessary for our legitimate interests (to provide our products and services to our clients)|
5. Disclosures of your personal data
We work with third party service providers who provide email hosting, core corporate applications, web hosting, maintenance, and other services for us. These third parties may have access to, or process Personal Data or Client Data as part of providing those services for us. We limit the information provided to these service providers to that which is reasonably necessary for them to perform their functions, and our contracts with them require them to maintain the confidentiality of such information.
Service providers include:
These third parties include but are not limited to Facebook AdsManager, Google Ads, LinkedIn Ads, Twitter Ads, Hubspot and Lead Forensics. Please contact us for a full list of third parties that we may share your personal data with. Sharing data with them is necessary for our legitimate interests (to develop our products/services and grow our business). In cases where the transferred data is processed outside of the UK and/or the EEA, the companies, which process the data have entered into the European Commission approved Standard Contractual Clauses (available at:).[a]
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. We review the 3rd parties we use as data processors regularly and we may change them if their service is no longer satisfactory to our business.
6. International transfers
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. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries
- Where we transfer your personal data to any country not deemed by the European Commission to provide an adequate level of protection for personal data, we 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.
Please Contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
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, 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.
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.
8. Data retention - How long will you use my 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.
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see below to find out more about these rights:
1.Request access to your personal data.
2. Request correction of your personal data
3. Request erasure of your personal data
4. Object to processing of your personal data
5. Restriction of processing your personal data
6. Request transfer of your personal data
7. Right to withdraw consent
If you wish to exercise any of the rights set out above, please Contact us at [email protected].
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 may refuse to comply with your request in these circumstances.
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.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may 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.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product 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 for 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). 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.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Internal Third Parties means those companies that are either (i) within our group of companies or (ii) under common control with us. We have signed NDA/Data Processing Agreements in place with these entities for when they process data on our behalf.
External Third Parties means service providers acting as processors based in the UK and/or USA who provide IT and system administration services on our behalf.
Your legal rights
You have the right to:
- Request access to your personal data (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.
- Request correction of the personal data that we hold about you. This enables you to 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. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. 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. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of 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. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, 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. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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 (d) 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 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. 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.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, 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 products or services to you. We will advise you if this is the case at the time you withdraw your consent.