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Privacy policy

Introduction

We are committed to safeguarding the privacy of our website visitors and service users.

This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.

We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website and services, we will ask you to consent to our use of cookies when you first visit our website.

In this policy, “we”, “us” and “our” refer to Cohort Software Ltd.

This website is owned and operated by Cohort Software Ltd.

We are registered in England and Wales under registration number 07946943, and our registered office is at Eleven Brindleyplace, 2 Brunswick Square, Birmingham, B1 2LP.

In this Section we have set out:

  • the general categories of personal data that we may process;
  • in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
  • the purposes for which we may process personal data; and
  • the legal bases of the processing.

We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

In addition to the specific purposes for which we may process your personal data set out in this Section, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

Please do not supply any other person’s personal data to us, unless we prompt you to do so.

Data Type & Purpose

Personal Data

Source

Legal Basis

Data Type & Purpose

usage data operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you

Personal Data

IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use

Source

our analytics tracking system

Legal Basis

our legitimate interests, namely the monitoring and improving our website and services

Data Type & Purpose

account data operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you

Personal Data

name and email address

Source

you or your employer

Legal Basis

our legitimate interests, namely the proper administration of our website and business

Data Type & Purpose

profile data for the purposes of enabling and monitoring your use of our website and services

Personal Data

name and email address

Source

you or your employer

Legal Basis

our legitimate interests, namely the proper administration of our website and business

Data Type & Purpose

service data for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you

Personal Data

Name, address, telephone number and email address

Source

you or your employer

Legal Basis

our legitimate interests, namely the proper administration of our website and business

Data Type & Purpose

publication data for the purposes of enabling such publication and administering our website and services

Personal Data

Name, address, telephone number and email address

Source

you or your employer

Legal Basis

consent

Data Type & Purpose

enquiry data for the purposes of offering, marketing and selling relevant goods and/or services to you

Personal Data

Name, address, telephone number and email address

Source

you or your employer

Legal Basis

consent

Data Type & Purpose

customer relationship data purposes of managing our relationships with customers, communicating with customers, keeping records of those communications and promoting our products and services to customers

Personal Data

your name, your employer, your job title or role, your contact details, and information contained in communications between us and you or your employer

Source

you or your employer

Legal Basis

legitimate interests, namely the proper management of our customer relationships

Data Type & Purpose

notification data for the purposes of sending you the relevant notifications and/or newsletters

Personal Data

Name, and email address

Source

you or your employer

Legal Basis

Consent OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract

Data Type & Purpose

correspondence data for the purposes of communicating with you and record-keeping

Personal Data

the communication content and metadata associated with the communication

Source

Our website will generate the metadata associated with communications made using the website contact forms

Legal Basis

our legitimate interests, namely the proper administration of our website and business

We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy. Information about our group of companies can be found at Cority Group.

  • We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
  • We may disclose normal personal data to our suppliers or subcontractors insofar as reasonably necessary for the performance of a contract.
  • In addition to the specific disclosures of personal data set out in this Section, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

In this Section, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).

  • We and our other group companies have offices and facilities in Canada, Australia. The European Commission has made an “adequacy decision” with respect to the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission, a copy of which can be obtained from our Data Protection Officer (DPO).
  • The hosting facilities for our website are situated in United Kingdom.
  • You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

This Section sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

  • Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
  • We will retain your personal data as follows:

Personal Data Category

Retention Period

Personal Data Category

General personal data which include your normal personal data and personal identity data

Retention Period

3 years after the end of our relationship with you

Personal Data Category

Special categories of personal data relating to you or your employees

Retention Period

Up until you tell us that you no longer want us to retain the data or Until the end of our relationship with you
  • In some cases, it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:
  • Notwithstanding the other provisions of this Section, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
  • For users that register on our website, we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.
  • We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.
  • We will store all your personal data on secure servers, personal computers and mobile devices, and in secure manual record-keeping systems.
  • You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
  • You should ensure that your password is not susceptible to being guessed, whether by a person or a computer program. You are responsible for keeping the password you use for accessing our website confidential and we will not ask you for your password (except when you log in to our website).
  • For more information about our technical and organisational measures see Awards & Accreditations

In this Section, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

Your principal rights under data protection law are:

  1. the right to access;
  2. the right to rectification;
  3. the right to erasure;
  4. the right to restrict processing;
  5. the right to object to processing;
  6. the right to data portability;
  7. the right to complain to a supervisory authority; and
  • the right to withdraw consent.
  • You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee
  • You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
  • In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary:[for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
  • In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful, but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
  • You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
  • You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
  • You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
  • To the extent that the legal basis for our processing of your personal data is:
    • consent; or
    • that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,
  • and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
  • If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
  • To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
  • You may exercise any of your rights in relation to your personal data by written notice to us.

Our website includes hyperlinks to, and details of, third party websites.

We have no control over, and are not responsible for, the privacy policies and practices of third parties.

Our website and services are targeted at persons over the age of 18.

If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.

Please let us know if the personal information that we hold about you needs to be corrected or updated.

In respect of data processed on behalf of our clients, we do not act as a data controller; instead, we act as a data processor.

Insofar as we act as a data processor rather than a data controller, this policy shall not apply. Our legal obligations as a data processor are instead set out in the contract between us and the relevant data controller.

Our principal place of business is at:

Eleven Brindleyplace
2 Brunswick Square, Brindleyplace
Birmingham, B1 2LP

You can contact us:

  • by post, to the postal address given above;
  • using our website contact form;
  • by telephone, on the contact number published on our website.

Our Data Protection Officer is Richard Hanson. You can contact him at email or via our postal address listed above. Please mark the envelope ‘Data Protection Officer’.

We are registered as a data controller with the UK Information Commissioner’s Office.

Our data protection registration number is Z3080617

We keep our privacy policy under regular review. Last update was on 25th May 2018.

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