Last updated: 1 June 2020
Cirrusli Limited (“us”, “we”, or “our”) operates the Cirrusli Limited website (the “Service”).
This page informs you of our policies regarding the collection, use and disclosure of Personal Information when you use our Service.
What is the purpose of this notice?
To describe how we collect and use personal data about you in accordance with the General Data Protection Regulation (GDPR).
What we need
Cirrusli will be what’s known as the “Controller” of the personal data you provide to us. We only collect basic personal data about you which does not include any special categories of personal information about you (known as Special Category Data). This does, however, include name, address, e-mail, telephone number, financial information.
Why we need it
We need to know your basic personal data in order to provide services to you. We will not collect any personal data from you we do not need to provide and oversee this service to you.
What we do with it
We only ever use your personal data with your consent, or where it is necessary:
- to enter into, or perform, a contract with you
- to comply with a legal duty
- to protect your vital interests
- for our own (or a third party’s) lawful interests, provided your rights don’t override these.
In any event, we’ll only use your information for the purpose or purposes it was collected for (or for closely related purposes).
We may process personal information for certain legitimate business purposes, which include some or all of the following:
- where the processing enables us to enhance, modify, personalise or otherwise improve our services/communications
- for the benefit of our customers to identify and prevent fraud
- to enhance the security of our network and information systems
- to better understand how people interact with our websites
- to provide postal communications which we think will be of interest to you
- to determine the effectiveness of promotional campaigns and advertising.
Whenever we process data for these purposes we will ensure that we always keep your personal data rights in high regard and take account of these rights at all times.
When we process your personal data for our legitimate interests, we will make sure that we consider and balance any potential impact on you (both positive and negative), and your rights under data protection laws. Our legitimate business interests do not automatically override your interests – we will 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 have the right to object to this processing if you wish, and if you wish to do so please email email@example.com . Please bear in mind that if you object this may affect our ability to carry out tasks above for your benefit.
Where we keep it
We are based in the UK and we store our data within the EU. Some organisations which provide services to us may transfer personal data outside of the EU, but we will only allow them to do if your data is adequately protected.
For example, some of our systems use Microsoft products. As a US company, it may be that using their products result in personal data being transferred to or accessible from the US. However, we will allow this as we are certain personal data will still be adequately protected (as Microsoft is certified under the USA’s Privacy Shield scheme).
How long we keep it
We will only use and store information for so long as it is required for the purposes it was collected for. How long information will be stored depends on the information in question and what it is being used for. For example, if you ask us not to send you marketing e-mails, we will stop storing your e-mails for marketing purposes (though we will keep a record of your preference not to be e-mailed).
We continually review what information we hold and delete what is no longer required. We never store payment card information. We will not retain your data for any longer than necessary and the longest time that we will hold your data will be seven years, dependant on our reason for holding your personal data as identified in our specific Privacy Statements below.
What are your rights?
We want to ensure that you remain in control of your personal data. Part of this is making sure you understand your legal rights, which are as follows:
- the right to confirmation as to whether we have your personal data and, if we do, to obtain a copy of the personal information we hold (this is known as a data subject access request)
- the right to have your data erased (though this will not apply where it is necessary for us to continue to use the data for a lawful reason)
- the right to have inaccurate data rectified
- the right to object to your data being used for marketing or profiling; and
- where technically feasible, you have the right to personal data you have provided to us which we process automatically based on your consent or the performance of a contract. This information will be provided in a common electronic format.
Please keep in mind that there are exceptions to the rights above and, though we will always try to respond to your satisfaction, there may be situations where we are unable to do so.
Different ways we process data
The different data we may request, hold and process will also vary depending on the reason you have provided us with your data. For the primary categories, we have developed specific Privacy Statements that can be found at the bottom of the page. These are for:
Changes to this privacy notice
The Company reserves the right to update or amend this privacy notice at any time. We may also notify you about the processing of your personal information in other ways.
If you have any questions about this privacy notice or how we handle your personal information, please contact our data compliance manager as follows: Ann Holland, 37 Mill Street, Bideford, EX39 4BS, 01237 320262 or email firstname.lastname@example.org
If you are not satisfied with our response or believe we are processing your personal data not in accordance with the law you can complain to the Information Commissioner’s Office, the UK supervisory authority for data protection issues.
PRIVACY STATEMENT FOR CLIENTS
PURPOSE OF THIS NOTICE. This notice describes how we collect and use personal data about you, in accordance with the General Data Protection Regulation (GDPR), the Data Protection Act 2018 and any other national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK (‘Data Protection Legislation’). Please note that full details regarding our provision of services to clients will be enclosed the individual Letters of Engagement between the company and each client which are provided to the client and signed by the client prior to the provision of any services. Please read the following carefully to understand our practices regarding your personal data and how we will treat it. ABOUT US Cirrusli Limited (“we”, “us”, “our” and “ours”) is registered in England and Wales as a limited company under number: 10710481 and our registered office is at 37 Mill Street, Bideford, EX39 2JJ. For the purpose of the Data Protection Legislation and this notice, we are the ‘data controller’. This means that we are responsible for deciding how we hold and use personal data about you. We are required under the Data Protection Legislation to notify you of the information contained in this privacy notice. We have appointed a data compliance manager. Our data compliance manager is our Data Protection Point of Contact and is responsible for assisting with enquiries in relation to this privacy notice or our treatment of your personal data. Should you wish to contact our Data Protection Point of Contact you can do so using the contact details noted at paragraph 12 (Contact Us), below. HOW WE MAY COLLECT YOUR PERSONAL DATA We obtain personal data about you, for example, when: • you request a proposal from us in respect of the services we provide; • you OR your employer OR our clients engages us to provide our services and also during the provision of those services; • you contact us by email, telephone, post or social media (for example when you have a query about our services); or • from third parties and/or publicly available resources (for example, from your employer or from Companies House). THE KIND OF INFORMATION WE HOLD ABOUT YOU The information we hold about you may include the following: • your personal details (such as your name and/or address); • details of contact we have had with you in relation to the provision, or the proposed provision, of our services; • details of any services you have received from us; • our correspondence and communications with you; • information about any complaints and enquiries you make to us; • information from research, surveys, and marketing activities; • Information we receive from other sources, such as publicly available information, information provided by your employer OR our clients HOW WE USE PERSONAL DATA WE HOLD ABOUT YOU We may process your personal data for purposes necessary for the performance of our contract with you OR your employer OR our clients and to comply with our legal obligations. We may process your personal data for the purposes necessary for the performance of our contract with our clients. This may include processing your personal data where you are an employee, subcontractor, supplier or customer of our client. We may process your personal data for the purposes of our own legitimate interests provided that those interests do not override any of your own interests, rights and freedoms which require the protection of personal data. This includes processing for marketing, business development, statistical and management purposes. We may process your personal data for certain additional purposes with your consent, and in these limited circumstances where your consent is required for the processing of your personal data then you have the right to withdraw your consent to processing for such specific purposes. Please note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data. Situations in which we will use your personal data We may use your personal data in order to: • carry out our obligations arising from any agreements entered into between you OR your employer OR our clients and us (which will most usually be for the provision of our services); • carry out our obligations arising from any agreements entered into between our clients and us (which will most usually be for the provision of our services) where you may be a subcontractor, supplier or customer of our client; • provide you with information related to our services and our events and activities that you request from us or which we feel may interest you, provided you have consented to be contacted for such purposes; • seek your thoughts and opinions on the services we provide; and • notify you about any changes to our services. In some circumstances, we may anonymise or pseudonymise the personal data so that it can no longer be associated with you, in which case we may use it without further notice to you. If you refuse to provide us with certain information when requested, we may not be able to perform the contract we have entered into with you. Alternatively, we may be unable to comply with our legal or regulatory obligations. We may also process your personal data without your knowledge or consent, in accordance with this notice, where we are legally required or permitted to do so. Data retention We will only retain your personal data for as long as is necessary to fulfil the purposes for which it is collected. When assessing what retention period is appropriate for your personal data, we take into consideration: • the requirements of our business and the services provided; • any statutory or legal obligations; • the purposes for which we originally collected the personal data; • the lawful grounds on which we based our processing; • the types of personal data we have collected; • the amount and categories of your personal data; and • whether the purpose of the processing could reasonably be fulfilled by other means. • Change of purpose • Where we need to use your personal data for another reason, other than for the purpose for which we collected it, we will only use your personal data where that reason is compatible with the original purpose. Should it be necessary to use your personal data for a new purpose, we will notify you and communicate the legal basis which allows us to do so before starting any new processing. DATA SHARING Why might you share my personal data with third parties? We will share your personal data with third parties where we are required by law, where it is necessary to administer the relationship between us or where we have another legitimate interest in doing so. Which third-party service providers process my personal data? “Third parties” includes third-party service providers. The following activities are carried out by third-party service providers: IT and cloud services, professional advisory services, administration services, marketing services and banking services. All of our third-party service providers are required to take commercially reasonable and appropriate security measures to protect your personal data. We only permit our third-party service providers to process your personal data for specified purposes and in accordance with our instructions. What about other third parties? We may share your personal data with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal data with a regulator or to otherwise comply with the law. TRANSFERRING PERSONAL DATA OUTSIDE THE EUROPEAN ECONOMIC AREA (EEA) When we share data, it may be transferred to, and processed in, countries other than the UK – such as to the United States, where some third-party data hosting provider’s servers are located. These countries may have laws different to the UK. Where we disclose personal data to a third party in another country, we ensure those third parties have safeguards in place to ensure your personal data remains protected. For individuals in the European Economic Area (EEA), this means that your data may be transferred outside of the EEA. Where your personal data is transferred outside the EEA, it will only be transferred to countries that have been identified as providing adequate protection for EEA data, or to a third party where there are approved transfer mechanisms in place to protect your personal data – i.e., by entering into the European Commission’s Standard Contractual Clauses, or by ensuring the entity is Privacy Shield certified (for transfers to US-based third parties). DATA SECURITY We have put in place commercially reasonable and 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 data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so. RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RESTRICTION Your duty to inform us of changes It is important that the personal data we hold about you is accurate and current. Should your personal information change, please notify us of any changes of which we need to be made aware by contacting us, using the contact details below. Your rights in connection with personal data Under certain circumstances, by law you have the right to: • Request access to your personal data. This enables you to receive details of the personal data we hold about you and to check that we are processing it lawfully. • Request correction of the personal data that we hold about you. • 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 exercised your right to object to processing (see below). • 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 basis. You also have the right to object where we are processing your personal information for direct marketing purposes. • Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example, if you want us to establish its accuracy or the reason for processing it. • Request the transfer of your personal data to you or another data controller if the processing is based on consent, carried out by automated means and this is technically feasible. • If you want to exercise any of the above rights, please email our data protection point of contact Natalie Willan – email@example.com • 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 for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances. We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it. RIGHT TO WITHDRAW CONSENT In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose (for example, in relation to direct marketing that you have indicated you would like to receive from us), you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please email our data protection point of contact firstname.lastname@example.org Once we have received notification that you have withdrawn your consent, we will no longer process your personal information (personal data) for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law. CHANGES TO THIS NOTICE Any changes we may make to our privacy notice in the future will be updated on our website www.cirrusli.co.uk. CONTACT US If you have any questions regarding this notice or if you would like to speak to us about the manner in which we process your personal data, please contact our data compliance manager, Natalie Willan on 01237 320262 or email email@example.com. You also have the right to make a complaint to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues, at any time.