1.1 Synectics plc and its subsidiary companies (“we”, “us”, “our”, the “Group”) are classed as data controllers. This means that as well as being committed to protecting the privacy and security of personal data, we are also responsible for deciding how we hold and use it.
1.2 We are required under data protection legislation to explain how we collect and use personal data and have opted to do this via this privacy notice (“Notice”).
1.3 It is important that you read this Notice as it explains how and why your personal data will be used and how long it will be retained for. It also provides you with certain information that must be provided under data protection legislation. If you have any queries or if you want to raise an objection to something in this Notice, please feel free to contact us using the details below.
You are entitled to object to us processing your personal data, in the ways summarised in this Notice. However, if you fail to provide personal data when requested by us, we may not be able to perform the contract with you or may have to cancel a product or service you have with us.
2. Data protection principles
2.1 We will comply with data protection law and principles, which means that your personal data will be:
2.1.1 used lawfully, fairly and in a transparent way;
2.1.2 collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes;
2.1.3 relevant to the purposes we have told you about and limited only to those purposes;
2.1.4 accurate and kept up to date;
2.1.5 kept only as long as necessary for the purposes we have told you about, and
2.1.6 kept securely.
3. What personal information do we hold about you?
3.1 Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). There are “special categories” of more sensitive personal data which require a higher level of protection.
3.2 We may collect, use, store and transfer different kinds of personal information about you which we have grouped together as follows:
3.2.1 Identity data which may include your first name, last name, a profile username, or date of birth;
3.2.2 Contact data which may include your email address, postal address or contact telephone number;
3.2.3 Technical data which may include your internet protocol (IP) address, 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 our website;
3.2.4 Profile data which may include a username and password;
3.2.5 Usage data which may include information about how you use our website, products and services;
3.2.6 Marketing and communications data which includes your preferences in receiving marketing from us and our third parties and your communication preferences.
3.2.7 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. For example, we may aggregate your Usage data to calculate the percentage of users accessing a specific website page. However, if we combine or connect Aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Notice.
3.3 We do not collect 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.
4. If you fail to provide personal information
4.1 Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
5. How do we collect your personal information?
5.1 We use different methods to collect data from and about you. For example:
5.1.1 Direct interactions with you: you may provide us with your personal information by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
184.108.40.206 subscribe to our service or publications;
220.127.116.11 request marketing to be sent to you;
18.104.22.168 enter a competition, promotion or survey; or
22.214.171.124 give us some feedback;
5.1.3 Third parties or publicly available sources: we may receive personal data about you from various third parties;
126.96.36.199 Technical data from the following parties:
• analytics providers such as Google based outside the EU; and
• search information providers such as Google based inside the EU;
188.8.131.52 Contact and Transaction data from providers of technical, payment and delivery services based inside the EU; and
184.108.40.206 Identity and Contact data from third party sources (for example Companies House).
6. How will we use information about you?
6.1 We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
6.1.1 Where we need to perform the contract we are about to enter into or have entered into with you;
6.1.2 Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; and
6.1.3 Where we need to comply with a legal or regulatory obligation.
6.2 We do not, at any time, sell personal data.
6.3 Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time. To do this, please contact our Data Protection Officer (details below).
6.4 We have set out below, in a table format, a description of all the ways we may use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
6.5 Please note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as a new customer||(a) Identity
|Performance of a contract with you|
To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey
(d) Marketing and Communications
|(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
|To enable you to complete a survey||a) Identity
(e) Marketing and Communications
(a) Performance of a contract with you
(b) 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 this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity
(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 and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||(a) Identity
(e) Marketing and Communications
|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
|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 about goods or services that may be of interest to you||(a) Identity
|Necessary for our legitimate interests (to develop our products/services and grow our business)|
Change of purpose
6.5 We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note however, that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Third party marketing
6.6 We will get your express opt-in consent before we share your personal data with any company outside the Group for marketing purposes.
6.7 You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you.
6.9 You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.
7. Data sharing – who do we share your information with?
7.1. We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 6 above;
7.1.1. Internal Third Parties as set out in part 10 (Glossary);
7.1.2. External Third Parties as set out in part 10 (Glossary);
7.1.3. Specific third parties such as Google; and
7.1.4. Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets.
7.2. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Notice.
7.3. 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.
International data transfers
7.4 Sometimes it may be necessary to transfer some of your personal information to countries outside the European Economic Area (EEA). To ensure that your personal information does receive an adequate level of protection we implemented safeguards to ensure an adequate level of data protection where your information is transferred to countries outside the EEA, such as standard contractual clauses for the transfer of personal information as approved by the European Commission and we also have the ability to conduct a risk assessment prior to sending any personal information to them.
8. Data security – how will we keep your information safe?
8.1 We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need-to-know. They will only process your personal information on our instructions, and they are subject to a duty of confidentiality.
8.2 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.
9. Data retention – how long will you use my information for?
9.1 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.
9.2 Generally 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.
10. What rights do you have over your information?
10.1 Under certain circumstances you have the right to:
10.1.1 request access to your personal information (commonly known as a “subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it;
10.1.2 request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected;
10.1.3 request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below);
10.1.4 object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes;
10.1.5 request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it; and / or
10.1.6 request the transfer of your personal information to another party.
10.2 If you want exercise any of the above rights, please contact the Data Protection Officer (details below).
11. Data Protection Officer
11.1 If you have any questions about this Notice or how we handle your personal information, please contact the Group’s Data Protection Officer as follows:
Data Protection Officer
3-4 Broadfield Close
S8 0XN By email: firstname.lastname@example.org
12.1 You also have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues at www.ico.org.uk or your country’s data protection body.
13.1 The following words and / or phrases used in this Policy shall have the following meanings;
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 other companies in the Group who are based in Germany, The United States of America, Macau or Singapore.
External Third Parties means (i) professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services and / or (ii) HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers who require reporting of processing activities in certain circumstances.