Nematrian Privacy Policy
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Privacy Policy
Nematrian Limited (company number 06908852) (and all
Trading Styles) (“we” or “us”) recognises that your privacy is important. This
Privacy Policy applies to all websites, web applications, other software and
associated services (collectively “Services”) that are provided by us, mainly
via the Nematrian website.
This Privacy Policy also applies to consultancy client
and employment-specific contracts entered into by Nematrian Limited, unless the
terms in these contracts supplement or override the contents of this Policy.
Please read this Privacy Policy carefully as once you use our Services
you will be regarded as having read and accepted this Privacy Policy. You must
not use our website or our Services if you do not accept this Privacy Policy.
If you have any questions about this Privacy Policy, please feel free to contact us by e-mailing us at ContactUs@nematrian.com or by writing to us at:
Privacy
Officer
Nematrian Limited
c/o Unit 24, Capital Business Centre
22
Carlton Road
South
Croydon
Surrey
CR2 0BS
United
Kingdom
You
are encouraged to report any improvements, suggestions or suspected breaches of
privacy or security to us by using the contact information listed above.
Information that we may collect
(i) Log information. Nematrian’s servers may automatically record some
information each time you visit our website or use some of our services, e.g.
the URL, IP address, browser type and language and the date and time of your
request.
(ii) Cookies. We may use cookies and other similar technologies to
enhance your online experience and to learn about how you use our services.
This can help us improve the quality of the services that we offer you. Cookies
are small files containing strings of characters that are sent by a website to
your computer or other device that uniquely identify your browser to the site
in question. For further information, refer to “Cookies” (below).
(iii) Information that you provide. We may collect information on you
when you register, log in to our site or at other times when you volunteer such
information. We may alter the extent of access that we give you to our Services
depending on the information you have provided us.
(iv) Links. We may present links in a format that enables us to keep
track of whether these links have been followed.
(v) Affiliates. We may provide web services that route your requests to
other companies’ software and websites and return back to you responses
received from these third-party sites and servers. These affiliates may collate
further information specific to your use of their services.
(vi) Other sites. This Policy applies to Nematrian Services only. We do
not exercise control over third party sites to which there may be links on our website.
We
may store log information as per (i) to allow us to understand better our
aggregate user base. We may also associate this information with information
that you provide as per (ii), (iii) and (iv)
If your browser permits them, we use cookies to facilitate your seamless
navigation between pages on our website. We may use cookies with defined expiry
times which may thus reside on your hard disk until you delete them. We may
associate these cookies with information collected via (i), (iii) and (iv),
bearing in mind that any particular computer, device or browser instance is not
necessarily always used by the same individual.
We may store and retain information that you provide as per (iii). This may
include answers you provide to ‘profiling’ questions if any when registering or
logging into the website and at other times.
Users wanting to store information permanently on our website and make this
information available to others generally need to provide us with an e-mail
address and potentially other “personal” information, so that we can identify
and notify them if we discover that the material they are then serving to third
parties is potentially objectionable or involves potentially inappropriate use
of other people’s intellectual property.
Pages that include Google AdSense for content ads make use of the DoubleClick
DART cookie. Data collated via this cookie may be used for various purposes by
Google, see http://www.google.com.
Other ad serving services used by our website may use similar types of cookies.
We may also use Google Analytics on our website for anonymous reporting of site
usage and for advertising on the site. If you would like to op-out of Google
Analytics monitoring your behaviour on our site the please refer to the Google
website given above.
Personal information we may collect
The
information collated as above may include “personal” information (including
“sensitive personal” information). “Personal information” is information that
you provide us which personally identifies you, such as your name, e-mail
address, telephone number or billing information, or other data which can
reasonably be linked to such information by us.
For example, if you decide to create an account or enquire about one or more of
our services then we may ask you to provide us with specific information such
as:
-
Basic personal details, such as name,
title and date of birth
-
Personal contact details, such as
home address, home e-mail address, phone number and mobile phone number
-
Work details, such as job title,
department, company name and address, work e-mail address, phone number and
mobile phone number
-
Log-in details, such as username and
password
-
Payment details, if applicable
-
Your opinion of our products and
services and how you prefer to receive them
Lawful basis for processing personal information
We
only process personal information where we have a lawful basis for doing so,
such as:
-
User consent. This is where you have given us explicit permission to
process personal information for a given purpose. You have the right to
withdraw this consent at any time. You can manage your preferences within your
account or by contacting us using the contact details given at the start of
this Policy.
-
Legitimate business purposes. This is where we have a legitimate business interest to
process personal information. For example, where we are aware of copyright
infringements on our website, it is in our legitimate business interest to
identify those responsible so that we can meet obligations imposed on us.
-
Contractual necessity. This is where we need to process personal information
to meet our contractual obligations. For example, when we have a contract to
provide you with a Service and we need to e-mail you a message as part of this
Service then the act of e-mailing you involves processing your information.
-
Legal obligation. This is where we need to process your personal
information to comply with law or regulation.
How we use your personal information
We
use personal information for the following main reasons:
1.
To provide our Services
2.
To improve and maintain performance
3.
To bill our customers
4.
To monitor compliance with terms and
policies to which our contracts are subject
5.
To personalise our Services
6.
To communicate changes to Services
and offers of new Services
7.
For advertising purposes
8.
For recruitment and other human
resources purposes
Who we share your personal information with
We,
and our advertising partners, use cookies to collect personal information and
serve you with advertisements that we believe are relevant to you and your
interests.
Our
website is publicly accessible and anyone around the world who accesses it will
be able to see anything that you post onto it. We encourage you to use a
pseudonym when commenting on our website if you do not wish to be identifiable
to others.
We
may disclose your information to comply with applicable laws, court orders or
other valid legal processes, and to enforce or apply our terms of use or any of
our other rights.
Should
we set up wholly or largely owned subsidiaries then the privacy policy set out
above will apply to the Nematrian group collectively. We may transfer or
disclose your personal information to any entity which takes over or acquires a
Nematrian business.
We
may share aggregated, non-identifiable information with third parties. Before
sharing any such information, we will ensure that it cannot identify you as an
individual.
We
may also disclose your personal data to third-party service providers, e.g. payroll
service providers. The identity and categories of such service providers may
change during the lifetime of your account. We require that our third-party
service providers only use your personal data as necessary to provide the
requested services to us. Each service provider is subject to a set of terms
consistent with this Privacy Policy. Some of our third-party service providers,
e.g. cloud storage providers, may be located outside the EEA. Where this is the
case, we will take steps to ensure as far as possible that the service
providers cannot access your personal information (e.g. it is suitably
encrypted) or if they can that your privacy rights continue to be protected as
outlined in this Policy.
The
extent to which we share information about our own employees (e.g. roles,
contact telephone numbers) will be as agreed with the relevant employee.
How long we retain your personal information
Unless
a longer retention period is required by applicable lay, we will retain your
personal information for the longer of the time your account is active or 7
years (and for a short time afterwards to cover any outstanding issues or
queries that may arise in relation to your account), or for a shorter period if
our lawful basis for processing your personal information has expired before
then. This period of retention is subject to review and alteration.
Information that others may collect via your use of our
website
If a webpage that you visit includes third party advertisements then third
parties may be placing and reading cookies on your browser or using web beacons
to collect information as a result of ad serving on our website.
Your Rights
Under data protection laws, you have rights as an individual in relation to the
personal data we hold about you. These rights include:
-
The right to object to direct
marketing
-
The right to access the personal data
that we process about you
-
The right to request the deletion of
your personal data
-
The right to request the
rectification of your personal data
-
The right to be informed about how we
use your personal data
-
The right not to be subject to any
decision based solely on automated processing of your data
-
The right to restrict the use of your
personal data, e.g. because it is not accurate, it has been used unlawfully but
you don’t want us to delete it or it is not relevant anymore but you want us to
keep it for use in legal claims
You
can exercise these rights through your account or by contacting us using the
contact details given at the start of this Policy. You may in limited
circumstances have the right to receive your personal data in a format that can
be transmitted to another entity.
You
also have the right to lodge a complaint with a supervisory authority. In the
UK, this is the Information Commissioner’s Office (ICO). Information about how
to do this is currently available on their website at www.ico.org.uk or by
calling their helpline on 0303-123-1113.
Uses
We may use information on you collated as above to provide the services you
have requested, and to provide services that display customised content and
advertising.
We may also use such information for auditing, research and analysis to operate
and improve Nematrian technologies and services.
If you have indicated that you are happy for us to do so, we may share
information on you with selected third parties and/or use this information to
provide you with marketing communications. You will have been given the
opportunity to indicate the means of communication (if any) you wish us to use
for this purpose. You can withdraw your consent or object to marketing from us
at any time, by unsubscribing from an e-mail you receive from us that contains
an ‘unsubscribe’ link, updating your account preferences or contacting us as
set out at the start of this policy.
We may share “aggregated non-personal information” with third parties outside
Nematrian. “Aggregated non-personal information” means information that groups
together users and their site usage characteristics according to user
characteristics, but does not reveal individual Users or User ID’s (or provide
such a high level of granularity that others can infer with a reasonable
likelihood who might be the specific individual in question).
We may also share your personal information with suitably authorised
representatives of law enforcement agencies or financial regulatory bodies, if
reasonably requested to do so, and with others if required by law to do so. In
this context, please bear in mind that we may process personal information on
servers in different countries and may therefore be required to submit to
requests for such information that might deemed appropriate in some
jurisdictions but not in others. Please also bear in mind that as a result of
anti-terrorism, crime and money laundering legislation, we may be required by
law to obtain satisfactory evidence of the identity of our customers. We may
also be obliged to disclose knowledge or suspicion of money laundering or
terrorist activities or dealing with proceeds of crime and in particular
circumstances that obligation will override other duties of confidentiality we
might implicitly or expressly be subject to. Moreover, we may not be permitted
to inform our customers that we have made such a disclosure or the reasons for
it.
Choices
You may decline to provide personal information to us and/or refuse cookies in
your browser, although some of the features of our services may not function
properly as a result, or the quality of service you may receive may be
diminished in some other way.
We will not collect or use "sensitive personal" information for
purposes other than those described in this Privacy Policy and/or in
supplementary notices, unless we have obtained your prior consent.
"Sensitive personal" information includes information we know to be
related to confidential medical information, racial or ethnic origins,
political or religious beliefs or sexuality and tied to personal information.
Third party providers and data privacy
If you decide to enter into a contract with a third party provider through a
channel on our website, the information you have provided to the third party
provider may be held by the provider for the purposes set out in that
provider's privacy policy. Therefore, you are strongly advised to read your
chosen provider's privacy policy and satisfy yourself as to the purposes for
which the provider will use your personal information before entering into the
contract. We have no responsibility for the uses to which a provider puts your
personal information once you have contracted with that provider.
Advertisements
The advertisements that you see displayed on this website may be delivered on
our behalf by a third-party advertising company. In such circumstances, no
personal information will be used during the course of serving these
advertising unless you have separately supplied such information to the
third-party advertiser. However, on our behalf, such a third-party advertiser
may place or recognize a unique cookie on your browser.
Security
Keeping information about you secure is very important to us. We take
appropriate measures to ensure your personal information is kept secure,
accurate, up-to-date, only for as long as necessary, and only used for the
purpose(s) it was originally captured/processed for.
However,
no data transmission over the internet can be guaranteed to be totally secure.
As a result, whilst we strive to protect your personal information, we cannot
ensure or warrant the security of any information which you send to us, and you
do so at your own risk. If during log-in you are redirected to a secure
Nematrian server (referenced by ‘https’ in the browser address field) then,
where practical, your subsequent interaction with that server during the same
site session, including transfer of sensitive information if any, will be
encrypted until you log out, to minimise the risk of interception during
transit.
Our
security practices, processes or technology do not guarantee absolute security
of your information and you should take all normal personal precautions such
as, but not limited to, not sharing passwords, not reusing passwords on
multiple sites, closing browsers and not using public networks (e.g. internet
cafes, etc.) when transmitting sensitive information.
Cookies
A cookie is a small text file placed on your computer by a web browser, which
has been sent by a web server. It is essentially an ‘identification card’
relating to you. The main purpose of our cookies is to identify you when you
visit our website. Each time your browser requests a web page from our server,
the browser sends the information in the text file back to the server and lets
the server know that you have returned to that web page. If you do not accept
incoming cookies then the performance of our website on your system will not be
to full standard or our website may not serve at all.
Sensitive Personal Information and information from
children under the age of 13
We
do not knowingly collect sensitive personal information (sometimes referred to
as special categories of personal data) except where we need to do so for
employment purposes. Legal grounds that would allow us to process your
sensitive personal information include:
-
When we obtain your explicit consent
to do so
-
When the processing is necessary for
carrying out our obligations under employment, social security or social
protection law
-
When processing is necessary for
reasons of substantial public interest
We
do not knowingly collect any form of personal data from children under the age
of 13. Where user consent is needed from such an individual, it typically needs
to be provided by someone exercising parental responsibility for that child.
Changes to our Privacy Policy
We
keep our Privacy Policy under review and we will place any updates to it
on our website.
Version Dated 24 May 2018