- General 1.1 Invenica Ltd (“we”, “us” or “Invenica”) take the privacy of your information very seriously. Our Privacy Notice is designed to tell you about our practices regarding the collection, use and disclosure of personal information which may be provided to us through our websites or collected through other means such as in person by us, by an online form, email, or telephone communication. 1.2 This notice applies to personal information provided by our customers and their authorised users and affiliated individuals. In this notice “you” refers to any individual whose personal data we hold or process (i.e: to you as an individual user, customer, or potential customer, or to you as an individual affiliated with one of our users, customers, or potential customers). 1.3 In general, our services are limited to the provision of telecoms services and we do not process personal data on a large scale, but we will hold certain data in relation to individual users and customers and individuals affiliated with our users or customers, and this notice sets out the basis on which we hold that data. 1.4 This notice is governed by the EU General Data Protection Regulation (the “GDPR”) from 25 May 2018.
- Legal Basis on which we process personal data 2.1 Personal data we hold about you will be processed either because: 2.1.1 the processing is necessary in order for us to comply with our obligations under a contract between you and us, specifically for the provision of our services; or 2.1.2 the processing is necessary in pursuit of a “legitimate interest”, a legitimate interest in this context means a valid interest we have or a third party has in processing your personal data which is not overridden by your interests in data privacy and security.
- Personal data we collect 3.1 We may collect and process the following personal data (information that can be uniquely identified with you) about you: 3.1.1 for individuals associated with our customers we may hold contact information such as names, email addresses, phone numbers, addresses, and job titles and/or specific roles within your organisation (“Customer Contact Information”); 3.1.2 for individuals associated with our suppliers and other third parties we interact with we may hold contact information such as names, email addresses, phone numbers, addresses, and job titles and/or specific roles within your organisation (“Third Party Contact Information”); 3.1.3 a record of any correspondence or communication between you and us and any information we may require from you when you report a problem or submit a complaint (“Communication Information”); 3.1.4 marketing information we may hold about you in order to provide information about our services this may include names, email addresses, phone numbers, addresses, and job titles and/or specific roles within your organisation (“Marketing Information”). 3.2 We will collect information either from you directly or from a third party (for instance your employer or an introducer). If we do obtain your personal data from a third party your privacy rights under this notice are not affected and you are still able to exercise the rights contained within this notice. 3.3 You do not have to supply any personal information to us in practice we may be unable to provide our services to you without personal data (for instance we will need contact information in order to communicate with you). You may withdraw our authority to process your personal data (or request that we restrict our processing) at any time but there are circumstances in which we may need to continue to process personal data (please see below).
- How we process your personal data 4.1 Please see the table below, which sets out the manner in which we will process the different types of personal data we hold:
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|When we are setting up an account with a customer or potential customer with whom you are associated or entering into an agreement to provide services to our customer.||Customer Contact Information Communication Information||Performance of a contract with you Necessary for our legitimate interests (to establish necessary information about you in order to provide our services)|
|When we communicate with you as an individual affiliated with our, customers, or potential customers in order to provide our services to you.||Customer Contact Information Communication Information||Performance of a contract with you Necessary for our legitimate interests (in order to deliver our services).|
|When we enter into an agreement with you or an organisation with which you are connected as a supplier.||Third Party Contact Information Communication Information.||Performance of a contract with you Necessary for our legitimate interests (in order to deliver our services).|
|When we communicate with you as an individual affiliated with our supplier or another third party we interact with.||Third Party Contact Information Communication Information||Performance of a contract with you Necessary for our legitimate interests (in order to deliver our services).|
|When we communicate with you, or you as an individual affiliated with our users, customers, or potential customers, about our services (for instance if you request support or make a complaint).||Customer Contact Information Communication Information||Performance of a contract with you Necessary for our legitimate interests (for running our business and to provide you with our Service)|
|To manage our relationship with you.||Customer Contact Information Communication Information||Performance of a contract with you Necessary to comply with a legal obligation Necessary for our legitimate interests|
|To administer and protect our business, including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data||Customer Contact Information Third Party Contact Information Communication Information||Necessary for our legitimate interests (for running our business, provision of administration services, network security, to prevent fraud and in the context of a business reorganisation) Necessary to comply with a legal obligation|
|To store your contact information for marketing purposes and sending marketing and other promotional communications to you.||Customer Contact Information Marketing Information||Necessary for our legitimate interests in promoting our services to business customers.|
- Data Retention 5.1 Our current data retention policy is to delete or destroy (to the extent we are able to) the personal data we hold about you in accordance with the following:
|Category of personal data||Length of retention|
|Records relevant for tax and customs authorities||8 years from the end of the year to which the records relate|
|Personal data processed in relation to a contract between you and us||7 years from either the end of the contract or the date you last used our Service, being the length of time following a breach of contract in which you are entitled to make a legal claim|
|Personal data held on marketing or business development records||3 years from the last date on which a data subject has interacted with us|
- Sharing your information 6.1 We do not disclose any information you provide to any third parties other than as follows: 6.1.1 if we are under a duty to disclose or share your personal data in order to comply with any legal obligation (for example, if required to do so by a court order or for the purposes of prevention of fraud or other crime); 6.1.2 in order to enforce any terms and conditions or agreements for our services that may apply; 6.1.3 If we are sub-contracting services to a third party we may provide information to that third party in order to provide the relevant services; 6.1.4 we may transfer your personal information to a third party as part of a sale of some or all of our business and assets to any third party or as part of any business restructuring or reorganisation, but we will take steps with the aim of ensuring that your privacy rights continue to be protected; 6.1.5 to protect our rights, property and safety, or the rights, property and safety of our users or any other third parties. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction. 6.2 Other than as set out above, we shall not disclose any of your personal information unless you give us permission to do so. If we do supply your personal information to a third party we will take steps to ensure that your privacy rights are protected and that third party complies with the terms of this notice.
- Security 7.1 We will take all reasonable steps to ensure that appropriate technical and organisational measures are carried out in order to safeguard the information we collect from you and protect against unlawful access and accidental loss or damage. These measures may include (as necessary): 7.1.1 protecting our servers with software firewalls; 7.1.2 locating our data processing storage facilities in secure locations; 7.1.3 encrypting all data stored on our server with an industry standard encryption method that encrypts the data between your computer and our server so that in the event of your network being insecure no data is passed in a format that could easily be deciphered; 7.1.4 when necessary, disposing of or deleting your data so it is done so securely; 7.1.5 regularly backing up and encrypting all data we hold. 7.2 We will ensure that our employees are aware of their privacy and data security obligations. We will take reasonable steps to ensure that the employees of third parties working on our behalf are aware of their privacy and data security obligations. 7.3 This notice and our procedures for handling personal data will be reviewed as necessary. 7.4 Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the Site; any transmission is at your own risk. Once we have received your information, we will use the strict procedures and security features referred to in this clause to try to prevent unauthorised access.
- Your privacy rights 8.1 The GDPR gives you the following rights in respect of personal data we hold about you:
|The right to be informed||You have a right to know about our personal data protection and data processing activities, details of which are contained in this notice.|
|The right of access||You can make what is known as a Subject Access Request (“SAR”) to request information about the personal data we hold about you (free of charge, save for reasonable expenses for repeat requests). If you wish to make a SAR please contact us as described below.|
|The right to correction||Please inform us if information we hold about you is incomplete or inaccurate in any way and we will update our records as soon as possible, but in any event within one month. We will take reasonable steps to communicate the change to any third parties to whom we have passed the same information.|
|The right to erasure (the ‘right to be forgotten’)||Please notify us if you no longer wish us to hold personal data about you (although in practice it is not possible to provide our services without holding your personal data and we may need to keep your data in some circumstances). Unless we have reasonable grounds to refuse the erasure, on receipt of such a request we will securely delete the personal data in question within one month. The data may continue to exist in certain backup, but we will take steps to ensure that it will not be accessible. We will communicate the erasure to any third parties to whom we have passed the same information.|
|The right to restrict processing||You can request that we no longer process your personal data in certain ways, whilst not requiring us to delete the same data. However again, some of our Services will not be available if processing is restricted.|
|The right to data portability||You have right to receive copies of personal data we hold about you in a commonly used and easily storable format (please let us know a format which suits you). You may also request that we transfer your personal data directly to third party (where technically possible).|
|The right to object||Unless we have overriding legitimate grounds for such processing, you may object to us using your personal data for direct marketing purposes (including profiling) or for research or statistical purposes. Please notify your objection to us and we will gladly cease such processing.|
|Rights with respect to automated decision-making and profiling||You have a right not to be subject to automated decision-making (including profiling) when those decisions have a legal (or similarly significant effect) on you. You are not entitled to this right when the automated processing is necessary for us to perform our obligations under a contract with you, it is permitted by law, or if you have given your explicit consent.|
|Right to withdraw consent||If we are relying on your consent as the basis on which we are processing your personal data, you have the right to withdraw your consent at any time. Even if you have not expressly given your consent to our processing, you also have the right to object (see above).|
- Data Breaches 9.1 If personal data we hold about you is subject to a breach or unauthorised disclosure or access, we will report this to the Information Commissioner’s Office (ICO) and/or our data protection manager. 9.2 If a breach is likely to result in a risk to your data rights and freedoms, we will notify you as soon as possible.
- Other websites 10.1 Our Service may contain links and references to other websites. Please be aware that this notice does not apply to those websites. 10.2 We cannot be responsible for the privacy policies and practices of sites that are not operated by us, even if you access them via the Site, our Portal, or any other service that is operated by us. We recommend that you check the policy of each site you visit and contact its owner or operator if you have any concerns or questions. 10.3 In addition, if you came to this Service via a third-party site, we cannot be responsible for the privacy policies and practices of the owners or operators of that third-party site and recommend that you check the policy of that third party site and contact its owner or operator if you have any concerns or questions.
- Transferring your information outside Europe 11.1 As part of the Service offered to you the information you provide to us may be transferred to, processed and stored at, countries or international organisations outside of the EEA. 11.2 If we transfer your information outside of the EEA, and the third country or international organisation in question has not been deemed by the EU Commission to have adequate data protection laws, we will provide appropriate safeguards and we will be responsible for ensuring your privacy rights continue to be protected as outlined in this notice. In particular we will ensure that there is an contract in place with our partners to ensure that your data is processed in accordance with this notice. 11.3 If you contact us while you are outside the EEA, your information may be transferred outside the EEA in order to communicate with you. 11.4 By submitting your personal information to us you agree to the transfer, storing or processing of your information outside the EEA in the manner described above.
- Notification of changes to the contents of this notice We will post details of any changes to our policy on [our website] to help ensure you are always aware of the information we collect, how we use it, and in what circumstances, if any, we share it with other parties.
- Contact us If at any time you would like to contact us with your views about our privacy practices, or with any enquiry or complaint relating to your personal information or how it is handled, you can do so via the following address: The Data Protection Officer, Invenica Ltd, Floor 9 Berkshire House, 168-173 High Holborn, London, WC1V 7AA or firstname.lastname@example.org.