Sondrel Ltd (we, us or our) is committed to protecting and respecting your privacy. This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting www.sondrel.com (our site) you are accepting and consenting to the practices described in this policy.
For the purposes of the Data Protection Act 1998 (DPA) and the General Data Protection Regulation ((EU) 2016/679) (GDPR) and all successor legislation to the DPA and the GDPR (Data Protection Legislation), the data controller is Sondrel Ltd (company no. 04491953) of Sondrel House, Theale Lakes Business Park, Moulden Way, Sulhamstead, Reading, RG7 4GB.
1. Information we collect from you
1.1 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).
1.2 We may collect, use, store and transfer the following data about you:
1.3 Information you give us
This is information about you that you give us by filling in forms on our site or by corresponding with us by phone, e-mail, in person or otherwise. It includes information you provide when you register with us, request or download any of our latest resources, request a quote, request a call, apply for a role, search for or purchase any of our services or solutions or when you report a problem with our site or give us some feedback. The information you give us may include your name, address, e-mail address, phone number, financial information, date of birth and CVs (where applicable).
1.4 Information we collect about you With regard to each of your visits to our site we may automatically collect the following information:
1.4.1 technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
1.4.2 information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), products you viewed or searched for page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number.
1.5 Information we receive from other sources We may receive personal data about you from various third parties including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers.
1.7 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.
1.8 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 (for example, to provide you with services). In this case, we may have to cancel a contract for services that we have with you but we will notify you if this is the case at the time.
2. Uses made of your information
2.1 We will only use your personal data when the law allows us to. Most commonly, we will use your personal information:
2.1.1 to carry out our obligations arising from any contracts entered into between you and us or to take steps at your request before entering into any contracts;
2.1.2 to comply with any legal obligations to which we are subject; or
2.1.3 where it is necessary for our or a third party’s legitimate interests, including for the purposes of preventing fraud, except where such interests are overridden by your interests or fundamental rights and freedoms.
2.2 Generally we do not rely on consent as a legal basis for processing your personal information other than in relation to sending direct marketing communications to you via email.
3. Purposes for which we will use your personal data
3.1 We have set out below, in a table format, a description of all the ways we plan to 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.
3.2 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/ to register you for the receipt of resources by you||Identity and contact details||Performance of a contract with you|
To process and deliver a service for you, including: (a) Manage payments, fees and charges;
(b) Collect and recover money owed to us
|Identity, contact details and financial and credit card information||(a) Performance of a contract with you|
(b) Necessary for our legitimate interests (to recover debts due to us)
|To manage our relationship with you which will include|
(b) Asking you to leave a review or take a survey
|Identity, contact details, and marketing preferences||(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 administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||Identity, contact details and technical data such as IP address||(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 use data analytics to improve our website, services, marketing, customer relationships and experiences||Technical data such as IP address||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 process your data in relation to you applying for a job with us or making an enquiry to us in relation to jobs||Identity, contact details, date of birth, CV||Necessary for our legitimate interests (to determine whether you are fit for a job we post or whether we can in any way benefit from your job application)|
We will get your express opt-in consent before we process your personal data for marketing purposes. Where you have given your consent, you can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.
5. Change of purpose
5.1 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.
5.2 If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
5.3 Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
6. Disclosure of your information
6.1 We may have to share your personal information with the third parties set out below, or any other third parties notified to you, for the purposes set out in paragraph 3 above:
6.1.1 Professional advisers including lawyers, bankers, auditors and insurers based in the UK;
6.1.2 Regulators and other authorities who require reporting of processing activities in certain circumstances;
6.1.3 Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. 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 privacy notice.
6.1.4 Fraud prevention agencies.
6.2 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.
7. International transfers
7.1 Many of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
7.2 Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
7.3 We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
7.4 Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
7.5 Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
7.6 Please contact us if you would like further information on the specific mechanism used by us when transferring your personal data out of the EEA.
8. Data security
8.1 We have put in place 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.
8.2 However, the transmission of information via the internet is never completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk.
8.3 We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
9.1 We will only retain your personal information for as long as is necessary to carry out the purpose for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements.
9.2 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.
9.3 In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
10. Your rights
10.1 Under the Data Protection Legislation you may be entitled to the following rights:
10.1.1 Where you have provided your consent to the processing of your personal data for any purpose, you have the right to withdraw such consent at any time by contacting us at Sondrel House Theale Lakes Business Park, Moulden Way, Sulhamstead, Reading, RG7 4GB or by email to: email@example.com .
10.1.2 You can ask us to rectify any inaccuracies in the personal information that we hold about you.
10.1.3 To request the erasure of personal information that we hold about you where there is no good reason for us to continue processing it, where you have successfully exercised your right to object to processing, where we may have processed you information unlawfully or where we are required to erase your personal data to comply with local law.
10.1.4 To object to our processing of your personal data where we are relying on a legitimate interest (or that of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
10.1.5 To restrict our processing of your personal data (a) if you want us to establish the data's accuracy (b) where our use of the data is unlawful but you do not want us to erase it (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
10.1.6 To request a copy of your personal data from us in a commonly used and machine-readable format or that we transmit your personal data to another data controller.
10.1.7 Not to be subject to automated decision-making, including profiling, which has legal or other significant effects on you.
10.1.8 To access information held about you. 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 is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
10.2 You can exercise any of the above rights at any time by contacting us at Sondrel House Theale Lakes Business Park, Moulden Way, Sulhamstead, Reading, RG7 4GB or by email to: firstname.lastname@example.org .
11. Links to and from our site
Our site may, from time to time, contain links to and from the websites of our partners and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
12. Changes to your personal data
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.