1.Definitions and Interpretation
In this Policy, the following terms shall have the following meanings:
|“Account”||means an account required to access and/or use certain areas and features of Our Site;|
|“Cookie Law”||means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 and of EU Regulation 2016/679 General Data Protection Regulation (“GDPR”)|
|“personal data”||means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site. This definition shall, where applicable, incorporate the definitions provided in the EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”); and|
|“We/Us/Our”||means GorillaHub, a limited company registered in England under company number 09667754, whose registered address is The Dairy House Moneyrow Green, Holyport, Maidenhead, Berkshire, UK, SL6 2ND|
2. Information About Us
- Our Site is owned and operated by GorillaHub Ltd , a limited company registered in England under company number 09667754, whose registered address is The Dairy House Moneyrow Green, Holyport, Maidenhead, Berkshire, England, SL6 2ND
- GorillaHub Ltd is the data controller and We are responsible for your personal data.
3. What Does This Policy Cover?
4. What is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’. Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
5. What Are My Rights?
Under the GDPR, you have the following rights, which we will always work to uphold:
- The right to access the personal data we hold about you. Part 13 will tell you how to do this.
- The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 17 to find out more.
- The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Part 17 to find out more.
- The right to restrict (i.e. prevent) the processing of your personal data.
- The right to object to us using your personal data for a particular purpose or purposes.
- The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
- Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 17. Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau. If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
6. What Data Do We Collect?
- Email address
- Telephone number
- Business name
- Job title
- Payment information
- Information about your preferences and interests
- Technical data such as IP address, login data, language, web browser type and version, operating system
- A list of URLs starting with a referring site, your activity on Our Site, and the site you exit to and time spent on pages
- Any other information you supply by entering a form, by phone, by email, entering a competition or completing a survey
- CV and application forms
- Credit information from 3rd parties
7. How Do You Use My Personal Data?
Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data may be used for one of the following purposes:
- Providing and managing your Account
- Providing and managing your access to Our Site
- Personalising and tailoring your experience on Our Site
- Supplying Our services to you. Your personal details are required in order for us to enter (or plan to enter) into a contract with you
- Providing you with proposals and quotations
- Administer and protect Our business and website
- Personalising and tailoring Our services for you
- Ask you to enter competitions or compete surveys
- Understand the effectiveness of our advertising
- Deliver relevant website content and offers to you
- Communicating with you. This may include responding to emails or calls from you
- Supplying you with information by email that you have opted-in to (you may unsubscribe or opt-out at any time by clicking the link at the bottom of each email.)
- Providing access to our support portal (https://servicedesk.gorillahub.online)
- Analysing your use of Our Site and gathering feedback to enable us to continually improve Our Site and your user experience.
- Scheduling and conducting video conference meetings, demonstrations and webinars
- Carry out credit checks
- Bring legal claims against you if you breach a contract of fail to make payment
- Comply with any legal obligations we are subject to or if required by a government authority
- Obtain or maintain insurance policies
- Manage our business
8. Our lawful basis for processing
Under GDPR, we are only able to process your data if we have a lawful reason to do so.
- In relation to Customer Data to deliver our services and fulfill our contract with you, update you in relation to services, the processing is required to deliver our services via contract and for our legitimate interest in keeping you informed about updates to the service
- In relation to Prospect Data collected during the enquiry process and to respond to your enquiries about our services, provide proposals and quotations, update you in relation to services, the processing is service your enquiry and with the intention of entering a contract and for our legitimate interest in keeping you informed about updates to our services
- In relation to Prospect Data we obtained when you signed up for any of our free resources, reply to communications about these resources and for record-keeping, you have provided consent to this processing for the purposes of sending you the resource therefore we have a legitimate interest to reply and keep records for our business
- In relation to Marketing Data we have obtained when you told us your marketing preferences, when you consented to receiving information about our products and services, enabling you to take part in competitions, prize draws and surveys, to deliver relevant content and advertisements to you and to measure the effectiveness of this advertising, we have a legitimate interest to assess how our clients and users use our products and services, to further improve them, to define marketing strategy and grow our business
- In relation to Technical Data such as IP address, login data, language, web browser type and version, operating system, list of URLs starting with a referring site, your activity on our Site, and the site you exit to and time spent on pages as well as other technology on the devices used to access our website, we process this data to analyse your use of our website and online services, to administer our website, services and business, to deliver relevant content and to understand the effectiveness of our advertising. Our lawful ground to process this data is our legitimate interest to properly administer our services, website and our business
- In relation to record keeping, this processing is required to comply with our legal obligations or our legitimate interests in administering our business or pursuing, defending or establishing a legal claim
- In relation to data we process in order to comply with legal requirements or as required by a government authority, the processing is necessary to comply with a legal obligation
9. Marketing Communications
Our lawful basis for processing your personal data in order to send you marketing communications is either your consent or our legitimate interests – to grow our business. Under the Privacy and Electronic Communications Regulations (PECR), we may only send you marketing communications if:
- You made a purchase or requested information about our products or services
- You agreed to receive marketing communications and, in each case, you have not opted out since
Under these regulations, if you are a Limited Company, we may send you marketing emails without your consent. You can still opt-out of these emails at any time. You can ask us to stop sending you marketing emails by either clicking the unsubscribe link at the bottom of each email or emailing email@example.com. Whilst you may opt-out of marketing communications, this opt-out does not apply to personal information provided by other means, such as purchases, enquires, warranty and support requests etc.
10. How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. This includes processing for the purposes of accounting, reporting or legal requirements. When deciding how long your data should be retained, we review the amount, nature, sensitivity and the potential risk of harm from unauthorised use or disclosure, the reason for processing and whether the objectives can be met by other means. We are required for tax purposes to keep basic information about customers such as contact, financial and transaction data for 6 years after they cease to be a customer.
11. How and Where Do You Store or Transfer My Personal Data?
We may store or transfer some or all of your personal data in countries that are not part of the European Economic Area (the “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein). These are known as “third countries” and may not have data protection laws that are as strong as those in the UK and/or the EEA. This means that we will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR as follows. We share your data with external third parties, as detailed below in Part 10, that are based outside of the EEA. The following safeguard[s] are applied to such transfers: Where we transfer your data to a third party based in the US, this may be protected if they are part of the EU-US Privacy Shield. This requires that third party to provide data protection to standards similar to those in Europe. More information is available from the European Commission. Please contact us using the details below in Part 17 for further information about the particular data protection mechanism used by us me when transferring your personal data to a third country.
12. Do You Share My Personal Data?
We may share your personal data for the purposes of fulfilling our contractual obligations with you, namely, building and supporting your websites. This may provide access you your data to our developers and technical staff working on the live site, staging copies and any backups. We may sometimes contract with the following external third parties to supply certain tools and services. These may include payment processing, delivery, and marketing. In some cases, those third parties may require access to some or all of your personal data that we hold. We list all external 3rd parties that may have access to your data
|Xero||Quotes & Invoicing||New Zealand||Link|
|Google Suite||Documents, files, communication & office suite||Global||Link|
|Hubspot||Customer Relationship Management||United States||Link|
|SiteGround||Website hosting & support portal||United Kingdom||Link|
|OVH||Website hosting & code repository||France||Link|
|Asana||Project management||United States||Link|
|Trello||Project Management||United States||Link|
|Basecamp||Project Management||United States||Link|
|Amazon Web Services||Website hosting & backups||United Kingdom||Link|
|Slack||Team communication||United States||Link|
|BrowserStack||Website browser testing||United States||Link|
|Calendly||Appointment management||United States||Link|
If any of your personal data is required by a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 9. If any personal data is transferred outside of the EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR, as explained above in Part 9. In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
13. Data Security
The security of your personal data is essential to us , and to protect your data, we take a number of important measures, including the following:
- Where possible, storing all Personal Data within systems located within the EAA. We select partners and providers able to provide this
- We look for evidence of GDPR compliance when selecting partners and platforms
- All computers, tablets and mobile devices are password protected
- All management and support systems are accessed only via passwords through an encrypted connection (HTTPS)
- Our Site is actively managed and maintained to the latest vendor security releases
- We locate our core hosting and development environments within the EAA
- We use cloud-based systems where possible to remove the need for data to be stored locally. We limit the ability to export data where possible
- Staff and Associates receive training in data security, are forbidden from taking unauthorised copies of data and this condition forms part of their terms of engagement
- We only allow access to your personal data to employees, associates and partners only when there is a business reason to do so
We have procedures in place 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.
14. How Can I Control My Personal Data?
In addition to your rights under the GDPR, set out in Part 5, when you submit personal data via Our Site, you may be given options to restrict our use of your personal data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails and at the point of providing your details. You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
15. Can I Withhold Information?
16. How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”. All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 17. We may need to request additional information for the purposes of establishing identity and ensure your right to access (or exercise any other rights) to your personal data. This is a security measure to prevent disclosure to any person who has no right to receive it. There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our OR administrative costs in responding. We will try to respond to your subject access request within one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
17. How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details:
- Email address: firstname.lastname@example.org
- Telephone number: +44 (0)1628947627.
- Postal Address: The Dairy House Moneyrow Green, Holyport, Maidenhead, Berkshire, UK, SL6 2ND
Policy Updated: 31st May, 2018