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We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint.
We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation (UK GDPR). We are also subject to the EU General Data Protection Regulation (EU GDPR) in relation to products and services we offer to individuals in the European Economic Area (EEA).
It would be helpful to start by explaining some key terms used in this policy:
| We, us, our | Photon Software Limited, a company registered in England and Wales under Company Number 12188457, with registered office at 60 Cannon Street, London EV4N 6NP |
| Personal data | Any information relating to an identified or identifiable individual |
| Special category personal data | Personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership, Genetic data, Biometric data (where used for identification purposes), Data concerning health, sex life or sexual orientation |
| Data subject | The individual who the personal data relates to |
The personal data we collect about you depends on the particular products and services we provide to you. We will collect and use the following personal data about you:
We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below. If you do not provide personal data we ask for, it may delay or prevent us from providing products and services to you.
We collect most of this personal data directly from you – in person, by telephone, text or email and/or via our website. However, we may also collect information:
Under data protection law, we can only use your personal data if we have a proper reason, e.g.:
A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests.
The table below explains what we use your personal data for and why.
| What we use your personal data for | Our reasons |
| Providing products and services to you | To perform our contract with you or to take steps at your request before entering into a contract |
| Preventing and detecting fraud against you or us | For our legitimate interest, i.e. to minimise fraud that could be damaging for you and/or us |
| Ensuring business policies are adhered to, e.g. policies covering security and internet use | For our legitimate interests, i.e. to make sure we are following our own internal procedures |
| Operational reasons, such as improving efficiency, training and quality control | For our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service to you at the best price |
| Ensuring the confidentiality of commercially sensitive information | Depending on the circumstances:—for our legitimate interests, i.e. to protect trade secrets and other commercially valuable information;—to comply with our legal and regulatory obligations |
| Statistical analysis to help us manage our business, e.g. in relation to our financial performance, customer base, product range or other efficiency measures | For our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service to you at the best price |
| Preventing unauthorised access and modifications to systems | Depending on the circumstances:—for our legitimate interests, i.e. to prevent and detect criminal activity that could be damaging for you and/or us;—to comply with our legal and regulatory obligations |
| Protecting the security of systems and data used to provide the products and services | To comply with our legal and regulatory obligationsWe may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal and regulatory obligations, and in those cases our reasons are for our legitimate interests, i.e. to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us |
| Updating customer records | Depending on the circumstances:—to perform our contract with you or to take steps at your request before entering into a contract;—to comply with our legal and regulatory obligations;—for our legitimate interests, e.g. making sure that we can keep in touch with our clients about existing orders and new products |
| Statutory returns | To comply with our legal and regulatory obligations |
| Ensuring safe working practices, staff administration and assessments | Depending on the circumstances:—to comply with our legal and regulatory obligations;—for our legitimate interests, e.g. to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you |
| Marketing our services to:—existing and former clients; —third parties who have previously expressed an interest in our services;—third parties with whom we have had no previous dealings. | For our legitimate interests, i.e. to promote our business to existing and former clients |
More details about how we use your personal data and why are set out in the table below.
| Purpose | Processing operation | Lawful basis relied on under the UK GDPR and EU GDPR | Relevant categories of personal data |
| Communications with you not related to marketing, including about changes to our terms or policies or changes to the products or other important notices (other than those addressed above) | Addressing and sending communications to you as required by data protection laws, i.e.:—the UK GDPR or Data Protection Act 2018;—the EU GDPR | Processing is necessary for compliance with a legal obligation to which we are subject (Article 6(1)(b)) | —your name, address and contact information, including email address and telephone number and company details if relevant;—your account details (username) |
| Addressing and sending communications to you about changes to our terms or policies or changes to the products or other important notices | Our legitimate interests (Article 6(1)(f)), which is to be as efficient as we can so we can deliver the best service to you | —your name, address and contact information, including email address and telephone number and company details if relevant—your account details (username) |
We do not collect any personal data which is special category.
See ‘Who we share your personal data with’ for further information on the steps we will take to protect your personal data where we need to share it with others.
We will use your personal data to send you updates (by email, text message, telephone or post) about our products and services, including exclusive offers, promotions or new products and services.
We have a legitimate interest in using your personal data for marketing purposes (see above ‘How and why we use your personal data’). This means we do not usually need your consent to send you marketing information. If your consent is needed, we will ask for this separately and clearly.
You do, however, have the right to opt out of receiving marketing communications at any time by contacting us at Photon Software.
We may ask you to confirm or update your marketing preferences if you ask us to provide further products and services in the future, or if there are changes in the law, regulation, or the structure of our business.
We will always treat your personal data with the utmost respect and never share it with other organisations for marketing purposes.
We will not share your personal data with any other third party.
Personal data may be held at our offices.
We will not keep your personal data for longer than we need it for the purpose for which it is used.
If you no longer have an account with us or we are no longer providing products or services to you, we will usually delete or anonymise your account data after seven years.
Following the end of the of the relevant retention period, we will delete or anonymise your personal data.
It is sometimes necessary for us to transfer your personal data to countries outside the UK and EEA. In those cases we will comply with applicable UK and EEA laws designed to ensure the privacy of your personal data.
We will transfer your personal data to:
Under data protection laws, we can only transfer your personal data to a country outside the UK/EEA where:
Where we transfer your personal data outside the UK or EEA, we do so on the basis of an adequacy regulation or (where this is not available) legally-approved standard data protection clauses recognised or issued further to Article 46(2) of the UK GDPR and/or EU GDPR. In the event we cannot or choose not to continue to rely on either of those mechanisms at any time, we will not transfer your personal data outside the UK/EEA unless we can do so on the basis of an alternative mechanism or exception provided by UK data protection law and reflected in an update to this policy.
Any changes to the destinations to which we send personal data or in the transfer mechanisms we rely on to transfer personal data internationally will be notified to you in accordance with the section on ‘Changes to this privacy policy’ below.
If you would like further information about data transferred outside the UK/EEA, please contact us (see ‘How to contact us’ below).
You have the following rights, which you can exercise free of charge:
| Access | The right to be provided with a copy of your personal data |
| Rectification | The right to require us to correct any mistakes in your personal data |
| Erasure (also known as the right to be forgotten) | The right to require us to delete your personal data – in certain situations |
| Restriction of processing | The right to require us to restrict processing of your personal data in certain circumstances, e.g. if you contest the accuracy of the data |
| Data portability | The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party – in certain situations |
| To object | The right to object:—at any time to your personal data being processed for direct marketing (including profiling);—in certain other situations to our continued processing of your personal data, e.g. processing carried out for the purpose of our legitimate interests unless there are compelling legitimate grounds for the processing to continue or the processing is required for the establishment, exercise or defence of legal claims |
| Not to be subject to automated individual decision making | The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you |
| The right to withdraw consent | If you have provided us with a consent to use your personal data you have a right to withdraw that consent easily at any timeYou may withdraw consent by contacting us Withdrawing consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn |
For more information on each of those rights, including the circumstances in which they apply, please contact us (see ‘How to contact us’ below) or see the Guidance from the UK Information Commissioner’s Officer (ICO).
If you would like to exercise any of those rights, please:
We have appropriate security measures to prevent personal data from being lost accidentally, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your personal data will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
Please contact us if you have any queries or concerns about our use of your personal data (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.
You may also have the right to lodge a complaint with the Information Commissioner (the UK data protection regulator). Please contact us if you would like further information.
This privacy notice was published on 26 January 2024.
We may change this privacy notice from time to time – when we do we will inform you via our website.
We take reasonable steps to ensure your personal data remains accurate and up to date. To help us with this, please let us know if any of the personal data you have provided to us has changed, e.g. your surname or address—see below ‘How to contact us’.
You can contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.
Our contact details are shown below:
| Our contact details |
| Photon Software Ltd, 60 Cannon Street, London EC4N 6NP email: adam.hill@photon-software.com tel: 07425 909066 |
Individuals within the EEA can contact us direct (see above).
© 2024 Photon Software Ltd. All rights reserved.
UK VAT Number: 435829960