Privacy Policy

Introduction

Welcome to Signol Limited’s privacy policy. Signol Limited is a behaviour change service that receives customer data, including personal data. This policy lays out how customer data will be protected and your privacy rights.

Controller
When Signol receives personal data from a customer, the customer is the controller, and Signol is the processor. Where Signol receives data from an individual directly, Signol is the controller. We have appointed a data privacy manager responsible for overseeing questions concerning this privacy policy.

If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below:
Full name of legal entity: Signol Limited
Email address: info@signol.io
Postal address: Waverly House, 9 Noel Street, London, W1F 8GQ, United Kingdom.

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
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‍Changes to the privacy policy and your duty to inform us of changes
‍We keep our privacy policy under regular review. This version was last updated on [09/10/2023].

The data we collect about you

‍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).

We are engaged by customers in the private and public sector to analyse data regarding their customer/user base, and we received data sets concerning their users.

In most instances, those data sets are anonymised before they reach us, i.e. all identifying information, including name and contact details, are removed. However, some customers provide us with data sets, including names and addresses, in which case those are processed in accordance with this policy. We anonymise those data sets upon receipt, but the original received will be stored until completion of the project, as further detailed below. Our analysis and reports to our customers use aggregated data (see below).

We may collect, use, store and transfer different kinds of personal data about you, which we have grouped together as follows:

‍Identity Data includes first name, maiden name, last name, marital status, title, date of birth and gender.

‍Contact Data includes email addresses, telephone numbers and home addresses.

‍Transaction Data includes details about payments to and from you and our customers.

‍Technical Data includes [internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website]. We collect, use and share

‍Aggregated Data such as statistical or demographic data. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate and analyse council tax payment records from a geographic area. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data, which will be used in accordance with this privacy policy.

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. We do not knowingly collect data relating to children.

How is your personal data collected?

‍We use different methods to collect data from and about you, including through:

Direct interactions. You may give us your Identity and Contact Data by corresponding with us by post, phone, email or otherwise.

Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.

Our customers that provide us with data sets via secure platforms.

Third Parties and publicly available sources. We will receive personal data about you from various third parties [and public sources] as set out below:

Technical Data from the analytics providers such as Google based outside the EU; Identity and Contact Data from publicly available sources such as Companies House based inside the EU.

How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Where we need to perform the contract we are about to enter into or have entered into with you.

Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

Where we need to comply with a legal obligation.

Purposes for which we will use your personal data

We have set out below 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.

Purpose/Activity/Type of data/Lawful basis for processing including basis of legitimate interest

‍To register a new customer (a) Identity (b) Contact Performance of a contract with you

To manage our relationship with you, including notifying you of changes to this privacy policy (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)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity (b) Contact (c) Technical

(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 (a) Technical (b) Usage 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 make suggestions and recommendations to you about services that may be of interest to you (a) Identity (b) Contact (c) Technical Necessary for our legitimate interests (to develop our products/services and grow our business)

Retention of Data for research purposes

Signol may anonymise and retain information for research purposes with the following caveats: a) Research data does not include personal information.

b) Research data is not attributed to customer businesses or in any way identifiable as having originated from the business.

c) Signol will not sell or make available to a 3rd party any research data collected from individuals or customers.

d) Signol will ensure that any Personal data used to generate Research data is securely deleted.

Promotional offers from us

We may use your Identity, Contact and Technical Data to form a view of what we think you may want or need or what may be of interest to you. This is how we decide which services and offers may be relevant for you. You will receive marketing communications if you have requested information from us or services from us and have not opted out of receiving that marketing. We do not share your personal data with any third party for marketing purposes.

Opting out

‍You can ask us to stop sending you marketing messages at any time by contacting us. Where you opt out of receiving marketing messages, this will not apply to personal data provided to us as a result of a service experience or other transactions.

Cookies

You can set your browser to refuse all or some browser cookies or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

Change of purpose

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 we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so. 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.

Disclosures of your personal data

‍We do not share personal data with third parties.

Third-party links

‍This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

‍International transfers

We do not transfer your personal data outside the European Economic Area (EEA).

Data security

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. 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.

Data retention: How long will you use my personal data for?

As a rule for data sets provided by our customers, these are retained for a month beyond the duration of the project we are working on for that customer. On average, project duration is 1 year. We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation with respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

‍Request the erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons, which will be notified to you, if applicable, at the time of your request.

‍Object to processing of your personal data where we are relying on a legitimate interest (or those 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 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.

‍Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

If you want us to establish the data’s accuracy.

Where our use of the data is unlawful, but you do not want us to erase it.

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.

You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may be unable to provide you certain products or services. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required. 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 could refuse to comply with your request in these circumstances.

What we may need from you. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond. We try to respond to all legitimate requests within one month. Occasionally, it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

‍Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Complying with a legal obligation means processing your personal data where necessary for compliance with a legal obligation that we are subject to.