This statement sets out Transversal's policy in relation to holding and using information which it may obtain from you in the course of your use of this Web site. For the purpose of the Data Protection Act 1998 Transversal is the data controller.
From time to time, as part of running our business, we collect and use certain personal information about individuals with whom we interact in relation our provision of our software and services, including for marketing such software and services (we refer to such individuals in this notice as “contacts” or “you”).
Where we collect personal information and decide what it is used for and how it is used, then under data protection law, we are categorised as a data controller. This means that we have certain legal responsibilities about how we use your personal information.
This policy explains our privacy practices and covers the following:
- What personal information we collect about you
- Where we get such personal information from
- How we use your personal information
- Who we share your personal information with
- How long we keep your personal information for
- Any transfers involving your personal information
- How we legally justify using and sharing your personal information
- How to contact us and your legal rights regarding your personal information
- Other relevant information
1. What personal information we collect about you
We collect and use personal information about certain people who fall within the following groups:
- If you work for an existing customer of ours - we collect and use certain personal information about contacts who work at organisations who are our existing customers, for example we may need to collect details about a contact who works in a customer’s accounts’ or sales’ team.
- If you work for one of our partners - we collect and use certain personal information about contacts who work at organisations who partner with us in providing similar products and services, i.e. partners who provide software tools, which we make available to our customers through our software.
- Potential customers and other third parties - from time to time we may also collect information about contacts at other third party organisations who are involved in this industry, such as potential customers, trade bodies, suppliers and other third parties.
Regardless of which organisation listed above you may be associated with, the information which we collect about you will only include (as a maximum) the following:
- Contact details - your name, email address, phone number, company name, address and job title.
- Online information - furthermore, our automated marketing tool, which monitors use of our website, collects personal information about visitors to the website, including their IP address and details of certain online activities whilst visiting our website (See section 4 below for more information).
Therefore, the information which we collect about you will not consist of any sensitive personal information or information relating to your home life.
2. Where we get such personal information from
We collect personal information from a variety of sources, including:
- from you directly - you may give us information about you by filling in forms on our site or by corresponding with us by phone, email, event attendance or otherwise. This includes information you provide when you register to use our site, sign up for any regular newsletter, information services, web forms or otherwise contact us;
- from our automated digital marketing tool, which monitors users’ activity on the website and collects certain information such as their IP address and details of certain online behaviour when using this website (see section 4 below for more information);
- if you work for one of our customers or partners, then we may obtain your contact details from your employer or another organisation, during the normal course of business communications or via referrals or networking opportunities e.g. we may put a contact at a customer in touch with one of our partners, and/or vice versa;
- from other third party sources such as advertising networks, and search information providers; and/or
- from publicly available information, such as LinkedIn or via a Google search.
3. How we use your personal information
- Providing and receiving services – As a supplier of software and related services across a number of industries, we need to communicate effectively and efficiently with various parties in the supply chain, in order to facilitate our provision of high quality and timely communications and services. Similarly, where your organisation provides services to us, we will need to know which individuals at your organisation we need to communicate with and keep details of your personal information. Therefore, we will use your personal information in relation to projects which we are involved in and services which we provide and receive, to enable us to liaise effectively with our customers, partners and other third parties.
- Other administrative uses – we also may use your personal information for internal purposes, including: to administer our site and for internal operations including troubleshooting, , testing, research, statistical and survey purposes; to improve our site to ensure that content is presented in the most effective manner for you and for your computer; to allow you to participate in interactive features of our services, when you choose to do so and as part of our efforts to keep our site safe and secure.
- Business Development – as a business, we want to make people in the industry aware of the range of products and services which we can offer, including new solutions, thought leadership, events and special offers. We keep lists of contacts on our client relationship management (CRM) system and from time to time we may send marketing information to such contacts. Please see paragraph 9 below regarding your right to object at any time to receiving direct marketing information.
4. Automated decision making
We have a feature on our website, which is an automated marketing system.This recognises the internet protocol (IP) address of visitors to our websites, email address and contact information if you clicked on an email link or choose to download relevant information and also cookies (small text files which download onto your computer to monitor a user’s actions in relation to using our website, for example which pages you visit, which links you click on and which content you access or download.
The information collected by the automated marketing system consists of information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including the date and time); products you viewed or searched for; page response times, download errors, lengths of visits to certain pages, page interaction information (such as scrolling, clicks and mouse-overs), methods used to browse away from the page, any phone number used to call our customer service number if you linked to our site from another website, the address of that website, and, if you linked to the site from a search engine, the address of that search engine and the search term you used.
The automated marketing system then generates a score which is sent to us, the score is based on the level of activity shown by a visitor to the website. For instance, if you visit our website, and click on several links and download content such as a guide, this would result in a higher score than if you merely visited the home page and went no further.
The score produced by the system makes certain recommendations, including that visitors who score above a certain threshold could potentially be interested in purchasing products and/or services from us and that we should contact them to follow up.There are essentially two types of visitors to the site – existing contacts and new visitors. Following a recommendation by the automated marketing system, we will only contact visitors who are existing contacts, whose contact details we already hold.Where the automated system makes such a recommendation, one of our sales and marketing team will review the score and decide whether to contact a visitor by phone or email, to discuss their potential interest in the products or services which they had viewed, based on the automated system’s recommendation.There is therefore a human element involved in interpreting the score and ultimately deciding whether to contact someone who has browsed the site.
In terms of new visitors, we store their personal identifiers such as the IP address, which helps us recognise the visitor when they make a repeat visit to the site, download any documents or enter their contact details into a form.
5. Who we share your personal information with
We will keep your information within our organisation, and will not share it except where described below or where disclosure is required or permitted by law.
With Customers – we may share your personal information with one of our Customers, for instance if you work for one of our Partners, we may pass on your details to a Customer.
With Partners – we may share your personal information with one or more of our Partners, for instance if you are interested in a particular product or service which is provided by a Partner. Those partners may pass on such information to other organisations who they are working with, e.g. a particular supplier of theirs.
With Suppliers – we have dedicated marketing CRM systems, provided by third parties called Salesforce and Act-on. Therefore, Salesforce and Act-on have potential access to your personal information but such access is only likely to be incidental to their provision of the CRM system – in other words, they are unlikely to be directly using your personal information other than storing and processing it on their system.
6. How long we keep your personal information for
Existing Customers and Existing Partners – if you work at an existing customer or partner of ours, then we will retain your personal information for the period of 2 years following expiry or termination of the contract between us and the relevant customer/partner or from our last contact.
Other third party contacts – generally, we will hold personal information about you whilst we have reasonable expectation of an ongoing or imminent future relationship with you, and we will review such personal information every 6 months, in order to determine whether it should be deleted. If we consider that your personal information is no longer required then we will delete it.
Online behaviour data – we will store the personal information collected by our automated marketing system for a period of 12 months.
We can confirm that, after the above retention periods have expired, we will delete your personal data, or will anonymise it, so that it is no longer capable of identifying you.
7. Transfers of your personal information
Personal information held on our CRM systems (provided by Salesforce and Act-on) will remain on servers based inside the European Union,.
8.Legal grounds for processing your personal information
Every use that we make of your personal information must meet a legal ground in the list set out by data protection law. The specific grounds which we rely upon when using your personal information are as follows:
Marketing – in relation to marketing activity which we perform using your personal information (including marketing based on a recommendation from the automated marketing system), we rely on the legitimate interests ground, with the legitimate interest being to promote our products and services to potential customers. Marketing is typically conducted by phone or email. If you object to receiving direct marketing information, we will cease sending you any more marketing information. However, we will keep minimal personal information about you on a screening list, to ensure that we do not accidentally send you marketing information against your wishes in the future.
9. Your rights in relation to your personal information
If you have any questions in relation to our use of your personal information, you should first contact us using the contact details in paragraph 10 below. Under certain conditions, you may have the right to require us to:
- provide you with further details on the use we make of your personal information and/or transfer a copy of your personal information to another data controller;
- provide you with an electronic copy of personal information that we hold;
- rectify any inaccuracies in the personal information we hold,
- restrict processing of your personal information;
- delete any personal information that we no longer have a lawful ground to use;
- object to our use of your personal information which is based on the 'legitimate interests' legal ground. If our use of your personal information based only on this legal ground is causing you undue harm, then we must cease using your personal information for that purpose.
You also have the right to object to receiving direct marketing communications from us.
Your exercise of most of these rights is subject to certain conditions and exemptions, for example to safeguard the public interest in investigating crimes, or protecting legal privilege. If you exercise any of these rights we will check your entitlement and respond in most cases within a month.
If you are not satisfied with our use of your personal information or our response to you, you can complain to the contact listed at paragraph 10 below. You also have the right to complain to the Information Commissioner’s Office (ICO) at any time.
10. Other Information
We will use reasonable endeavours to ensure that your personal information is accurate. In order to assist us with this, you should notify us of any changes to your personal information that we hold, by contacting us as set out below.
We are required to employ adequate technical and organisational security measures to protect your personal information from any loss, destruction, damage or unlawful disclosure. However, the nature of the internet is such that we cannot guarantee the security of the information you transmit to us electronically, and any transmission is at your own risk.
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The Adobe Flash Player (and similar applications) ("Flash") uses technology to remember settings, preferences and usage similar to browser cookies but these are managed through a different interface than the one provided by your Web browser. This technology creates locally stored objects that are often referred to as "Flash cookies". We employ Flash cookies in certain situations where we use Flash to provide video clips. You may access your Flash management tools from Adobe’s Web site directly. We do not use Flash cookies to serve interest-based advertising.
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