Privacy

1  Who we are

We are CirrusHQ Ltd (CirrusHQ), a company incorporated in Scotland with registered number SC405771 and having our registered office address at 4 Deer Park Avenue, Fairways Business Park, Livingston, West Lothian, EH54 8AF.

We are a data controller for the purposes of the General Data Protection Regulation (Regulation (EU) 2016/679) and related data protection legislation, except in relation to any services we may carry out for you where we may be a data processor.

2  How to contact us

If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us using the details set out below.

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.

3  Privacy Information

We are committed to protecting your personal data and your privacy. This privacy notice aims to give you information on how we collect and process your personal data through your use of our website www.cirrushq.com (the Website) (including any personal data that you may provide through our Website), where we have a contract in place with you (please note that separate terms and conditions may also be applicable here) and through your other communications with us.

It is important that you read this privacy notice when we are collecting or processing personal data about you so that you are fully aware of how and why we are using 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.

This version of our privacy notice was last updated on 17 May 2022.

4  To whom does this privacy notice apply?

This privacy notice applies to:

• all individuals who visit our Website or who contact us by post, telephone, e-mail, social media or other means (including other electronic means); or
• all individuals who are our customer contacts where you or your organisation are or have been our customer; or
• all individuals who are our business contacts where you or your organisation supply goods or services to us, provide professional services, have expressed an interest in us or have any other business relationship with us (including where your organisation is a public authority, an industry body or regulatory authority or similar).

5  Information about our Website

Our 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 we are not responsible for their privacy statements. When you leave our Website, we encourage you to read the privacy notice of every website you visit.

Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site.

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 the Website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Notice.

6  Children

Our Website is not intended for children and we do not knowingly collect any personal data relating to children.

7  What personal data do we collect and process?

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

• Identity Data includes first name, last name, social media username (such as LinkedIn or Twitter) or similar identifier, marital status, title, date of birth and gender.
• Contact Data includes home or work address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• 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 our Website.
• Usage Data includes information about how you use our Website.
• Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
• Business Contact Data includes your name, business or work contact details, details about who you work for and your role in any such organisation and your credentials.

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.

8  How is your personal data obtained?

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

• Direct interactions generally. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email, via social media or otherwise. This includes personal data you provide when you:
  • contact us through our Website;
  • submit an enquiry about our products or services; or
  • give us some feedback.
• Direct interactions with business contacts. You may give us your Identity, Contact and Business Contact Data by filling in forms or by corresponding with us by post, phone, email, via social media or otherwise. This includes personal data you provide when you:
  • negotiate and/or enter into a contract with us; or
  • provide us with your business card.
• Automated technologies or interactions. As you interact with our Website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies.
• Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out:
  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
  • Technical Data from analytics providers or search information providers.
  • Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register.
  • Business Contact Data from your business or organisation or from third party references or from professional advisors.

9  Failure to provide personal data

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 service you have with us but we will notify you if this is the case at the time.

10  How will we use your personal data?

Personal data will be processed by us where you consent to the processing or where that processing is necessary for 1) the performance of a contract with you; or 2) compliance with a legal obligation to which we are subject; or 3) the purposes of our legitimate interests (or those of a third party).

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.

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.

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.

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.

11  Marketing

If you are a consumer, we will only provide you with direct marketing communications where you have consented to receive such communications. You can subscribe to such marketing communications, and you can adjust your marketing preferences at any time by contacting us (How to contact us).

If you represent another business, we may provide you with direct marketing communications where we feel that this may be relevant to your business (provided that you have not opted out of such communications). When we use your personal data for such purposes, we do so on the basis that it is in our legitimate interests to pursue direct marketing, provided that it constitutes fair processing of your personal data to do so.

You can also opt-out or unsubscribe from all or some of these marketing communications at any time by contacting us (How to contact us) or by clicking “unsubscribe” at the bottom of any marketing e-mail.

Where you opt out of receiving these marketing communications, this opt-out will not apply to personal data provided to us for any other purpose.

12  With whom do we share your personal data?

We may have to share your personal data with the parties set out below for the purposes set out in the table above.

• Amazon Web Services.
• Service providers acting as processors who provide IT and system administration services.
• Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
• Any relevant regulatory authority or law enforcement agency, including HM Revenue & Customs, courts or tribunals who require reporting of processing activities in certain circumstances.
• 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.

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.

Any sharing of your personal data will only take place either where we are legally obliged to do so, where it is necessary for the performance of a contract with you or where it is in our legitimate interests to do so, including as follows:

• to maintain network and information security;
• to develop and improve our services and products in order to remain competitive;
• to protect and defend our legal rights;
• to pursue our commercial objectives where this does not override your rights and freedoms as a data subject.

13  International transfers

Some of our external third parties are headquartered or based outside of the EEA so their processing of your personal data may involve a transfer of data outside of the EEA. We seek to ensure that our external third parties retain your personal data within the EEA wherever possible. Our key external third party is Amazon Web Services – for further details please refer to the Amazon Web Services privacy notice (as it applies within the European Union) here: https://www.amazon.co.uk/gp/help/customer/display.html?nodeId=201909010.

Whenever we are required to transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring that appropriate safeguards are implemented, including any of the following:

• 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. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
• 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. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
• Where we use providers based in the USA (such as Microsoft), 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 European Union and the USA. For further details, see European Commission: EU-US Privacy Shield.

14  Automated decision making and profiling

We do not use automated decision-making (including profiling) to make any decisions which would produce a legal effect or similarly significantly affect a data subject.

15  How long do we retain your personal data?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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.

For tax purposes, we retain basic information about our customers and the representatives of our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers.

16  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 the Information Commissioner’s Office of a breach where we are legally required to do so.

17  Your rights

Your personal data is protected by legal rights, which include your rights 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 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. 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, following 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 on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes.
• 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; or 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 (data portability). We will provide to 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 which 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 not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of these rights, please contact us using the details above.

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.

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.

We try to respond to all legitimate requests within one month. Occasionally it may 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.

You also have the right to complain to the Information Commissioner’s Office, which regulates the processing of personal data, about how we are processing your personal data.

The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk