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Privacy Policy

This Privacy Policy sets out the basis on which any personal data provided to us, will be processed.

For your information, this Website is operated and wholly owned by Submission Technology Ltd. (“Submission Technology,” “we,” or “us”), registered in England with the company number 04456811 and registered address: Heritage House, 34b North Cray Road, Bexley, Kent, DA5 3LZ.

For the purposes of the EU General Data Protection Regulation (2016), Submission Technology is the registered data controller with the Information Commissioner’s Office (ICO); our registration number is Z7981900. To contact us, please email our Data Protection Officer: dpo@submissiontechnology.co.uk.

1. Data We Collect

In order to run this Website effectively, we collect certain categories of personal data including:

  • Technical Data: such as Device IDs, device type (e.g. mobile), access dates and times, browser type and version, cookie data, 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 the Website; and,
  • Usage Data: such as information about how you use our Website, products and services.

Non-Personal Data

We also collect, use and share aggregate data such as statistical or demographic data. This is considered non-personal data because it does not directly or indirectly identify you. We use the data to analyse our Website usage, for example, to calculate the number of users accessing a certain feature of the Website.

2. How Data Is Collected

As you interact with our Website, we may automatically collect Technical Data and Usage Data by cookies, server logs and tracking technologies (defined below).

3. Our Lawful Basis for Processing

We will only collect and further process your Personal Data where permitted by law. Purposes for which we use your personal data are outlined in the table below.

WHEN YOUR PERSONAL DATA IS PROCESSED WHAT PERSONAL DATA WE ARE COLLECTING HOW WE USE YOUR PERSONAL DATA OUR LEGAL BASIS FOR PROCESSING

Website Administration • Technical Data • To provide IT services and network security

  • To troubleshoot
  • To perform data analysis, testing, system maintenance, support, reporting and hosting of data
  • To run analytics or collect statistics
  • To monitor and improve our Website • To fulfil our contract with you by providing our Service
  • For our legitimate interests of running our business

Online Browsing • Usage Data

  • Technical Data • To improve our Website, Service and your user experience
  • To run analytics and collect statistics
  • To enable our Website to function properly
  • To understand how you arrived at our WebsiteTo customise our Services
  • To ensure the proper display of content
  • To fulfil our contract with you by providing our Service
  • For our legitimate interests to improve our Services and Website; to provide you with a better user experience

4. Who We Share Your Data With

We share your data with the following third parties. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. Our third-party service providers are required to only use your personal data as per our instructions.

  • Service providers that we use to support our business and help provide our Service to you including third party cookie providers.
  • Fraud prevention and identity verification services where we believe that disclosure is necessary or appropriate to protect the rights, property or safety of our customers.
  • Law enforcement agencies, courts, supervisory authorities, regulatory bodies and certain other third-parties, to the extent that we are permitted or required to do so by law, in order to comply with our legal and regulatory obligations, or in the interests of national security, or to respond to verified requests relating to a criminal investigation.
  • For any other purpose disclosed by us when you provide the information or with your consent.

Where in the world your data is transferred

Submission Technology is headquartered in the UK. The information that you provide or that we collect as a result of your interaction with the Website and/or the user of the Services will only be transferred to parties located within the European Economic Area (EEA) that have been recognised by the European Commission as providing an adequate level of data protection. In rare circumstances, when transfers need to take place to countries outside of this consideration, we have put in place measures, including ensuring the recipient is bound by EU Standard Contractual Clauses, to protect your Personal Data.

Where any Personal Data is transferred to the USA, we also rely on the EU-US Privacy Shield Frameworks (“Privacy Shield”) to ensure recipients adhere to the Privacy Shield Principles.

5. How Long Your Data Will Be Kept For

We will not retain your personal data for longer than necessary for the purposes set out in this Privacy Policy. The length of time we hold your data will depend on our ongoing relationship with you, our legal obligation, any request you may make to delete your personal data, and our legitimate interest in relation to the management of our own rights. Once we no longer have a purpose to retain your personal data, we will securely destroy your personal data subject to the foregoing and in accordance with applicable laws and regulations.

6. Your Data Subjects Right

Right to information:

You have a right to know what Personal Data we collect and further process about you and how we use it.

Right to access:

You have a right to be provided with a copy of your Personal Data.

Right to rectification:

You have a right to correct or update any inaccurate or incomplete Personal Data we hold about you.

Right to erasure/be forgotten:

You have the right to ask us to erase Personal Data when there is no good reason for us to continue to process it. This is not an absolute right, meaning we may not always be able to comply with your request. If this is the case, we will inform you in a timely manner with reasons why.

Right to restrict processing:

You have the right to ask us to restrict processing of your Personal Data e.g. if you want us to establish the accuracy of your data.

Right to request data portability:

In certain circumstances, you have the right to request the transfer of your Personal Data to you or to a third party in a commonly used machine-readable format.

Right to object to processing:

You have the right to object to the processing of your Personal data in the following circumstances: (i) at any time your Personal Data is being processed for direct marketing; or (ii) in circumstances when we rely on our legitimate interests to process your Personal Data. We may demonstrate we have a compelling reason to process your information, for example, for preventing fraud.

Right to withdraw consent at any time:

At any time, you have provided us with your consent to process your Personal Data, you have a right to withdraw your consent.

Right not to be subject to a decision based solely on automated decision-making:

You have 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. However, you right does not apply if: (i) you gave us your consent to process your data in this way; (ii) we are permitted by law to make our decision; or (iii) our automated decision was necessary to enter into a contract with you.

Reporting to a Supervisory Authority:

If you are not satisfied with our response or believe we are processing your personal data not in accordance with the law you can make a complaint to the UK Supervisory Authority, the Information Commissioner’s Office (ICO). You can contact the ICO through their website: https://ico.org.uk/concerns/ or by telephone: 0303 123 1113.

7. Cookies and Tracking Technologies

Submission Technology and third parties may use cookies or similar tracking technologies (e.g. pixels, beacons, scripts etc.) to analyse trends, administer the website, track users’ movements around the website for performance analysis, and to gather demographic information about our user base to better deliver our Service.

What is a cookie?

Cookies are small pieces of text used to store information on web browsers. Cookies are used to store and receive identifiers and other information on computers, phones and other devices. Other technologies, including data we store on your web browser or device, identifiers associated with your device, and other software, are used for similar purposes.

Types of Cookies we use

  • Strictly necessary cookies. These are cookies that are required for the operation of our website.
  • Analytical/performance cookies. These cookies allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users find what they are looking for easily.
  • Functionality cookies. These cookies are used to recognise you when you return to our website. This enables us to personalise our content for you, and remember your preferences (for example, your choice of language or region).
  • Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
  • Third Party cookies. These are cookies that are set by a domain other than ours. Where we work with third parties, they may set cookies, web beacons or similar technologies to deliver the services that they are providing. For example, to help us analyse how you use our Website, which third-party websites you came from, detect or prevent fraud or collect information about your activities on our Website. To opt out of Google Analytics for all websites: https://tools.google.com/dlpage/gaoptout

Blocking or Declining Cookies

Depending on your browser, you can configure your web browser to delete and/or block the use of cookies. We have provided some links to the more commonly used browsers below. Please click on the appropriate browser link for instructions on how to manage cookies:

Internet Explorer

https://support.microsoft.com/en-us/help/17442/windows-internet-explorer-delete-manage-cookies

Firefox

https://support.mozilla.org/en-US/kb/Cookies

Google Chrome

https://support.google.com/chrome/bin/answer.py?hl=en&answer=95647

Opera

https://www.opera.com/help/tutorials/security/privacy/

Safari

https://support.apple.com/kb/PH5042

Safari iOS (iPhone, iPad)

https://support.apple.com/kb/HT1677

For further information about behavioural advertising, cookies and other storage technologies, and the steps you can take to protect your privacy online visit http://www.youronlinechoices.eu/. If you wish to opt out of any interest-based advertising visit https://preferences-mgr.truste.com/. Please note, you will continue to receive generic ads.

8. Changes to this Privacy Policy

In the event of updates to our Service that materially expand the sharing or use of your personal information in ways not already disclosed to you, we will notify you on our Website and update this Privacy Policy accordingly.

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