DataJavelin Ltd. understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of our clients, potential clients and website users and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
1. Information About Us
DataJavelin Ltd. is a company incorporated in England and Wales under number 11357308 whose registered office is at 14 Haven Brow, Seaford, United Kingdom, BN25 3QP
2. What Does This Notice Cover?
This Privacy Information explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.
3. What Is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
The personal data that we use is set out in Part 5, below.
4. What Are My Rights?
Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:
The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 11.
The right to access the personal data we hold about you. Part 10 will tell you how to do this.
The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 11 to find out more.
The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 11 to find out more.
The right to restrict (i.e. prevent) the processing of your personal data.
The right to object to us using your personal data for a particular purpose or purposes.
The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 11.
It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 11.
5. What Personal Data Do You Collect?
Information Collected Automatically:
Whenever you interact with our website, we automatically receive and record information on our server logs from your browser including your, “cookie” information, and the page you requested. “Cookies” are identifiers we transfer to your computer or mobile device that allow us to recognize your browser or mobile device and tell us how and when pages in our website are visited by you. We use Google Analytics. You may be able to change the preferences on your browser or mobile device to prevent or limit your computer or device’s acceptance of cookies, but this may prevent you from taking advantage of some of our website’s features. If you click on a link to a third-party website, such third party may also transmit cookies to you. When you use the Services, whether as a DataJavelin customer or a non-registered user just browsing, our servers or third-party partners automatically record information that your browser sends whenever you visit a website (“Log Data”). For example, Log Data may include information such as your computer’s IP address, browser type or the webpage you were visiting before you came to our website, pages of our website that you visit, the time spent on those pages, information you search for on our website, access times and dates, and other statistics. We use this information to monitor and analyse the use of the website and the Services and for the website’s technical administration, to increase our website’s functionality and user-friendliness, and to better tailor it to our visitors’ needs. Technologies such as cookies, beacons, scripts and tags are used by DataJavelin and our third-party partners. These technologies are used in analysing trends, administering the website, tracking users’ movements around the site, and gathering demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual and aggregated basis. Various browsers may offer their own management tools for removing these types of tracking technologies.
6. How Else Do You Use My Personal Data?
Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following describes how we will or may use your personal data:
For our own internal records.
To contact you in response to a specific query.
To customise the website for you.
To send you promotional emails about products, services, offers and other things we think might be relevant to you.
To contact you via email, telephone or mail for market research reasons.
We may contact you by email or other means; for example, we may follow up on your contact us request or communicate with you about your use of the Website or Services. Please note that if you do not want to receive legal notices from us, those legal notices will still govern your use of the Website, and you are responsible for reviewing such legal notices for changes. If you subscribe to our newsletter(s), we will use your name and email address to send the newsletter to you. Out of respect for your privacy, you may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails.
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email, telephone, text message or post with information, news, and offers on our services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out. We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time.
We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 11.
If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.
In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.
7. How Long Will You Keep My Personal Data?
We will only retain your personal information 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.
8. How and Where Do You Store or Transfer My Personal Data?
With the following exception stated below we will only store or transfer your personal data within the European Economic Area (the “EEA”).
We use G-Suite as such your personal data may be transferred to servers outside the EEA.
G Suite offers the Data Processing Amendment and model contract clauses as a means of meeting the adequacy and security requirements of the European Union's General Data Protection Regulation (the "GDPR"). As the data controller, we have accepted the terms of the Data Processing Amendment and model contract clauses.
This means that your personal data will be fully protected under the Data Protection Legislation, GDPR, and/or to equivalent standards by law.
The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality. Our procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so.
9. Do You Share My Personal Data?
We will not share any of your personal data with any third parties for any purposes, subject to the following exceptions.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
10. How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email addresses shown in Part 11. We will respond to your subject access request within less than one month.
11. How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please contact Colin Hayhurst at colin(at)datajavelin(dot)com.
12. Changes to this Privacy Notice
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.