SquaredUp Limited (“SquaredUp”, “we”, “us” or “our”) is a company incorporated in England and Wales with company number 07834869. Our registered office is Abbey Place 24-28 Easton Street High Wycombe Buckinghamshire HP11 1NT.
This policy sets out the basis on which your personal data will be processed by us when you:
For the purpose of data protection laws, we are a data controller and we are registered as a data controller with the Information Commissioner’s Office under number ZA538404.
Reference to “you” or “your” are to you as an individual using our websites or otherwise with whom we are in contact (whether on behalf of yourself, another individual or organisation).
This version was last updated on 7 August 2019.
It is important that the personal data we hold about you is accurate and current. You should keep us informed if your personal data changes during your relationship with us.
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).
2.1 Sections 2.2 – 2.12 explain the purposes for which we may process personal data as a controller, as well as the legal basis on which this processing is carried out.
2.2 To provide services to you: Where you request our services on behalf of a business or organisation (for example via our website, email, by telephone or when meeting one of our members of staff), we may process your personal data to provide these services. We may use your personal data to register you, or the business as a new customer contact, to be in contact with you or for other reasons in relation to working with you. Our use of your personal data in this way includes sharing your personal data with our employees and other personnel.
The legal basis for using your information in this way is that it is necessary for the purposes of our legitimate interests in providing our services. If you do not provide us with the personal data we request from you for customer services purposes, we may not be able to fully answer your queries.
2.3 To provide information to you: We may process personal data relating to an individual in order to respond to general or specific enquiries, however communicated, which may have been sent by you on your own behalf or in your capacity as an employee or representative of a business or organisation.
The legal basis on which we process an individual’s personal data in these circumstances is our legitimate interest to assist you with queries, grow our business and to provide good customer service.
2.4 To make our website better: We may process your personal data in order to provide you with a more tailored user experience, including using your personal data to make sure our websites are displayed in the most effective way for the device you are using. This processing means that your experience of our websites will be more tailored to you. We also use various cookies to help us improve our website (more details are set out in section 5) and may share your personal data with the third party analytics and search engine providers that assist us in the improvement and optimisation of our website.
We will also process personal data for the purposes of making our website more secure, and to administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
The legal basis on which we process personal data in these circumstances is our legitimate interest to provide you with the best customer experience we can, keep our website updated and relevant, study how individuals use our services, to inform our marketing strategy and to ensure that our website is kept secure.
2.5 For prospecting and marketing purposes: In a business-to-business sales context, we may process personal data in order to make contact with you to provide or seek information in connection with our products and/or services. The legal basis we rely on for making contact with you and processing your personal data is our shared legitimate interests in doing business together. When we make contact with you can exercise your right to object to such contact from us (for more information about individuals’ rights please see section 9).
2.6 In connection with our recruitment activities: We may process personal data relating to you for the purpose of work opportunities you may be interested in. This personal data may be collected directly from you or via third parties such as recruitment agents or other websites such as LinkedIn. The legal basis on which we process your personal data in these circumstances is our legitimate interest to recruit employees and workers to grow our business.
2.7 If our business is sold: We will transfer your personal data to a third party:
2.7.1 in the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets (at all times in accordance with all applicable data protection laws); or
2.7.2 if SquaredUp or substantially all of its assets are acquired by a third party, in which case personal data held by us will be one of the assets transferred to the purchaser,
in each case, the legal basis on which we process your data in these circumstances is our legitimate interest to ensure our business can be continued by a purchaser. If you object to our use of personal data in this way, the relevant seller or buyer of our business may not be able to provide good and/or services to you.
The legal basis on which we process personal data in these circumstances is our legitimate interest to remain transparent in our use of personal data and to ensure you are kept updated on how and why we process your personal data.
2.9 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.
2.10 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.
2.11 Please note that we may process your personal data without knowledge or consent, where this is required or permitted by law.
2.12 In certain circumstances we may also need to share your personal data if we are under a duty to disclose or share personal data in order to comply with any legal obligation.
3.1 We will collect and process the following personal data about you.
3.2 Information you give us: You may provide personal data when corresponding with us by post, phone, email or otherwise. This includes information you provide as an individual for and on behalf of a business or other organisation. This includes personal data provided to us when you:
3.2.1 visit our websites (including our support portal);
3.2.2 register for a free trial via our website;
3.2.3 enquire about our services via our website, via email or by telephone;
3.2.4 meet with one of our members of staff (such as at an event) to discuss our services or otherwise contact us;
3.2.5 contact us about employment opportunities;
3.2.6 request marketing and publications to be sent to you;
3.2.7 set up a customer account with us;
3.2.8 are a customer making contact with us via our website, via email or by telephone; or
3.2.9 provide us with feedback on our services.
The information you give us may include names, email addresses, phone numbers and job roles/titles.
The information you give us in relation to employment opportunities may include date of birth, National Insurance number, employment data and educational and/or professional qualifications.
3.3 Online Information we collect: With regard to each of your visits to our websites we will automatically collect the following information:
3.3.1 technical information, including the Internet protocol (IP) address used to connect your computer to the internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, screen resolution, operating system and platform; and
3.3.2 information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our website (including date and time), page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs) and methods used to browse away from the page.
3.4 Information we receive from other sources: We may receive personal data about you from various other third parties and public sources as set out below:
3.4.1 name and related information from resellers and/or official partners;
3.4.2 name and related information from individuals recommending, in a business-to-business context, that we make contact with you to introduce our services to you or a business or organisation of which you are an employee of representative;
3.4.3 name and related information (and possibly special categories of personal) data from recruitment professionals who provide us with such information for recruitment purposes;
3.4.4 recruitment-related data such as identity and contact data, job title/role and educational/professional qualifications from third party websites such as LinkedIn; and
3.4.5 technical and website usage data from analytics providers, such as Google, based outside the European Union (EU).
3.5 We do not actively collect any special categories of personal data about you. This includes details about your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic or biometric data, health, sex life or sexual orientation. However, we may process certain special categories of personal data when you include such information in your CV which you (or a third party) send to us when making contact with us about employment opportunities with us.
4.2 Your personal data may be shared by us with categories of recipients that include our official business partners and other external third parties who provide support integral to the provision of our services and enable us to operate, such as:
4.2.1 Service providers acting as processors based in the UK who provide IT and system administration services.
4.2.2 Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors, insurers and employment and recruitment agencies based in the UK (or other relevant jurisdictions) who provide consultancy, banking, legal, insurance, accounting and recruitment services.
4.2.3 Marketing and public relations companies based in (and outside) the UK, in particular social media organisations such as Facebook, Instagram, Twitter, Vimeo and YouTube.
4.2.4 HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the UK (or other relevant jurisdictions) who require reporting of processing activities in certain circumstances.
4.2.5 Other third party companies where we have an agreement in place and only where an individual has agreed that we may share their personal data with them.
5.2 A cookie is a small file of letters and numbers that we store on your browser or the hard drive of their computer. We only use (and store) non-essential cookies on your computer’s browser or hard drive if you provide your consent.
|ARRAffinity||This cookie is set by websites run on the Windows Azure cloud platform. It is used for load balancing to make sure the visitor page requests are routed to the same server in any browsing session.||After session sends||https://blogs.msdn.microsoft.com/devschool/2015/06/19/azure-arraffinity-makes-affinity-cookies/|
|ASP.NET_SessionId||Set by websites built using ASP.NET allows server to identify users by a number. Only stores an ID, nothing else.||After session ends|
|__cfduid||Used to help Cloudflare identify malicious visitors to the website and minimize blocking legitimate users from accessing the website.||24 hours||https://support.cloudflare.com/hc/en-us/articles/360024915491-Privacy-and-the-cfduid-Cookie|
|Hotjar||When someone visits hotjar.com, we collect standard internet log information and details of visitor behavior patterns. Hotjar does this to find out things such as the number of visitors to the various parts of the site.||12 months||https://www.hotjar.com/legal/policies/cookie-information|
|__RequestVerificationToken||This is an anti-forgery cookie set by web applications built using ASP.NET MVC technologies. It is designed to stop unauthorised posting of content to a website, known as Cross-Site Request Forgery. It holds no information about the user and is destroyed on closing the browser.||After session ends|
5.4 You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) they may not be able to access all or parts of our website.
5.5 Except for essential cookies, all cookies will expire as outlined under the expiration column in the table included in paragraph 5.2.
6.1 We do not process your personal data in any country outside the EU.
6.2 However, certain third parties are based outside of the EU, so their processing of your personal data will involve a transfer of data outside the EU.
6.3 Whenever we transfer your personal data out of the EU, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
6.3.1 We will only transfer the personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
6.3.2 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.
6.3.3 Where we use providers based in the US, 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 Europe and the US.
Please contact us if you want further information on the specific mechanism used by us when transferring personal data out of the EU.
7.1 We have put in place appropriate security measures to prevent personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. This includes ensuring all data is encrypted in transit and at rest and that end-user devices enforce drive encryption and all credentials are required to be complex and stored securely using Lastpass. In addition, we limit access to individuals’ personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process personal data on our instructions and they are subject to a duty of confidentiality.
7.2 We have put in place procedures to deal with any suspected personal data breach and will notify the individuals involved and any applicable regulator of a breach where we are legally required to do so.
8.1 We will only retain 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.
8.2 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 the personal data, the purposes for which we process the personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
8.3 We will generally retain our customers’ data for a period of 7 (seven) years after the contract to which is applied has ended, to ensure that we are able to assist should they have any questions or feedback in relation to our services or to protect, or defend, our legal rights, or for tax purposes.
8.4 Where we have processed personal data to provide you with marketing communications, we may contact you at least every twelve (12) months to ensure you are happy to continue receiving such communications. If you tell us that you no longer wish to receive such communications, your personal data will be removed from our marketing lists (but will be added to a “do not contact” list).
8.5 Where we have processed personal data for any other reason (such as where you have contacted us with a question in connection with our services), subject to section 8.3, we will retain your data for twelve (12) months.
8.6 In some circumstances you can ask us to delete your data: see section 9.1.3 below for further information.
8.7 In some circumstances we may anonymise personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
9.1 Under certain circumstances, you have rights under data protection laws in relation to your personal data. You may have the right to:
9.1.1 Request access to your personal data (commonly known as a “data subject access request”). This enables individuals to receive a copy of the personal data we hold about them and to check that we are lawfully processing it.
9.1.2 Request correction of the personal data that we hold about you. This enables individuals to have any incomplete or inaccurate data we hold about them corrected, though we may need to verify the accuracy of the new data they provide to us.
9.1.3 Request erasure of your personal data. This enables individuals to ask us to delete or remove personal data where there is no good reason for us continuing to process it. Individuals also have the right to ask us to delete or remove their personal data where they have successfully exercised their right to object to processing (see below), where we may have processed their information unlawfully or where we are required to erase their personal data to comply with local law. Note, however, that we may not always be able to comply with an individual’s request of erasure for specific legal reasons which will be notified to them, if applicable, at the time of their request.
9.1.4 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. Individuals also have the right to object where we are processing their personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process an individual’s information which override their rights and freedoms.
9.1.5 Request restriction of processing of your personal data. This enables individuals to ask us to suspend the processing of their personal data in the following scenarios: (a) if they want us to establish the data’s accuracy; (b) where our use of the data is unlawful but they do not want us to erase it; (c) where they need us to hold the data even if we no longer require it as they need it to establish, exercise or defend legal claims; or (d) they have objected to our use of their data but we need to verify whether we have overriding legitimate grounds to use it.
9.1.6 Request the transfer of your personal data to them or to a third party. We will provide to individuals, or a third party they have chosen, their personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which they initially provided consent for us to use or where we used the information to perform a contract with the individual.
9.1.7 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 the individual withdrew their consent. If an individual withdraws their consent, we may not be able to provide certain services to them. We will advise the individual if this is the case at the time they withdraw their consent.
If you wish to exercise any of the rights set out above, please contact us directly.
Individuals have the right to make a complaint at any time to the ICO, the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with concerns before you approach the ICO so please contact us in the first instance.
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Full name of legal entity:
+44 (0) 1628 947 847