PRIVACY POLICY
SEEWOO UK LIMITED
DATA PROTECTION INFORMATION NOTICE
1. Introduction
1.1. In this notice, “we”, “us” and “our” refer to SeeWoo UK Limited, a company incorporated in England and Wales (company number 10812273) with its registered office at Tavistock House South, Tavistock Square, London WC1H 9LG.
1.2. We are committed to safeguarding the privacy of all individuals whose personal data we store and process; in this notice we explain how we will handle your personal data.
1.3. This notice applies where we are acting as a data controller with respect to your personal data; in other words, where we determine the purposes and means of the processing of that personal data.
2. How we may collect your personal data
2.1. If you request a proposal from us in respect of the products or services we provide.
2.2. You or your employer engages us to provide products / services and also during the provision of those products / services.
2.3. You contact us by email, telephone, post or social media for example to seek information, request information or for any other reason relating to the products / services we provide.
2.4. When you subscribe to any of our marketing communications including email product or service updates, newsletters, event invitations, and competition entries.
2.5. When you apply for a job vacancy by email, post, social media, via third parties or via our website.
3. How we use your personal data
3.1. In this section we have set out:
3.1.1. The general categories of personal data that we may process.
3.1.2. In the case of personal data that we did not obtain directly from you, the source and specific categories of that data.
3.1.3. The purposes for which we may process personal data.
3.1.4. The legal bases of the processing.
3.2. We may process your account data (“account data”). The account data may include your name, postal address, telephone number and email address. The source of the account data is you or your employer. The account data may be processed for the purposes of providing our products and services, ensuring the security of our products and services, maintaining back-ups of our databases and communicating with you.
3.3. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
3.4. We may process your personal data that is provided in the course of the use of our products and services (“sales data”). The source of the sales data is you or your employer. The sales data may be processed for the purposes of providing our products and services, ensuring the security of our products and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our business and provision of products and services relevant to you or your business.
3.5. We may process information relating to transactions, including purchases of goods and services that you enter into with us (“transaction data”). The transaction data may include you or your employers contact details, bank account or card details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions.
3.6. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely the proper administration of our business and provision of products and services relevant to you or your business.
3.7. We may process information that you provide to us for the purpose of subscribing to our email notification and/or newsletters and for competition entries (“notification data”). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract, and our legitimate interests, namely the proper administration of our business and provision of our products and services relevant to you or your business.
3.8. We may process information contained in or relating to any communication that you send to us (“correspondence data”). The correspondence data may include the communication content and metadata associated with the communication. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our business and provision of products and services relevant to you or your business.
3.9. We may process any of your personal data identified in this notice where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
3.10. In addition to the specific purposes for which we may process your personal data set out in this section, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
3.11. Please do not supply any other person’s personal data to us, unless we prompt you to do so.
4. Providing your personal data to others
4.1. We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
4.2. We may disclose all areas of personal data set out in section 2 above to any other
4.3. companies within the SeeWoo Group, our suppliers or subcontractors insofar as reasonably necessary for the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract, and our legitimate interests, namely the proper administration of our business and provision of products and services relevant to you or your business.
4.4. In addition to the specific disclosures of personal data set out in this section, we may disclose your personal data with third parties where we are required by law, where it is necessary to administer the relationship between us or where we have another legitimate interest in doing so. Services provided by third parties include: IT and cloud services, professional advisory services, marketing services, audit confirmation services and banking services.
5. Retaining and deleting personal data
5.1. This section sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
5.2. Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
5.3. We will retain your personal data for a minimum period of 1 year and for a maximum period of 7 years following 25 May 2018.
5.4. Sales data will be retained for a minimum period of 1 year and for a maximum period of 10 years following 25 May 2018.
5.5. Transaction data will be retained for a minimum period of 1 year and for a maximum period of 10 years following 25 May 2018.
5.6. Notification data will be retained for a minimum period of 1 year and for a maximum period of 10 years following 25 May 2018.
5.7. Correspondence data will be retained for a minimum period of 1 year and for a maximum period of 10 years following 25 May 2018.
5.8. In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases the period of retention of all categories of data will be determined based on reasonable need and the legitimate interest on which the data is being held.
5.9. Notwithstanding the other provisions of this section, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
6. Security of personal data
6.1. We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.
6.2. We will store all your personal data on secure servers, personal computers and mobile devices, and in secure manual record-keeping systems.
6.3. You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
7. Amendments
7.1. We will publish changes to this notice on our website at www.seewoouk.com
7.2. We will notify you of any changes to this notice which may affect you by e-mail or post.
8. Your rights
8.1. In this section, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
8.2. Your principal rights under data protection law are:
8.2.1. The right to access.
8.2.2. The right to rectification.
8.2.3. The right to erasure.
8.2.4. The right to restrict processing.
8.2.5. The right to object to processing.
8.2.6. The right to data portability.
8.2.7. The right to complain to a supervisory authority.
8.2.8. The right to withdraw consent.
8.3. You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
8.4. You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
8.5. In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed.
8.6. You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
8.7. To the extent that the legal basis for our processing of your personal data is:
8.7.1. Consent; or
8.7.2. Processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine- readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
8.8. If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
8.9. To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
8.10. You may exercise any of your rights in relation to your personal data by written notice to us, in addition to the other methods specified in this section.
9. Our details
9.1. Our full legal name is SeeWoo UK Limited.
9.2. We are registered in England and Wales under registration number 10812273, and our registered office is at Tavistock House South, Tavistock Square, London WC1H 9LG.
9.3. Our principal place of business is at Unit 8, Premier Park Road, London, NW10 7NZ.
9.4. You can contact us:
9.4.1. By post, at the postal address above.
9.4.2. Using our website contact form at www.seewoouk.com.
9.4.3. By telephone, on 020 33 886688
9.4.4. By email, to info@seewoouk.com.