Privacy Policy

Service95 Privacy Policy

Last updated: 24 May 2022

 

OUR PRIVACY PROMISE

This website www.service95.com/ (including Service95 newsletter) (the “Website“) is operated by Service95 Limited  (“we“, “us” and “our“).  Your privacy is important to us and we are committed to protecting your personal data and being transparent about the personal data we hold and use and, wherever possible, giving you choice over how we use your personal data.

This policy is intended to inform you in a concise, transparent, intelligible and easily accessible manner about our privacy practices and your legal rights as a data subject, but we appreciate that you may have queries or want to seek clarification as to its terms. If so, please contact us (using the details set out at the “Who We Are and Our Contact Details” section below) and we will endeavour to respond to you as soon as possible.

We may make changes to this policy from time to time, including as may be necessary or prudent to reflect any changes in the ways we process your personal data or any changes in data protection laws.  Any updates to this policy will be posted on the Website, so please check this policy regularly so that you are aware of any changes.  

 

INTRODUCTION

Please read this policy carefully. Among other things, it explains:

• What personal data we collect about you;
• Why we collect and use your personal data and the legal bases we rely on for processing;
• Who we disclose your personal data to;
• Where we store your personal data;
• How long we keep your personal data; and 
• Your rights regarding the personal data you provide to us. 

 

WHO WE ARE AND OUR CONTACT DETAILS

For the purposes of data protection laws, the data controller is Service 95 Limited, a company registered in England and Wales (company no. 13451669) with its registered office at 88-90 Baker Street, London, United Kingdom W1U 6TQ. 

If you have any queries regarding this policy or the way in which we process your personal data, please contact us at dataprotection@service95.com.

 

CHANGES TO YOUR PERSONAL INFORMATION

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes or if you become aware that any personal data that we hold about you is not accurate.

 

HOW IS YOUR PERSONAL DATA COLLECTED

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

1. Direct interactions. You may give us information about you when you:

• subscribe to our services or publications (our “newsletter“) on or through the Website;
• request marketing to be sent to you;
• correspond/interact with us via email, phone, social media or other channels; or
• participate in competitions, surveys and questionnaires or provide us with a review or feedback.

2. Third parties. Where lawful, we may also obtain personal data from third parties (including third party platforms) and we may process that information where it is needed in order to provide our newsletter to you, including where it is needed for our internal administrative purposes or for marketing and business development purposes. 
3. Automated technologies or interactions. We may also automatically collect certain Technical Data (as defined below) relating to your device and your activities on the Website. We may also collect such data from third parties such as analytics providers and third party platforms and organisations within advertising networks (including Facebook).

 

WHAT PERSONAL DATA WE COLLECT

The type of personal data we process may include (as applicable) the following:

Categories of Data	Description of Data
Identity Data	Name and any details which we might obtain from your email address or email content (including signature) or from any profile data that is publicly available (e.g. your Facebook profile).
Contact Data	Your email address, city, and phone number.
Correspondence Data	Information which you provide in, or we learn about you from, any correspondence or communications with us, including details of any enquiries or requests for technical support or customer care support and any other information you provide to us.
Usage Data	Device IP address, the pages of the Website that you visit, usage information for the Website, your use of social sharing features such as Likes, comments and links that you share (e.g. via Facebook Comment or Share).
Technical Data	Type of device, unique device identifier (e.g. an IMEI number, IDFA, IP, or Mac address), network information, the type of operating system, platform and browser you use, location, time zone settings and other device related information and online identifiers.
Marketing and Communications Data	Your marketing preferences and communication preferences and any information that you may provide to us in any reviews or feedback.

 

Information about why we process the above personal data and the lawful basis we rely upon is set out in the table at “Why We Collect and Use Your Personal Data” section below. 

Children Data: you must be able to give us consent in order to sign up to receive our newsletter. In the UK, that means you must be 13 years old or over. Elsewhere in the EEA, you must be 16 years old or over. If you are not above the required age, you may not access the Website or newsletter other than through your parent or guardian consent.

We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

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.

 

WHY WE COLLECT AND USE YOUR PERSONAL DATA

 

3. We use your personal data for a number of purposes but only where we are allowed to by the law.  
4. We may process your personal data in any circumstances where such processing is necessary or permitted:
   • in order to perform any agreement we have entered into with you or in anticipation of any agreement we may enter into with you (e.g. to receive our newsletter);
   • to comply with any applicable law or regulation; and/or
   • for the purposes of the legitimate interests pursued by us or a third party. These legitimate interests include the purposes identified in the table below at “Why We Collect and Use Your Personal Data” section, but also include other commercial interests and our internal administrative purposes. Where we rely on legitimate interests as the lawful basis for processing your personal data, we will put in place appropriate safeguards to protect your data and to ensure that your interests or fundamental rights and freedoms are not overridden by those legitimate interests.
5. We may also process your personal data where we have your consent. Where we rely on consent as the lawful basis for processing your personal data, you have the right to withdraw your consent at any time and if you wish to do so, you should contact us using the contact details set out at “Who We Are and Our Contact Details” section above. Where we obtain your consent to send you marketing communications, you can unsubscribe by following the unsubscribe link within the communication. The withdrawal of consent does not affect the lawfulness of processing based on consent before withdrawal or the lawfulness of processing based on other lawful grounds.
6. We may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. 
7. Information about the purposes for which we use your personal data, the types of personal data we process to achieve these purposes, and the lawful basis by which we process it, is set out in the table below:

 

Purpose/Activity	Type of Personal Data Processed	Lawful Basis for Processing
Registration To register you to receive our newsletter	·  Identity Data ·  Contact Data	·  Performance of a contract with you
Provision of our newsletter To provide our you with our newsletter.	·  Identity Data ·  Contact Data ·  Correspondence Data ·  Usage Data ·  Technical Data	·  Performance of a contract with you ·  Our legitimate interests to operate our business
Business Operation and Maintenance To operate and protect the Website and our social media channels (including troubleshooting, incident management and data breach management, data analysis, product and system testing, system maintenance, support, reporting and hosting of data)	·  Identity Data ·  Contact Data ·  Correspondence Data ·  Usage Data ·  Technical Data	·  Compliance with a legal obligation ·  Our legitimate interests to operate and improve our business, fulfil our legal and contractual obligations and for the purposes of IT security
Customer Relationship Management To manage our relationship with our customers which includes notifying you of any changes to our terms or this policy or to our newsletter, to respond to enquiries, messages, and requests for technical support and customer care support	·  Identity Data ·  Contact Data ·  Correspondence Data ·  Usage Data ·  Marketing and Communications Data	·  Performance of a contract ·  Compliance with a legal obligation  ·  Our legitimate interests to respond to enquiries, messages and requests, operate, develop and improve our business
Business Development To use data analytics to improve the Website (in particular, content of our newsletter), marketing customer relationships and experiences	·  Usage Data ·  Technical Data	·  Our legitimate interests to define types of customers for our products and services, develop and improve our business and to inform our marketing strategy
Surveys To enable you to take part in a prize draw, competition or complete a survey	·  Identity Data ·  Contact Data ·  Usage Data ·  Marketing and Communications Data	·  Performance of a contract with you ·  Our legitimate interests to study how customers use our products/ services, to develop them and grow our business.
Marketing and Advertising To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	·  Identity Data ·  Contact Data ·  Usage Data ·  Marketing and Communications Data ·  Technical Data	·  Our legitimate interests to study how customers use our products/ services, to develop them and grow our business.

 

1. 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. 
2. If we need to use your personal data for an unrelated purpose, we will notify you (which may be by way of update to this policy) and we will explain the legal basis which allows us to do so.
3. Please note that we may process your personal data without your knowledge or consent where this is required or permitted by law.

 

WHAT IF YOU REFUSE TO PROVIDE US WITH ANY PERSONAL DATA?

Where we need to collect personal data by law, or under the terms of an agreement we have with you, and you fail to provide that data when requested (or fail to consent to the processing of that data, if necessary), we may not be able to perform the agreement or arrangement we have or are trying to enter into with you. For example, without your consent and without you having given us accurate contact details we will be unable to provide you with our newsletter.

 

SHARING INFORMATION WITH THIRD PARTIES 

1. We will not share any of your personal data with third parties except as set out in this section or otherwise notified to you or agreed between you and us from time to time. 
2. We may share personal data with our partnered companies for the purposes outlined in this policy. We may also share personal data with third party service providers who we engage to provide services which facilitate our business. We may also need to share personal data with other third parties in order to comply with our legal and regulatory obligations. Below is a list of specific third parties and other categories of third parties with whom we may share your personal data: 
   • Sailthru, operated by Sailthru, Inc., our newsletter distribution provider;
   • GoDaddy, operated by GoDaddy, Inc., our hosting provider;
   • Law enforcement or a regulator; and
   • Legal counsel and other professional advisers including accountants and auditors.
3. We ensure that any third party engaged by us who processes your personal data in connection with the purposes listed above has policies and procedures in place to ensure compliance with data protection laws. 
4. For any third parties that are based or process data outside of the UK or the EEA, we engage such third parties in accordance with section “International Transfers of Personal Data” below. 
5. In the event that our business or any part of it is sold or integrated with another business, your details may be disclosed to our advisers and those of any prospective purchaser and will be passed to the new owners of the business.

 

INTERNATIONAL TRANSFERS OF PERSONAL DATA

1. From time to time it may be necessary for us to transfer your information internationally. In particular, your information may be transferred to and/or stored on the servers of third parties identified in the section above which are based outside of the UK and the EEA.
   • However, we will not transfer your personal data outside of the UK and the EEA unless: 
   • such transfer is to a country or jurisdiction which the EU Commission or the UK has approved as having an adequate level of protection; or
   • appropriate safeguards are in place in accordance with data protection laws. These safeguards include the use of standard contractual clauses or binding corporate rules; or
2. the transfer is otherwise allowed under data protection laws (including where we have consent or the transfer is necessary for the performance of a contract with the data subject).
3. We will ensure that where your personal data is transferred outside of the UK and the EEA, it is afforded the same protection as would be afforded to it within the UK and EEA.

 

YOUR RIGHTS AS A DATA SUBJECT

1. Subject to any conditions and requirements set out in data protection laws, you may have some, or all, of the following rights in relation to the personal data we hold about you: 

• • the right to request a copy of your personal data held by us;
  • the right to correct any inaccurate or incomplete personal data held by us;
  • the right to request that we erase personal data we hold about you;
  • the right to request that we restrict the processing of your data;
  • the right to have your personal data transferred to another organisation;
  • the right to object to certain types of processing of your personal data by us (e.g. not be subject to a decision based solely on automated processing); and
  • the right to withdraw consent at any time.

No fee is usually required

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 could refuse to comply with your request in these circumstances.

What we may need from you

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.

Time limit to respond

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

No Absolute Right

Please note that these rights are not absolute in all situations and may be subject to certain conditions and provisions set out in data protection laws.  We cannot, therefore, guarantee that we’ll be able to honour any request from you in connection with the rights set out above. (For example, even if you request that we delete your personal data, we may be required by law to retain some personal data for accounting and record keeping purposes or in order that we comply with our legal and regulatory obligations). 

For further information or to exercise any particular right, please contact us at dataprotection@service95.com.

 

RETENTION OF YOUR PERSONAL DATA

1. As a minimum, we need to retain your personal data for as long as is necessary to enable us to fulfil the purpose for which it is processed, including to fulfil our legal and regulatory obligations (e.g. relating to record keeping) and to exercise or defend any legal claims.
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 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, regulatory, tax, accounting or other requirements.
3. If you are signed up to our newsletter, we will delete your personal data once you unsubscribe from our newsletter, unless we have cause to continue processing it (for example due to any on-going purchase of goods or services, or where we are required to keep records of the same).
4. We will notify you without undue delay in accordance with the requirements of data protection laws, if we have reason to believe that there has been a personal data breach by us which could adversely affect your rights and freedoms and we are required by law to notify you.
5. In some circumstances, we will anonymise your 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.

 

LINKS TO THIRD PARTIES 

1. The Website may link or redirect to other websites, social media accounts or other content which is not under our control. Such links or redirections are not endorsements of such websites or representation of our affiliation with them in any way and such third party websites are outside the scope of this policy. 
2. If you access such third party websites or platforms, please ensure that you are satisfied with their respective privacy policies before you provide them with any personal data. We cannot be held responsible for the activities, privacy policies or levels of privacy compliance of any website or platform operated by any third party.

 

COOKIES

1. A cookie is a small file of letters and numbers stored on your browser or the hard drive of your computer. Cookies contain information that is transferred to your computer’s hard drive. We use the word Cookie to include any tracking technologies, including pixels and tags.
2. The Website uses cookies to distinguish you from other users of our Website. This helps us to provide you with a better experience when you browse our website and also allows us to improve our Website.
3. Some data collected by cookies is collected on an anonymous and/or aggregated basis. Where we use cookies that contain personal data, we will only process that personal data as set out in this policy. 
4. Our Websites use some or all of the following cookies:
5. • Strictly necessary cookies. These are cookies that are required for the operation of our Website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.

1. • Analytical/performance cookies. These 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 are finding what they are looking for easily.

1. • Functionality cookies. These are used to recognise you when you return to our Website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

1. • 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.

You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

Cookie

Purpose

Facebook pixel

The Facebook pixel is a piece of code that we use on our Website to allow us to measure the effectiveness of advertising by understanding the actions people take on the Website. The Facebook pixel receives these types of data:   Http Headers – Anything present in HTTP headers. HTTP Headers are a standard web protocol sent between any browser request and any server on the internet. HTTP Headers include IP addresses, information about the web browser, page location, document, referrer and person using the website.   Pixel-specific Data – Includes Pixel ID and the Facebook Cookie.   Button Click Data – Includes any buttons clicked by site visitors, the labels of those buttons and any pages visited as a result of the button clicks.   Optional Values – Developers and marketers can optionally choose to send additional information about the visit through conversion tracking. Example custom data events are conversion value, page type, and more. Form Field Names – Includes website field names like ‘email’, ‘address’, ‘quantity’ for when you purchase a product or service. We don’t capture field values unless you include them as part of Advanced Matching, or conversion tracking.   Facebook’s cookies policy can be found here: https://www.facebook.com/policies/cookies/

 

1. Please note third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies and other technology (e.g. web beacons), over which we have no control. 
2. Your browser may give you the ability to block all or some cookies by activating a setting in your browser’s options. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of the Website.
3. Except for essential cookies, all cookies will remain unless the cookie cache is cleared (unless otherwise indicated in the table above).

 

QUESTIONS AND COMPLAINTS

1. We take our data protection obligations seriously. If you have any questions or complaints about this policy or the way that we handle your personal data, we would appreciate the chance to deal with your concerns in the first instance before you approach the relevant data protection authority. Please contact us using the details provided at the “Who We Are and How to Contact Us” section above.
2. You have the right to make a complaint at any time to the relevant supervisory authority for data protection issues, which in the UK is the Information Commissioner’s Office (ICO) (www.ico.org.uk).