1. Introduction

This privacy notice provides you with details of how we collect and process your personal data, in accordance with the General Data Protection Regulation (GDPR), the Data Protection Act 2018, and any other national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK (‘Data Protection Legislation’).

cloudDNA Ltd, an IT consultancy practice, is the data controller and we are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).  We are registered in England and Wales as a limited liability company under number 08280734 and our registered office and postal address is 11 Castle Hill, Maidenhead, Berkshire, SL6 4AA.  Our email address [email protected].

If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk).  We would be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.

It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at [email protected].

Sensitive Data

We do not collect any Sensitive Data about you.  Sensitive data refers to data that 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.  We do not collect any information about criminal convictions and offences.

2. How we may collect your Personal Data

 We obtain personal data about you, for example, when:

• You request a proposal from us in respect of the services we provide.
• You or your employer or our clients engage us to provide our services and also during the provision of those services.
• You contact us by email, telephone, post, website contact form, social media or speak to us at an event when you have a query about our services.
• You use our site clouddnagroup.com including any information you may provide through our site when you enquire about a product, or event, sign up to our newsletter, or take part in a prize draw or competition.  By providing us with your data via our site, you warrant to us that you are over 13 years of age.
• As you use our site we may automatically collect Technical Data about your equipment, browsing actions and usage patterns.  We collect this data by using cookies, server logs and similar technologies.  We may also receive Technical Data about you if you visit other websites that use our cookies.  Please see our cookie policy at https://clouddnagroup.com/cookie-policy for further details.
• From third parties and/or publicly available resources (for example, from your employer, from Companies House or from analytics providers such as Google based outside the EU).

3. The kind of information we hold about you

 The information we hold about you may include the following:

• Your personal details including your name, address, marital status, title,  gender, place of work, job title,email address and telephone numbers.
• Details of contact we have had with you in relation to the provision, or the proposed provision, of our services.
• Details of any services you have received from us.
• Our correspondence and communications with you.
• Information about any complaints and enquiries you make to us.
• Information from research, surveys, and marketing activities.
• Information we receive from other sources, such as publicly available information, information provided by our vendors or information provided by your employer or our clients.
• Technical data including your internet protocol address, browser type and version browser plug-in types and versions, time zone setting and location, operating system and platform, and other technology on the devices you use to access our site.

We may also process Aggregated Data from your personal data but this data does not reveal your identity and as such in itself is not personal data. An example of this is where we review your data to work out the percentage of website users using a specific feature of our site.

4. How we use your Personal Data

We will only use your personal data when legally permitted.  The most common uses of your personal data are:

• Where we need to perform the contract with you, or your employer, or our clients.
• We may process your personal data where needed to perform our contract with our clients. This may include processing your personal data where you are an employee, subcontractor, supplier or customer of our client.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

Please note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data.

Generally, we do not rely on consent as a legal ground for processing your personal data, other than in relation to sending marketing communications to you via email. You have the right to withdraw consent to marketing at any time by emailing us at [email protected].

Purposes for processing your Personal Data

Set out below is a description of the ways we intend to use your personal data and the legal grounds on which we will process such data.  We have also explained what our legitimate interests are where relevant.

We may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your data.  Please email us at [email protected] if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Marketing communications

You will receive marketing communications from us if you have:

• Requested information from us or purchased goods or services from us; or
• If you provided us with your details and ticked the box at the point of entry of your details for us to send you marketing communications; and
• In each case, you have not opted out of receiving that marketing.

We will not share your personal data with any third party for marketing purposes.

You can ask us to stop sending you marketing messages at any time by emailing us at [email protected].

Where you opt out of receiving our marketing communications, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.

5. Disclosures of your Personal Data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above:

• Service providers who provide IT, cloud and system administration services.
• Vendors who produce the products that we supply to you.
• Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance, marketing and accounting services.
• HM Revenue & Customs, regulators and other authorities based in the United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances.
• Service providers who provide checks to verify identity and address in accordance with anti money laundering legislation.
• Credit reference agencies who help us understand any financial risk that we may be exposed to.
• Professional services organisation who may work on our behalf to help deliver your project.

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law.  We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

6. Transferring Personal Data outside of the European Economic Area (EEA)

Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.

Many of our third parties service providers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; or
• Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or
• Where we use providers based in the United States, we may transfer data to them if they are part of the EU-US Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.

If none of the above safeguards are available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.

Please email us at [email protected] if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.  In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know such data.  They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data retention

We will only retain your 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.

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.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see below for further information.

In some circumstances we may 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.

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:

• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.

You can see more about these rights at:

https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.

If you wish to exercise any of the rights set out above, please email us at [email protected].

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 may refuse to comply with your request in these circumstances.

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.

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

10. Third-Party links

Our site may include links to third-party websites, plug-ins and applications.  Clicking on those links or enabling those connections may allow third parties to collect or share data about you.  We do not control these third-party websites and are not responsible for their privacy notices.  When you leave our website, we encourage you to read the privacy notice of every website you visit.

11. Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set off access cookies.  If you disable or refuse cookies, please note that some parts of our website may become inaccessible or not function properly.  For more information about the cookies we use, please see https://clouddnagroup.com/cookie-policy.