Privacy Policy

Privacy Policy

Cirrico Limited (“we/us/our”) respects your privacy and is committed to protecting your personal data.  

This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

There is a Glossary in section 11 to help you understand the meaning of some of the terms used in this privacy policy.

1. Important information and who we are

Purpose of this policy

This privacy policy aims to give you information on how we collect and process your personal data through your interactions with us (e.g. engaging us to provide services, making enquiries or browsing our website – cirrico.com).

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing notice that we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your personal data.  This privacy policy supplements other notices and policies and is not intended to override them.

Controller

We are Cirrico Ltd, a company incorporated and registered in England and Wales under company number 15242206 with its registered office at C/O Rpgcc, 40 Gracechurch Street, London, England, EC3V 0BT.  We are the controller of your personal data and are responsible to you for its protection.  We are on the data protection register held by the Information Commissioner’s Office under registration number:  ZB622036.

Our data privacy manager is responsible for overseeing questions in relation to this privacy policy.  If you have any questions about this privacy policy, including any requests to exercise your legal rights (please see section 10 for more information on these), please contact us using the details set out below.

Contact details

Our contact details are:

Full name of legal entity:  Cirrico Ltd

Email address:  [email protected]

Postal address:  C/O Rpgcc, 40 Gracechurch Street, London, England, EC3V 0BT, UK (marked for the attention of the Data Privacy Manager)

Telephone number:  020 7526 9201 (please ask to speak to the Data Privacy Manager)

Changes to the privacy policy and your duty to inform us of changes

While this policy is compliant with the law as it stands at the date of publication, data protection is an area that is subject to frequent and substantial change, and so consultation and refinement as to perceived best practice occurs often.  For this reason, we keep this privacy policy under regular review and may have to update it from time to time to remain compliant with the law or its best practice.  We will not always inform you of any changes to this policy, so we recommend that you check this document regularly when interacting with us.

It is important that the personal data we hold about you is accurate and current.  Please keep us informed if your personal data changes during your relationship with us and we will update our records accordingly.

Third-party links

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

1. Customer Data

In providing our services to you, we will come into contact with and process your own customer data, which may include personal data.  We refer in this policy to any data on your own customers that you disclose to us over the course of our working relationship with you as “Customer data”.  This policy is primarily concerned with our collection and use of the personal data of you, our customers, and not Customer data, but this section 2 sets out some important points in respect of Customer data.

We do not actively collect Customer data, in that we will only ever receive that Customer data that you have specifically disclosed to us for the purposes of carrying out our services.  We will store Customer data in our systems while performing services for you, but we do not store it long-term – we only need it to provide our services and once those services are completed, the Customer data is securely deleted.

The various processing activities set out in this privacy policy do not apply to Customer data.  We only process Customer data to the limited extent required for our services, subject always to your specific instructions.

All information that we may come into contact with while working with you, including Customer data, is subject to strict confidentiality obligations and high levels of protection – please see section 8 for more detail.

We do not make any assessment of the Customer data that you give to us and it is your responsibility to ensure that it is complete, accurate and uncorrupted when you disclose it to us.  Unless specifically requested as part of our services, we do not provide a back-up service for Customer data.

You remain responsible to your customers for the Customer data, but we will assist you in ensuring your compliance with your obligations to your customers.  Consequently, should the Customer data contain any special categories of Personal data (see section 3 below for what this means), or otherwise require special treatment over and above that set out in this policy, you must inform us.

1. The personal data we collect about you

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).

We may collect, use, store and transfer different kinds of personal data about you, which we have grouped together as follows:

Identity data.  This is your full name and title.  Where you are part of a company, this may include the full name and title of directors, managers, owners and other key personnel of that company, together with the full name and title of any other employees of yours with whom we might work.

Contact data.  This is the postal address, billing address (if different from the postal address) email address and telephone numbers for a customer business.  This also includes your communication preferences, including for things like marketing that we may look to send to you in accordance with those preferences.

Finance data.  This is your bank account information, or other information required for the payment of our fees.

Engagement data.  This is the detail about our relationship with you and your company and the products and services that we provide to you and your company.  This includes things like:  the precise extent of the services provided to you; all documentation prepared by, or issued to, us in respect of the provision or receipt of our products and services (including all proposals and order forms and all internal policies of ours or yours with which we are expected to comply); all communications in respect of our provision of services to you (including recordings of telephone calls and minutes or notes of meetings had with you); and information about the fees charged and paid over the course of our relationship with you and/or your company.

Technical data.  This is your internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website.  This information may be collected via small data files called “cookies” – please see our cookie policy for more information.

Usage data.  This is information about how you use our website, products and services.  This information may also be collected via cookies – again, please see our cookie policy for more information.

Marketing and communications data.  This is your preferences in receiving marketing from us and/or our third parties and includes a record of what marketing or promotional material we may have sent to you, or to which you have responded.

We may sometimes collect and use 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 it does not directly or indirectly reveal your identity.  An example of Aggregated data is where we may aggregate your Usage data with other Usage data that we have collected in order 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 (i.e. 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.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, or provide incomplete or inaccurate data, we may not be able to perform the contract we have or are trying to enter into with you.  In this case, we may have to cancel the applicable arrangement, but we will notify you if this is the case at the time.

1. How is your personal data collected?

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

Direct interactions.  You may give us your Identity, Contact and Financial data by filling in forms or by corresponding with us by post, phone, email, via the Cirrico portal or otherwise, or by engaging with us to receive our products and services. We will also collect Engagement data via our interactions over the course of an engagement, including via the Cirrico portal.  This includes personal data you provide when you:

• Enquire about our products or services (whether in person, at an event, or by telephone or email);
• Engage us to provide products and/or services;
• Give us information or documentation relating to our provision of products or services, whether or not via the Cirrico Portal;
• Request marketing to be sent to you;
• Give us some feedback; or
• Contact us.

Automated technologies or interactions.  As you interact with our website, we will automatically collect Technical and Usage Data about your equipment, browsing actions and patterns.  We collect this personal data by using cookies and other similar technologies.  Please see our cookie policy for further details.

Third parties or publicly available sources.  We will receive personal data about you from various third parties and public sources who are authorised to share it with us, as set out below:

• Technical and Usage data from analytics providers (we use Google Analytics) and online search engines (e.g. Google, Bing and Yahoo) – please see sections 6 and 7 for more information;
• Contact, Financial and Engagement data from providers of technical, payment and delivery services;
• Identity, Contact and limited Engagement data from third parties recommending us to you (e.g. Salesforce) (only where you have consented for such third parties to do so); and
• Identity and Contact data from publicly available and accessible sources (e.g. Companies House and social media pages).

1. How we use your personal data

We can only use your personal data when the law allows us to – the “lawful bases”.  The lawful bases are as follows:

1. You have consented to such use;
2. The use is necessary for the performance of a contract with you;
3. The use is necessary for compliance with a legal obligation that we owe;
4. The use is necessary to protect your vital interests or those of another person;
5. The use is necessary for the performance of a task carried out in the public interest, or in the exercise of official authority; and
6. The use is necessary for the purposes of our legitimate interests or those of a third party (except where such interests are overridden by your fundamental rights and interests).

For more information on what some of these lawful bases mean, please see the Glossary in section 11.  Most commonly, we will use your personal data under the lawful bases identified in 2, 3 and 6 above.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email.  You have the right to withdraw consent to marketing at any time by contacting us using the details given above.

Purposes for which we will use your Personal data.

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so.  We have also identified what our legitimate interests are where appropriate.

Note that 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 contact us 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 and promotions

We may use your Identity, Contact, Technical and Usage data to form a view on what we think you may want or need, or what may be of interest to you.  This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You may receive marketing communications from us if you have requested information from us or purchased services from us in the past and you have not opted out of receiving that marketing.  We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.  Where you opt-out of receiving these marketing messages, this will not apply to personal data provided to us as a result of your engagement of us.

Change of purpose

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 using the details given above.

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.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

1. Disclosures of your personal data

We will only process your data for the purposes set out in section 5 above, which may be carried out by our employees or sub-contractors who are based outside of the United Kingdom and the European Economic Area (EEA), from time to time. We may also have to share your personal data with the parties set out below for the purposes set out in section 5 above.  If any of our employees or any of these organisations are based, or have group or affiliated companies that are based, outside of the United Kingdom and the EEA, then section 7 below sets out the legal basis on which your personal data is transferred to them.

• We are an authorised partner of Salesforce.com, Inc., acting through its UK subsidiary – Salesforce.com EMEA Limited – and we have to share Identity and limited Engagement data with Salesforce.com, Inc. and its affiliated companies in Europe and the USA from time to time in order to remain an authorised partner and to provide services to you.
• We work with professional advisers, acting as processors or separate or joint controllers (as necessary), to provide certain professional services to us.  As part of this, we may disclose to them some of your Personal data.  In this category we include lawyers, bankers, accountants, auditors and insurers based in the United Kingdom.
• From time to time we may need to disclose Personal data to HM Revenue & Customs and other public authorities acting as processors or separate or joint controllers (as necessary) based in the United Kingdom who require reporting of processing activities in certain circumstances.
• We use a cloud-based customer relationship management solution provided by Salesforce.com EMEA Limited, part of the Salesforce Group ultimately controlled by Salesforce.com, Inc. (a company incorporated in the USA).  While Salesforce does have servers in the EU, there is a chance that some personal data may be passed to the USA.
• Certain elements of our services are sub-contracted to trusted third parties.  In particular our backup service is provided by OwnBackup, Inc., which is a company incorporated and registered in the USA and is also an authorised partner of Salesforce.com, Inc. OwnBackup, Inc. do not access or alter any data during the backup process, and the act of backing up data and metadata is the only processing which takes place.    Other sub-contractors may be used as required to perform our obligations under our contract with you, and all data transferred will be subject to the protections set out by UK law or by section 7 below.
• We work with certain other service providers, acting as processors, to help us operate and manage our business.  This includes providers of IT, software and archiving services (such as our website developers, accounting software and IT consultants).
• We work with Google, Inc, which is a company incorporated and registered in the USA for their analytics services in the management of our website.
• Other third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets.  Alternatively, we may seek to acquire other businesses or merge with them.  If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy.

We recommend that for the named third parties set out above, you visit their respective websites and read their privacy policies, which will set out in more detail these organisations’ own approach to the protection of your Personal data and privacy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law.  We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.  All disclosures are subject to confidentiality and non-disclosure obligations, whether arising under contract, law or professional conduct rules.  We use contractual obligations, or other equivalent measures, to ensure that all third parties in receipt of your personal data from us comply with data protection law.

1. International transfers

For transfers of personal data outside of the UK, but within the European Economic Area (EEA), no additional protective measures beyond the contractual obligations mentioned need to be put in place as data protection law offers the same level of protection and rights to data subjects across all of the EEA.  However, some of our employees or some of the third parties identified in section 6 above are based outside the EEA, or have group or affiliated companies based outside of the EEA, so their processing of your Personal data may involve a transfer of data outside the EEA.

Whenever we transfer your Personal data out of the United Kingdom and the EEA, we ensure that a similar degree of protection as that afforded to it by UK law is given by implementing any of the following options:

• Only transferring your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the UK government;
• We may incorporate Standard Contractual Clauses and the International Data Transfer Addendum by way of reference into our Master Services Agreement, as approved by the UK government and the ICO.  For further details, see https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/international-transfers-after-uk-exit/.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the United Kingdom and the EEA.

1. Data security

We have put in place appropriate technical and security measures to prevent your Personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed, including using firewalls, anti-virus software, password protection and the use of encryption software.  All data is held on secure cloud-based servers that are encrypted and backed up regularly.  We limit access to your personal data only to those employees, agents, contractors and other third parties who have a business need to know.  They will only process your Personal data on our instructions and they are subject to a duty of confidentiality.  We have internal procedures in place to monitor, control and limit employee access to personal data and to ensure that all employees comply with our internal access control policy and are appropriately trained in their data protection obligations.

We have been awarded the ISO27001:2013 ‘Managing Information Security’ certification from The British Assessment Bureau which is subject to annual assessments to remain valid. As such, we are subject to regular internal and external audit to ensure that we follow the stringent data security procedures recommended by the certification.

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.

• 1. Retention of Data

How long will you use my Personal data for?

We will only retain your Personal data for as long as reasonably necessary to fulfil the purposes for which we originally collected it, including for the purposes of satisfying any legal, regulatory, tax, 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, regulatory, tax, accounting or other requirements.

By law, we have to keep certain categories of information for a certain period of time.  This includes:

• Basic information about all our customers including Contact, Identity and Engagement data, and some Finance data for 6 years after they cease being customers; and
• VAT and other tax records in respect of customers for 6 years after they cease being a customer for tax purposes.

Please see our cookie policy for information on the duration of the cookies that we use.

We may retain your personal data for longer periods than those stated above in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect of our relationship with you.

After the relevant retention period has expired, we will securely delete or destroy your personal data and ensure that any third parties to whom we may have disclosed your personal data does so too.

In some circumstances you can ask us to delete your data before the retention period has expired – the Right to Erasure.  Please see section 10 below for more information.

• 1. Your legal rights

Your rights

Under certain circumstances, you have rights under data protection laws in relation to your Personal data.  These rights are 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 of your Personal data;
• Request transfer of your Personal data; and
• Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us using the contact details given above.

No Fee 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 may refuse to comply with your request in these circumstances.

Time limit to respond

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.

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk).  We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

• 1. Glossary

Lawful basis

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience.  We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests.  We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).  You can obtain further information about how we assess out legitimate interests against any potential impact on you in respect of specific activities by contacting us using the details given above.

Performance of a Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligations to which we are subject.

Your legal rights

You have the right to:

• Request access to your personal data (commonly known as a “subject access request”).  This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it;
• Request correction of the personal data that we hold about you that may be incomplete or inaccurate.  Please note that we may need to verify the accuracy of the new data you provide to us;
• Request erasure of your personal data.  This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it.  You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law.  Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons, which will be notified to you, if applicable, at the time of your request;
• 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.  You also have the right to object where we are processing your personal data for direct marketing purposes.  In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms;
• Request restriction of processing of your personal data.  This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it;
• Request the transfer of your personal data to you or to a third party.  We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format.  Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you; and
• 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 you withdraw your consent.  If you withdraw your consent, we may not be able to provide certain products or services to you.  We will advise you if this is the case at the time you withdraw your consent.