Privacy Policy

INTRODUCTION

Welcome to Cinolla Software Limited’s Privacy Policy.

Cinolla Software Limited respects your privacy and is committed to protecting your personal data. This Privacy Policy will inform you we look after your personal data (including when you visit our website (https://www.cinolla.com) or when you access the Cinolla Activity Platform) This Policy also tells you about your privacy rights and how the law protects you.

Cinolla Software Limited (“we”, “us” or “our”) is the data controller with responsibility for your personal data. Our address is 26 Caledon Road, Lower Parkstone, Poole, Dorset, BH14 9NN.

We have appointed a Data Protection officer (DPO) and their details are below. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the DPO using the details provided.

Data Protection Offer: Rob Brasington

Email address: dataofficer@cinolla.com

Telephone number: 01202 937620

CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

This version was last updated on 25 February, 2020.

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.

THIRD-PARTY LINKS

This website 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 statements. When you leave our website, we encourage you to read the Privacy Policy of every website you visit.

THE 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 depending on who you are which we have grouped together in the following categories:

Identity Data which includes: title and full name.

Contact Data which includes: address, email address and telephone numbers.

Technical Data which includes internet protocol (IP) address, your login data, 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 this website, and aggregated statistical data.

Financial Data which includes bank details.

For the avoidance of doubt, we do not collect any special categories of personal data about you. Special categories of data include 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. Similarly, we do not 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, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

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 and Contact by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

apply for our products or services; or
request marketing to be sent to you.

Automated technologies or interactions. As you interact with our website, or use our Cinolla Activity Platform, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies (as defined below).

Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources. We collect Technical Data via our analytics providers such as Google based outside the EU.

COOKIES

For information about how we use cookies on our website, please refer to our Cookies Policy at https://cinolla.com/cookie-policy/.

HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Where we need to perform the contract we are about to enter into or have entered into with you.

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.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by following the instructions contained in the marketing message or by contacting us on dataofficer@cinolla.com.

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.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To process and deliver your (or your employer's) order including to: (a) Register you (or your employer) as a new customer (b) Manage payments, fees and charges (c) Collect and recover money owed to us (d) Discuss the suitability of our platform and manage any subsequent demos or trials of that system	(a) Identity (b) Contact (c) Financial	(a) Where you are our customer, performance of a contract with you (including taking pre-contractual steps) (b) Where you are an employee or representative of our customer, necessary for our legitimate interests (to manage payments, fees and charges, collect and recover monies due to us, manage the contract or relationship between us and your employer, including in the event of a dispute)
To provide the Cinolla Activity Platform, including related services	(a) Identity (b) Contact	Performance of a contract with you (including taking pre-contractual steps)
To manage our relationship with you which will includes notifying you about changes to our terms and conditions or privacy policy	(a) Identity (b) Contact	(a) Performance of a contract with you (including taking pre-contractual steps) (b) Necessary to comply with our legal obligations (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To administer, protect and improve our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data, conducting data analytics)	(a) Identity (b) Contact (c) Technical	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise, defining types of customers for our products and services, keeping our website updated and relevant, developing our business and to inform our marketing strategy) (b) Necessary to comply with our legal obligations
Marketing to our existing customers and those who have negotiated contracts with us.	(a) Identity (b) Contact	Necessary for our legitimate interests (to develop our products/services and grow our business)
Managing the relationship with contractors and suppliers, including their employees and representatives, to include: (a) Negotiating, entering into and administering contracts. (b) Making payment. (c) Keeping proper administrative records.	(a) Identity (b) Contact (c) Financial	(a) Performance of a contract with you (including taking pre-contractual steps) (b) Necessary for our legitimate interests (to administer the relationship between us and our contractor/supplier where you are their employee or representative, including in the event of a dispute)

MARKETING COMMUNICATIONS

You will receive marketing communications from us if you have opted-in to receive them. We may also send you marketing communications if you are an existing or former customer of ours and you have not otherwise opted-out of receiving marketing communications from us. You can opt-out of receiving marketing communications by leaving certain boxes unticked when you provide your contact information to us, by following the instructions in our marketing communications, or by contacting us at any time.

THIRD-PARTY MARKETING

We will get your express opt-in consent before we share your personal data with any company outside Cinolla Software Limited for marketing purposes.

DISCLOSURES OF YOUR PERSONAL DATA

We share your personal data with the parties set out below for the purposes set out in the table above.

Companies within our corporate group. Other companies in our group for business efficacy. Those companies adhere to the same high standards of data processing as we do.
External service providers. Including service providers acting as processors or hosts who provide IT and system administration services and service agents for support and delivery companies for the transportation of products. Such third parties are subject to contractual terms which uphold the processing standards set out in current data protection law.
Our professional advisers. Including solicitors, barristers, bankers, auditors and insurers based in the United Kingdom or EEA who provide consultancy, banking, legal, insurance and accounting services. Our advisers are subject to duties of professional confidentiality.
Regulators and public authorities. Who require reporting of processing activities in certain circumstances.
Third parties to whom we may choose to sell, transfer, or merge parts or all of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. All disclosures would be made in accordance with current data protection law.

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.

INTERNATIONAL TRANSFERS

We do not transfer your data outside of the EEA. We will notify you should this position change.

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. 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.

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

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. We typically retain personal data for the periods set out below:

Customer and supplier information (including contact details of their employees and representatives) where Cinolla enters into a contract, seven years from the date of termination of the contract.
Customer and supplier information (including contact details of employees and representatives) where a contract is not entered into - three years from the last communication between the parties concerning that matter.

In some circumstances you can ask us to delete your data: see Request erasure of your personal data, below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) in which case we may use this information indefinitely without further notice to you.

YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data as listed below:

Request access to your personal data (commonly known as a "data 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. You will not have to pay a fee to access your personal data. 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.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though 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.
Object to processing of your personal data where we are relying on a legitimate interest 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.
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.
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 services to you. We will advise you if this is the case at the time you withdraw your consent.

Please email us on dataofficer@cinolla.com if you wish to exercise any of these rights.

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.

COMPLAINTS

You have the right to make a complaint to the Information Commissioner’s Office (ICO), (www.ico.org.uk) if you have concerns about our data processing activities. We would, however, appreciate the chance to address your concerns before you approach the ICO and would appreciate you contacting us in the first instance by email to dataofficer@cinolla.com or by post to Cinolla Software Limited, 26 Caledon Road, Lower Parkstone, Poole, Dorset, BH14 9NN.

FURTHER INFORMATION

If you wish to learn more information or have a question about your Personal Data or cookies please email us on dataofficer@cinolla.com with the title of your question in the email header.