PRIVACY NOTICE

 

Restrata Solutions FZ-LLC and its affiliates and subsidiaries (collectively “we”, “our” or “us”) respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website www.securelocate.com and tell you about your privacy rights and how the law protects you.

 

PURPOSE OF THIS PRIVACY NOTICE  

 

This privacy notice aims to give you information on how we collect and process your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter or purchase a product or service.

 

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

 

If you are unwilling to accept the terms and conditions of this privacy notice, we ask that you do not use the SecureLocate service (“SecureLocate Service”). By using the SecureLocate Service, you agree to the terms of this privacy notice. When you submit information via the SecureLocate Service, you consent to the collection, use and disclosure of that information in accordance with this privacy notice.

 

This privacy notice (together with our end-user license agreement as set out at www.securelocate.com (“EULA”) and any additional terms of use incorporated by reference into the EULA, together our “Terms of Use”) apply to your use of:

           SecureLocate software as the SecureLocate Service and / or the mobile application software (“App”), once you have downloaded and installed a copy of the App onto your mobile telephone or handheld device.

            Any of the services accessible through the App, unless the EULA states that a separate privacy notice applies to a particular service, in which case that privacy policy only applies.

 

CONTROLLER  

 

Restrata Solutions FZ-LLC (“Restrata”) is the controller and responsible for your personal data (collectively referred to as “Restrata”, “we”, “us” or “our” in this privacy notice).

 

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.

 

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

  

We reserve the right to occasionally update this privacy notice. At such time, we will also revise the “last updated” date at the end of the privacy notice. For material changes to this privacy notice, we will notify you by placing a prominent notice on the SecureLocate website. We recommend that you periodically review this Privacy Policy.

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 notice of every website you visit.

 

2.  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 which we have grouped together follows:

 

         Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.

         Contact Data includes billing address, email address and telephone numbers.

         Financial Data includes bank account and payment card details.

         Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.

         Technical Data includes the type of mobile device you use or the mobile phone number used by the device, mobile network information, your mobile operating system, the type of mobile browser you use and time zone setting.

         Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.

         Location Data includes the use of GPS and / or GNSS technology to determine your current location. Some of our location-enabled services require your personal data for the feature to work. You are able to disable the location function at your entire discretion at any time.

         Usage Data includes details of your use of our apps or your visits to any of our websites including, but not limited to, traffic data, location data, weblogs and other communication data and the resources that you access.

         Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

 

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.

 

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.

3.  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 or otherwise. This includes personal data you provide when you:

         create an account on our SecureLocate Service; and

         subscribe to our service.

         Automated technologies or interactions. As you interact with our website or app, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies.

                     Third parties or publicly available sources. We may receive personal data about you from various third parties.

4.  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.

 You have the right to withdraw consent to marketing at any time by contacting us at support@securelocate.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. 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.

 

Purpose/Activity

 

Type of data

 

Lawful basis for processing including basis of legitimate interest

 

To register you as a new customer

 

(a) Identity

(b) Contact

 

Performance of a contract with you

 

To process and deliver your order including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

 

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Marketing and Communications

 

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

 

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

 

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

 

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

 

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

 

(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)

(b) Necessary to comply with a legal obligation

 

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

 

(a) Technical

(b) Usage

 

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

 

 

 

OPTING OUT  

 

You can ask us or third parties to stop sending you marketing messages by contacting us on support@securelocate.com 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 a SecureLocate Service purchase.

 

CHANGE OF PURPOSE  

  

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.

 

6.  INTERNATIONAL TRANSFERS  

  

We share your personal data within the Restrata Group of companies. This will involve transferring your data outside the European Economic Area (EEA). We ensure your personal data is protected by requiring all our group companies to follow the same rules when processing your personal data.

 

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it 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.

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. 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  

 

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.

 

9.  YOUR LEGAL RIGHTS  

 

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

 

         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.

If you wish to exercise any of the rights set out above, please contact us at support@securelocate.com

 

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.

 

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 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.  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).

 

Performance of 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 obligation that we are subject to.