As a data controller and a data processor Saltwhistle must comply with the GDPR. GDPR refers to the General Data Protection Regulations which came into effect on 25th May 2018.
Data processor: Responsible for processing Personal Data on behalf of a controller.
Data controller: Determines the purposes and means of processing Personal Data.
We value your privacy and we are committed to:
- Not selling your information.
- Keeping your data safe, secure and confidential.
- Using your information lawfully and in accordance with GDPR.
- What information does Saltwhistle collect?
Personal Data is defined in Article 4 GDPR as information relating to an identified or identifiable natural person. An identifiable person can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (IP address) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
We collect Personal Data and any other information which does not fall within that definition above i.e. which cannot be used to reveal a user’s identity. This information may include the browser name, the type of computer and technical information about the users means of connection to our site, such as operating system and the internet service providers utilized. We use this information for product and service improvement.
- Sensitive Information
We collect information about your browsing habits on https://saltwhistle.com and other associated websites discussed in the first paragraph of these policies and through the Saltwhistle web application therefore we ask that you do not send us or disclose to us any sensitive Personal Data (e.g., racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purposes of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation), unless you consent to us processing that data.
- Web Browser Cookies
- How do we collect your Information?
Saltwhistle collects Personal Data and other information in several ways, for instance:
- Through our website: Saltwhistle collects information through our websites when you complete a form.
- Offline: Saltwhistle collects information from you offline during phone calls with our sales representatives and when we attend events i.e. networking events.
- User Consent: Saltwhistle collects information such as user location and address when you voluntarily provide it to us.
- Miscellaneous Information: Saltwhistle obtains information about you from other sources, such as public databases, joint marketing partners and social media platforms, as well as GDPR compliant third parties.
- How do we use your personal information?
Saltwhistle may collect and use user’s personal information for the following purposes:
- Improving and personalising user’s digital experience.
- To send periodical marketing communications including emails which may interest you, in compliance with GDPR.
- To send you information regarding changes to our websites and any changes to our terms and conditions, privacy policies and cookie policies.
- If a user decides to opt-in to our email alerts, they will receive emails that may include company news, updates, related product or service information, etc. If at any time the user would like to unsubscribe from receiving future emails, we include detailed unsubscribe instructions at the bottom of each email.
- To comply with applicable laws and regulations and for other business purposes, such as internal audits and accounting.
- Legal basis
Article 6 of GDPR sets out the six legal grounds for processing Personal Data.
Processing persona data shall be lawful only if one of the following grounds applies:
- Processing is necessary for the performance of a contract with the data subject.
- Processing is necessary for compliance with a legal obligation.
- Processing is necessary to protect the vital interests of a data subject.
- Processing is necessary to perform a task is carried out in the public interest.
- Legitimate Interest.
Saltwhistle’s legal basis for processing Personal Data will vary upon the circumstances in which the Personal Data was collected. In some circumstances, we rely on your consent as our legal basis for processing your Personal Data and, we will also process your information when it is necessary to do so in order to enter into a contract with you or in order to perform a contract with you. We also collect and process Personal Data when it is in our legitimate business interest to do so, such as direct marketing for promoting our services and products to other businesses.
- Retention of Personal Information
We will retain your Personal Data for a period of time consistent with the original purpose of collection discussed in s.5 of these privacy policies. Once the information is no longer necessary to fulfil the specified purpose we will endeavour to promptly delete it.
- Profiling and Automated Decision Making
Profiling and Automated Decision Making: Saltwhistle carries out automated and quasi-automated data processing activities in order to establish what services might be of interest to our clients and when they may be ready to purchase the product. Saltwhistle does not use automated decision-making technologies in circumstances which would result in legal effects to data subjects.
Why does Saltwhistle use this technology? Saltwhistle uses cookie tracking technology to identify key products, topics and services that may be of interest to our customers in order to serve them with relevant, timely and personalised digital communications.
- How do we protect your Personal Data?
We have implemented appropriate organisational, technical and administrative measures to protect Personal Data stored by Saltwhistle, including security controls to protect against alteration, disclosure and destruction of your Personal Data and to prevent any unauthorised access to our systems.
- Sharing your personal information
We do not sell, trade, or rent users’ personal identification information to others. We will not allow unrelated third parties and companies to use your personal information for any purpose without your consent.
We may share your information with;
- Sub-processors (Service Providers): We engage various companies to perform tasks on our behalf such as web hosting and developers, operating our mailing services. When we share your information to our service providers, we require our service providers to maintain a level of privacy, confidentiality and security in accordance with the relevant laws and regulations.
- With third-party search engines that may index user profile pages and usernames as part of the URL of the user profile page by default.
- Business transfers: We may disclose Personal Data to third parties in the event of sale, merger and acquisition, corporate restructuring or disposition of any portion of our company.
- Disclosure to law enforcement agencies: We may release Personal Data to public and government authorities when we reasonably believe that disclosure is necessary, to protect our rights, for tax enforcement, to investigate fraud and for national security purposes.
- International transfers of Information
Saltwhistle will only make international data transfers to the United States when it is necessary to do so in order to fulfil a contractual obligation between the data subject and the controller. All international data transfers are made to trusted service providers which are under a contractual obligation not to misuse your data. Any of your data which is transferred to the US will be protected under the EU-US Privacy Shield.
EU-US Privacy Shield
The EU-US privacy shield framework protects fundamental rights of anyone in the EU whose Personal Data is transferred to the United States for commercial purposes.
Saltwhistle will store all data in the EU, wherever possible.
- Information regarding children
This website is not intended for minors under the age of 18. Saltwhistle does not knowingly or intentionally collect information about minors under the age of 18. If you believe that we have mistakenly collected such information, please contact us at email@example.com so we can erase the information from our systems.
- Your rights under GDPR
Articles 13 to 22 of GDPR define your data protection rights under EU law.
Your rights are the following:
- The right to be informed.
- The right of access (subject access request).
- The right to rectification.
- The right to erasure (right to be forgotten)
- The right to restrict processing.
- The right to data portability.
- The right to object.
- Rights on profiling and automated decision-making.
Saltwhistle is eager to protect your rights under GDPR, therefore If you have any queries or concerns regarding your rights please do not hesitate to contact us at firstname.lastname@example.org.
In the unlikely event that you do not receive a response within 30 days you have the right to contact the Information Commissioners. Officer Wycliffe House, Water Lane, Wilmslow, SK9 5AF, Email: https://ico.org.uk/global/contact-us/email or telephone: 0303 123 1113.
- Your Acceptance of these terms
- Breach Notification
In the unlikely event of a data breach we will notify our subscribers, customers and the Information Commissioners Office without undue delay, and in any event within 72 hours after becoming aware of a Personal Data breach.
What is a Personal Data breach? For the purposes of GDPR a Personal Data breach is the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, Personal Data.
- Contacting us