Privacy Policy

This privacy policy is for the website www.supportrobotics.com and for our mobile apps, web applications and services (the “Platforms”) and governs the privacy of their users. It explains how we comply with applicable legislation including the GDPR (General Data Protection Regulation), the DPA (Data Protection Act 2018) and the PECR (Privacy and Electronic Communications Regulations).

Please note that our Platforms may have been rebranded and provided to you by your Internet Service Provider under a licence from Support Robotics Limited, the developer and operator of the Platforms (see "Our role as a controller or processor", below).

This policy will explain how the website or Platforms may affect your privacy and personal details; how we process, collect, manage and store those details and how your rights are protected. Additionally, it will explain the use of cookies and the download or streaming of any documents or media made available to you on our website or Platforms.

Please read this policy carefully together with our Terms and Conditions and any other policies we may publish so you are fully aware of how and why we use your data. This policy supplements these other terms and policies and is not intended to override them.

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact our data protection officer:

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.

Our role as a controller or processor

In some cases, Support Robotics may make versions of the Platforms available on behalf of third parties (the “Third Party Platforms”). These may be websites or mobile applications. The Third Party Platforms will normally be branded with the logo of the relevant third party.

In these cases, Support Robotics is acting as a supplier to the relevant third party. The third party is the controller in relation to any personal data collected or processed via the Third Party Platforms and Support Robotics is the processor, acting on the instructions of the controller. You should refer to the third-party controller’s own privacy policy for information about the collection, use and retention of personal data via the Third Party Platforms. That privacy policy will normally be available on their main website.

If you have any questions or concerns about personal data in relation to a Third Party Platform, you should direct your query to the relevant third party in the first instance.

In all other cases, Support Robotics is the controller of any personal information shared through its website or Platforms and is responsible for your personal data as set out in this privacy policy.

We have appointed a data protection officer who 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 contact the data protection officer using the details above.

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 as follows:

• Identity Data includes first name, maiden name, last name and username or similar identifier.
• Contact Data includes billing address, delivery 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 your device type and specifications, operating system version, internet protocol (IP) address, browser type and version, and performance information relating to the devices you use to access our website or Platforms.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our website or Platforms.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share 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 this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website or Platform 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 (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.

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.

Users contacting us through our website or Platforms do so at their own discretion and provide any personal details at their own risk.

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:
  • enquire about or purchase our services;
  • download our mobile application or other digital content;
  • create an account with us;
  • subscribe to our service or publications;
  • request marketing to be sent to you;
  • enter a competition, promotion or survey; or
  • give us feedback or contact us.
• Automated technologies or interactions. As you interact with our website or Platforms, we will 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. Please see the section on Cookies for further details.
• Third party sources. We will receive personal data about you from various third parties as set out below:
  • Technical Data from the following parties:
    1. analytics providers such as Google based outside the EU;
    2. search information providers such as Google based outside the EU.
  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services based both inside and outside the EU.
  • Identity and Contact Data from publicly available sources such as LinkedIn, Companies House and the Electoral Register based inside the EU.

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 a contract 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 obligation.

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 or text message. You have the right to withdraw consent to marketing at any time by contacting us.

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 basis we are relying on to process your personal data where more than one ground has been set out in the table below.

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

We may use your Identity, Contact, Technical, Usage and Profile 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 will receive marketing communications from us if you have requested information from us or purchased services from us 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 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 a service purchase, service experience or other transactions.

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.

Disclosures of your personal data

The data that we collect about you is usually collected for the purposes of providing our service to our Customers. These may be companies who in turn provide services to you and we therefore share this data with them as part of our services.

We may also share your personal data with the parties set out below for the purposes set out in the table ‘Purposes for which we will use your personal data’ above.

• Service providers, professional advisers or any governmental authority.
• 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.

In the provision of our services to you, we may share your personal data with the third party service providers listed below. A link to each party’s own privacy policy is also included so you can understand more about how they use personal data which they collect:

• We use HubSpot to host our website and CRM. When you complete forms on our website, we store the information provided within HubSpot so that we can process your enquiry. You can read the HubSpot privacy policy here: https://legal.hubspot.com/privacy-policy
• Google provides cloud hosting for our Platforms and analytics services which we use to monitor our website and Platforms. You may opt-out of certain features in your mobile device settings or by following the instructions provided by Google in their privacy policy: https://policies.google.com/privacy
• Measurement Lab (M-Lab) provides technology used in our speed tests. M-Lab publishes test results along with IP addresses in order to promote Internet research. When you run a test, your IP address will be shared with them and processed in accordance with their privacy policy: https://www.measurementlab.net/privacy/
• Twilio provides our Platforms with the capability to communicate with end-users via email, SMS, chat and video. Twilio may need to collect and process certain Personal Information about you to provide these services. To learn more about Twilio's privacy practices, please visit https://www.twilio.com/legal/privacy
• We use geolocation services from ipstack.com, provided by apilayer GmbH. We use their services to provide additional context to our Platform users. To learn more about their privacy policy, please visit https://ipstack.com/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.

We will not sell, distribute or lease your personal information to third parties unless we have your permission or are required by law to do so.

Some of our external third parties are based outside the 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 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. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

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

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.

Any downloadable documents, files or media made available on our website or Platforms are provided to users at their own risk. While all precautions have been undertaken to ensure only genuine downloads are available, users are advised to verify their authenticity using third party anti-virus software or similar applications.

Data retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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.

External Website Links

Although we only aim to include quality, safe and relevant external links, users are advised to adopt a policy of caution before clicking any external web links contained in the website or Platforms. External links are any clickable text / banners / images that point to a domain other than supportrobotics.com.

We cannot guarantee or verify the contents of any externally linked website despite our best efforts. Users should therefore note they click on external links at their own risk and we cannot be held liable for any damages or implications caused by visiting any external links mentioned.

Social Media Policy

We adopt a social media policy to ensure our business and our staff conduct themselves accordingly online. While we may have official profiles on social media platforms users are advised to verify authenticity of such profiles before engaging with or sharing information with such profiles. We will never ask for user passwords or personal details on social media platforms. Users are advised to conduct themselves appropriately when engaging with us on social media.

There may be instances where our website features social sharing buttons, which help share content directly from our web pages to the respective social media platforms. You use these social sharing buttons at your own discretion and accept that doing so may publish content to your social media profile feed or page.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These rights are set out below:

You have the right to:

• 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.
• 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. 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:
• If you want us to establish the data's accuracy.
• Where our use of the data is unlawful, but you do not want us to erase it.
• 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.
• 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 products or services to you. We will advise you if this is the case at the time you withdraw your consent.

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

Accessing your personal data

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 could 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 could 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.

Use of Cookies

Cookies are small files saved to the user’s computer that track, and store information about the user’s interactions and usage of our website and Platforms. Our website and Platforms use cookies for statistical analysis purposes, to help us better understand how users interact with them so that we might improve them in future. These cookies do not give us access to your computer or any personally identifiable information about you.

As required by legislation, our website uses a cookie control system, allowing the user to give explicit permission. By giving permission or continuing to use the website you consent to our use of cookies. Users are advised that if they wish to deny the use of cookies from this website, they should take steps within their browsers security settings to block the saving of cookies.

Our website will continue to operate without cookies, but our Platforms will not. Users of our Platforms are advised to cease using the Platforms if they are uncomfortable with our cookie policy or contact us for further information.

We use different categories of cookies on our website and Platforms as explained further below:

• Authentication cookies . These are cookies that enable you to register as a user on our website or Platforms, log into secure areas, use a shopping cart or use e-billing services, for example.
• Analytical/performance cookies . They allow us to recognise and count the number of visitors and to see how visitors move around our website and Platforms when they are using them. This helps us to improve the way our website and Platforms work, for example, by ensuring that users are finding what they are looking for easily.
• Functionality cookies . These are used to recognise you when you return to our website or Platforms. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Targeting cookies . These cookies record your visit to our website or Platforms, the pages you have visited and the links you have followed. We will use this information to make our website and Platforms and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

Policy edited by Support Robotics Limited, July 2021