Data Controller
SOS Intelligence Ltd (Company number 09185530)
Address – Floor 28 One Ropemaker Street London EC2Y 9AW
Telephone – +44 20 3920 8002
www.sosintel.co.uk
Contact and Data Access Rights
You have the right to obtain a copy of the personal information we are processing and to obtain information about how we process it. We will not charge you for providing you with the information but may charge you a reasonable fee for supplying any additional copies.
Data Protection Officer
SOS Intelligence Ltd
Floor 28 One Ropemaker Street
London
EC3Y9AW
Or:
From our customer portal by using the support messaging tool
Or:
Please note that where the request is received via email, security checks will be conducted prior to release of any information.
Definitions
Legitimate interests is mentioned in our privacy notice because data protection laws allow the processing of personal information where the purpose is legitimate and is not outweighed by your interests, fundamental rights and freedoms. Those laws call this the ‘legitimate interests’ legal reason for processing personal information.
Personal Information means information that is about you or from which we can identify you.
Process or processing includes everything we do with your personal information from its collection, through to its destruction or deletion when we no longer need it. This includes for instance collecting it (from you), obtaining it (from other organisations), using, sharing, storing, retaining, deleting, destroying and transferring it overseas. In this privacy notice we use “process”, “hold” and various other terms to mean the same thing – Processing.
Why we process your personal information and what is the legal basis for this (including when we share it with others)?
We may use the personal information that we hold about you for the following legal reason (for some processing more than one legal reason may be relevant except where we rely on your consent):
Performance of Contract
We will process your personal information when that information is necessary to perform our contract with you or for taking steps prior to entering into the contract with us (but where the party to the contract is a corporate or business, this legal reason for processing personal data regarding any individual named or associated will not apply). We will do this for providing you with the plan applied for and servicing that plan or service during the life of the relationship. This could include:
Legal Obligations
We will process your personal information when it is necessary to comply with our legal obligations including:
Legitimate Interests
We will process your personal information where we consider that it is, on balance, when having considered your rights and freedoms, appropriate for us to do so for the following legitimate interests (for ourselves and in some cases other organisations as listed below):
Consent
Your personal information may be used for other purposes for which you have given your explicit permission, including.
for more information about information sharing
We use analytics to help us understand the behaviour of our web visitors and also help us communicate with appropriate prospects.
We use Google Analytics, Plausible, Leadfeeder and Lead Forensics. The first two are web analytics tools which allow us to see the usage of the website.
Leadfeeder and Lead Forensics: We collect the behavioural data of all website visitors. This includes; pages viewed, visitor source and time spent on the site. The visitor IP address is collected to detect the company and geographic location. All visit data is aggregated on the company level.
Source of information
If you have subscribed to one of our service plans then information you provided, will be stored and processed by us in order to set your account up and provide services to you.
If you are a customer of a managed security service provider who uses our services on a white label bases then we will be a sub processor and may be storing and processing any keywords your service provider has sent us.
Information we hold
In general, we will hold only the information you have provided to us as part of enrolment to one of our service plans this consists of:
Personal Information
Your name, surname email address and possibly your company name.
We may also hold other information you provide to us in the form of the keywords you add to your account that you have asked us to monitor.
Information supplied with a view to potential employment
If you have provided to us, directly or indirectly, your CV, we will hold your personal information including employment status, interview notes and history.
Who we may share the information with
We may share information outside SOS Intelligence if:
Data Retention
Our standard data retention length of time is one year following the closure of your account or your account going into arrears.
CVs
Where you have provided to us your CV, unless we subsequently employ you, at which time you will be provided with an appropriate Privacy Notice, we will store your CV and the information contained therein for 6 months for our legitimate interests. This is in case of questions or queries from you about your application and in case suitable other roles come up which might interest you. If you send us your CV, we will keep your details on file for a period of 6 months so that we may contact you in the event that a suitable opportunity at SOS Intelligence (not anywhere else) arises during that time. If you’d rather we did not retain your details on file, please let us know as soon as possible by contacting us at [email protected]. In that case your CV will no longer be used by us to contact you about opportunities and it will be dealt with in accordance with our data retention policy.
Other rights under data protection laws
Here is a list of other rights that all individuals have under data protection laws. They do not apply in all circumstances. If you wish to exercise any of them we will explain at that time if they are engaged or not:
Please email [email protected] if you wish to exercise any of these rights if and to the extent they are relevant.
Please note that where the request is received via email, security checks will be conducted prior to release of any information.
Right to withdraw consent (and also how to unsubscribe from marketing even if we do not rely on consent)
Where the reason for processing your personal information is ‘consent’, you can withdraw this consent at any time by contacting our DPO using the details above.
If you are a business we will not be relying on consent to do marketing with your personal information instead we will rely on legitimate interests but you can still at any time ask us to stop using your personal information for marketing purposes. To do this you can contact the DPO (contact details at the top of this Privacy Notice) or click on the “unsubscribe link” within the email.
The same applies if you are our contact at the corporate customer and where we use your email address or other business related contact detail to market the corporate. For example, ‘[email protected]’, We will rely on legitimate interests to use your personal information to send you marketing that is intended for the corporate customer.You can contact the DPO (contact details at the top of this Privacy Notice) or click on the unsubscribe link within the email to stop this at any time.
What is the consequence of you withdrawing consent (where we rely on consent as the lawful reason for our processing of your personal information):
The consequence might be that we cannot send you some marketing communications (where we were relying on consent as the lawful reason for that – this is not relevant to you if you are a contact person at a corporate customer or since we rely on legitimate interests to market you).
These outcomes will be relevant only in cases where we rely on explicit consent for this processing.
To comply with payment services regulations we have to share some of your personal information with other payment service providers in some circumstances such as when you ask us to share information about your account with them. Whilst those payment services regulations mention ‘consent’ for this, ‘consent’ in that context does not have the same meaning as ‘consent’ under data protection laws. The legal grounds which may be relevant to this are compliance with our legal obligations, performance of our contract with you, our legitimate interests, or a combination of these. This is why if you ask to withdraw consent from what we do with your personal information where we need to have it under the payment services regulations, we may still have to hold and use your personal information.
Marketing to corporate customers
If you are a contact at a corporate customer please read this section.
In addition to, or instead of, sending you marketing intended for the corporate customer, we may market the corporate customer directly be using its own contact detail. For example ‘[email protected]’. We will only do this if you (on its behalf) have provided us with permission to do so. To be clear – this is not a data protection law consent – it is instead a permission for us to use the contact detail for a corporate (not you as the contact at the corporate) for marketing purposes. This means you do not have a right under data protection law to withdraw consent for the corporate customer. However you can tell us to stop marketing the corporate customer at any time by clicking on the link within the email.
Data anonymization and use of aggregated information
Your personal information may be converted into statistical or aggregated data which cannot be used to re-identify you. It may then be used to produce statistical research and reports. This aggregated data may be shared and used in all the ways described in this privacy notice.
We use Google Analytics and Plausible Analytics to give us information about website visitors. We use this information to also help us with Google PPC advertising and working out which adverts perform best.
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