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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:

[email protected]

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:

  • notifying you about either important changes to the features and operation of our service;
  • responding to your enquiries and complaints;
  • updating, consolidating, and improving the accuracy of our records;
  • Billing, arrears and debt recovery activities;
  • Sharing your personal information with payment services providers (this means a firm providing and maintaining a payment account).

Legal Obligations

We will process your personal information when it is necessary to comply with our legal obligations including:

  • When required by law and for compliance with laws that apply to us.

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):

  • processing personal information about you as an individual and you as a person associated with a corporate entity (or its subsidiaries) who is our customer testing new systems and checking upgrades to existing systems
  • Service modelling, statistical and trend analysis, with the aim of developing and improving products and services.
  • administering and managing your account and services relating to it.
  • for some of our marketing and in that case we will market to you based on this being for our legitimate interests.
  • processing your information where you provide us with a CV in relation to a vacancy you have applied for or where you are submitting a CV with a view to future opportunities;
  • when we share your personal information with other people and organisations including:
    • Other organisations and businesses who provide services to us such as debt recovery agencies, solicitors and suppliers of back office/servicing functions or IT services.
  • Providing feedback to recruitment agencies, head hunters and other agencies on the suitability of your CV or on any interview undertaken.

Consent 

Your personal information may be used for other purposes for which you have given your explicit permission, including.

  • Information Sharing – When you give your consent for SOS Intelligence to share your personal information with another party. See

for more information about information sharing

  • Marketing – We will only send marketing materials related to our products and services to individuals who have consented to us doing so. You are in control of this consent and therefore it can be withdrawn at any time.  Should you wish to do so please contact us by emailing [email protected].

 

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:

  • Allowed by our agreement
  • You provided consent
  • It is required by law
  • It is required to process the payment or invoice for use of our service
  • It is needed by subcontractors to help us manage your account or service
  • For providing monitoring of specific feeds such as, but not limited to; Twitter where keywords you tell us may need to be known by twitter to provide an information feed.

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:

  • The right to have your personal information corrected if it is inaccurateand to have incomplete personal information completed;
  • The right to object to processing of your personal information;
  • The right to restrict processingof your personal information;
  • The right to have your personal information erased(the “right to be forgotten”);
  • The right to move, copy or transfer your personal information(“data portability”);
  • The rights in relation to automated decision making which has a legal effect or otherwise significantly affects you.

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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