PRIVACY POLICY

ISARR understands that your privacy is important to you and that you care about how your information is used and shared online. We respect and value the privacy of everyone who visits Our Site and will only collect and use information in ways that are useful to you and in a manner consistent with your rights and Our obligations under the law.

This Policy applies to Our use of any and all data collected by us in relation to your use of Our Site. Please read this Policy carefully and ensure that you understand it. Your acceptance of Our Privacy Policy is deemed to occur upon your first use of Our Site. If you do not accept and agree with this Policy, you must stop using Our Site immediately.

Definitions and Interpretation

In this Policy the following terms shall have the following meanings:

Information About Us

Our Site https://isarr.com is owned and operated by Comunis Ltd trading as ISARR, a limited company registered in England under Company number 04823119, whose registered address is 85 Great Portland Street, First Floor, London W1W 7LT and VAT number 04823119.

Our data protection officer can be contacted at dpo@isarr.com 

Scope – What Does This Policy Cover

This Privacy Policy applies only to your use of Our Site. It does not extend to any websites that are linked to from Our Site (whether We provide those links or whether they are shared by other users). We have no control over how your data is collected, stored or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to them.

What Data Do We Collect

Some data will be collected automatically by Our Site, other data will only be collected if you voluntarily submit it and consent to Us using it for the purposes set out in this policy, for example, when signing up for email marketing material

Depending upon your use of Our Site, We may collect some or all of the following data:

• Name
• business/company name
• job title
• profession
• contact information such as email addresses and telephone numbers
• IP address (automatically collected)
• web browser type and version (automatically collected)
• operating system (automatically collected)
• a list of URLs starting with a referring site, your activity on Our Site, and the site you exit to (automatically collected)

How Do We Use Your Data

All personal data is stored securely in accordance with the Data Protection Act 2018 (GDPR)

We use your data to provide the best possible services to you. This includes:

• Providing and managing your access to Our Site
• Personalising and tailoring your experience on Our Site
• Responding to communications from you
• Supplying you with email newsletters, alerts etc. that you have subscribed to. You may unsubscribe or opt-out at any time by contacting us via the website or at dpo@isarr.com
• Analysing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience

In some cases, the collection of data may be a statutory or contractual requirement and We will be limited in the products and services We can provide you without your consent for Us to be able to use such data.

With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email AND/OR telephone with information and news on Our products AND/OR services. We will not however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the Data Protection Act 2018 (GDPR) and the Privacy and Electronic Communications (EC Directive) Regulations 2003, as amended in 2004, 2011 and 2015.

Under GDPR We will ensure that your personal data is processed lawfully, fairly, and transparently without adversely affecting your rights.  We will only process your personal data if at least one of the following ‘Lawful Basis’ applies:

• you have given consent to the processing of your personal data for one or more specific purposes;
• processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;
• processing is necessary for compliance with a legal obligation to which we are  subject;
• processing is necessary to protect the vital interests of you or of another natural person;
• processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or
• processing is necessary for the purposes of the legitimate interests pursued by Us or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.

How and Where Do We Store Your Data

We only keep your data for as long as We need to in order to use it to deliver services and or products contained in this policy and/or for as long as We have your permission to keep it.  In any event, We will conduct an annual review to ascertain whether We need to keep your data. Your data will be deleted if We no longer need it in accordance with the terms of our Data Retention Policy.

Your data will be primarily stored within the European Economic Area, however, where our third party service providers store data outside of the EEA, We demand Model/Standard Contract clauses in line with The Data Protection Act 2018 (GDPR)

Data security is of great importance to Us, and to protect your data We have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through Our Site.

Notwithstanding the security measures that We take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to Us data via the internet.

Do We Share Your Data

We may contract with third parties to supply products and services to you on our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data is handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under the law.

Cookies

Our Site may place and access certain first party Cookies on your computer or device. First party Cookies are those placed directly by Us and are used only by Us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve Our products and services. In addition, Our Site uses (self hosted) website analytics services managed by ISARR

You may also receive certain third party Cookies on your computer or device. Third party Cookies are those placed by websites, services, and/or parties other than Us.Our third party Website service providers:

• Mailgun – Mail Service
• Google GSuite – CRM
• Salesflare – CRM
• DragApp – email CRM 
• Upcloud (UK Data Centre) Web Analytics server (self hosted)

Website Analytics

We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales and other information. All such data will be anonymised and will not include any personally identifying information. We may from time to time share such data with third parties such as prospective investors, affiliates, partners and advertisers. Data will only be shared and used within the bounds of the law.

In certain circumstances We may be legally required to share certain data held by Us, which may include your personal information, for example, where We are involved in legal proceedings, where We are complying with the requirements of legislation, a court order, or a governmental authority. We do not require any further consent from you in order to share your data in such circumstances and will comply as required with any legally binding request that is made of Us.

What Happens If Our Business Changes Hands

We may, from time to time, expand or reduce Our business and this may involve the sale and/or the transfer of control of all or part of Our business. Data provided by users will, where it is relevant to any part of Our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use the data for the purposes for which it was originally collected by Us.

How Can You Control Your Data

When you submit information via Our Site, you may be given options to restrict Our use of your data. We aim to give you strong controls on Our use of your data including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details AND/OR by managing your Account. You can also contact us at any time regarding your personal data using the email address dpo@isarr.com

You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you from receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.

Your Right to Withhold Information and Your Right to Withdraw Information After You Have Given it

You may access Our Site without providing any data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.

You may restrict your internet browser’s use of Cookies.

You may withdraw your consent for Us to use your personal data as set out in this policy at any time by contacting Us using the our web form or by emailing dpo@isarr.com, and We will delete Your data from Our systems.  However, you acknowledge this may limit Our ability to provide the best possible products and services to you.

How Can You Access Your Data

You have the legal right to ask for a copy of any of your personal data held by Us (where such data is held), by contacting us at dpo@isarr.com Where personal data is requested, we may require further checks to verify identification

Summary of Your Rights under GDPR

Under the GDPR, you have the right to:

• request access to, deletion of or correction of, your personal data held by Us;
• complain to a supervisory authority;
• be informed of what data processing is taking place;
• restrict processing;
• data portability;
• object to processing of your personal data;
• rights with respect to automated decision-making and profiling (see section 14 below).

To enforce any of the foregoing rights or if you have any other questions about Our Site or this Privacy Policy, please contact Us at dpo@isarr.com

Contacting Us

If you have any questions about Our Site or this Privacy Policy, please contact Us by email at dpo@isarr.com by telephone on +44 203 4750 753, or by post at ISARR, 85 Great Portland Street, First Floor, London W1W 7LT. Please ensure that your query is clear, particularly if it is a request for information about the data We hold about you.

Changes to Our Privacy Policy

We may change this Website Privacy and Cookie Policy as we deem necessary from time to time, or as may be required by law. Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date.