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.
Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
|“Account”||means an account required to access and/or use certain areas and features of Our Site;|
|“Cookie”||means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 12, below;]|
|“Our Site”||means this Website, https://isarr.com;|
|“UK and EU Cookie Law”||means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended in 2004, 2011 and 2015; and]|
|“We/Us/Our”||means Comunis Ltd, trading as ISARR, a limited company registered in England under, whose registered address is 85 Great Portland Street, First Floor, London W1W 7LT .|
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 firstname.lastname@example.org
Scope – What Does This Policy Cover
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:
- business/company name
- job title
- 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 email@example.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.
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)
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
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 firstname.lastname@example.org
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 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 email@example.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 firstname.lastname@example.org 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).
85 Great Portland Street, First Floor, London W1W 7LT
Office Number: 0203 4750 753