This is the Privacy & Cookies Policy (the “PCP”) of Digital Connextions Limited, (a company registered in Scotland with a company number of SC447870 and a registered address of 163 Bath Street, Glasgow, G2 4SQ) and hereinafter referred to as “we”, “us” or “our” in this PCP.
Introduction: we are the controller and responsible for your processing your data in connection with your use of our software application Atom (the “Platform”). This PCP describes the ways in which we collect and use information about our users (hereafter “you” or “users”) when you visit and/or use the Platform. If you have any queries about this PCP and your personal data please contact us using the following contact details:
- by e-mail to firstname.lastname@example.org
- write to us at our registered address: FAO Data Protection Officer, Digital Connextions Limited, 163 Bath Street, Glasgow, G2 4SQ, Scotland
- 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. We would, however appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
- Who this PCP applies to: This PCP applies to any person who uses the Platform and people who make complaints to us by email. By using the Platform you agree to be bound by this PCP. We may change this PCP at any time. We shall deem your continued use of the Platform as indicating your consent to such changes.
Data we collect from you: When you sign up to an account for the Platform and when you use the Platform we collect the following information from you:
- upon sign-up we collect your user name, your e-mail address, your password and details of the device you are using together with your profile information for your user profile which may include your full name, identifying you and other contact information such as your telephone number;
- details in relation to your use of the Platform;
- your IP address or the internet browser which you are using when you use the Platform; and
- Information we do not collect from you: 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.
How we use data collected from people who use the Platform: we will only use your personal data where the law allows us to. Most commonly we will use your personal data in the following circumstances:
- in order to operate the Platform and to provide the most functional and efficient service possible via the Platform;
- 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 or regulatory obligation.
- help you access your information after you sign in and remember information for future visits;
- complete your transactions using the Platform;
- facilitate the improvement of the Platform and your experience of the Platform and to develop and test the Platform;
- provide technical support in relation to user enquires, resolving disputes and troubleshooting;
- to monitor numbers of visitors, traffic and demographic patterns;
- prevent fraud or illegal activities;
- to provide information about other products and services. From time to time we may send you information about the Platform and other goods and services which we think may be of interest to you. You can withdraw your consent to this at any time by sending an e-mail to email@example.com
- contact you with our online newsletter, which you can unsubscribe from at any time; and
- share with third parties for the purposes as described in paragraph 7 below.
Sharing information with third parties: 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 purpose and only permit them to process your personal data for specified purposes and in accordance with our instructions. We may share your information with third parties including:
- your information shall be shared with our Provider organisations with whom you can take up Opportunities as further described on the Platform. When you take up Opportunities with Providers you may be subject to the Providers own Privacy and Cookies policies or terms and conditions to which we are not a party;
- we may also share elements of your participation on the Platform (e.g. displaying your geographical location to communicate with other users in similar locations) with other users but if we do so it will be done anonymously;
- in relation to the sale of some or all of our business, or its assets, to any third party, or as part of any business restructuring or reorganisation, but we will take steps with the aim of ensuring that your privacy rights continue to be protected;
- in anonymised form with data aggregators and service providers as part of an analysis of user metrics or sales performance; and
- with law enforcement agencies in compliance with law enforcement.
- Stopping us from collecting this information: If you do not want us to collect and use this information you can use your browser settings and privacy settings on your device to prevent us collecting certain of the information about you referred to in this PCP. If you still have concerns about the information we collect please contact us at any time by sending an e-mail to firstname.lastname@example.org. However, the Platform may not function fully, or at all, on your device if you decide to do so and we reserve the right to restrict access to the Platform if users do not agree to provide such information.
- Links to third party websites: We are not responsible for the privacy policies and practices of other sites even if you access such sites using links from the Platform when you are using the Platform. We recommend that you check the policy of each site you visit and contact its owner or operator if you have any concerns or questions. In addition, if you link to the Platform from a third party site or via a social network (e.g. Twitter, Facebook), we are not responsible for the privacy policies and practices of the owners or operators of that third party site and recommend that you check the policy of that third party site and contact its owner or operator if you have any concerns or questions.
- Security: We have implemented technology and policies to safeguard your privacy from unauthorised access and improper use. Our physical servers are operated by a dedicated third party service within the EU. We delete data we hold about you in relation to the Platform if you have not accessed the service in the previous 10 years.
- The Platform's policy towards children: We do not knowingly collect personally identifiable information in relation to children under the age of 13. If we discover it has collected personal data in relation to any children under 13 we shall delete such information.
Cookies and similar technologies:
- Disabling Cookies: The use of the cookies described above improves the functionality of The Platform and your experience using it. If you do not want these cookies to be served on your device, you are able to disable them by changing the settings on your browser, or on your device. Please note that if you do decide to disable cookies you may not be able to access all or part of the Platform, some of the features of the Platform or the Platform may not function properly. By continuing to use the Platform, including using social networking media functionality, you consent to the relevant cookies being set on your device.
- More information: To find out more about how cookies work, how to manage and delete them and to see which ones have been set please visit www.aboutcookies.org or www.allaboutcookies.org.
- Cookies we use: Descriptions of the cookies used by the Platform, and in connection with The Platform are provided in the Table below.
- Device Identifiers: When you use a mobile device to access the Platform, we may access, collect, monitor, store on your device, and/or remotely store one or more “device identifiers“. Device identifiers are small data files or similar data structures stored on or associated with your mobile device, which uniquely identify your mobile device. A device identifier may be data stored in connection with the device hardware, data stored in connection with the device's operating system or other software, or data sent to the device by us. A device identifier may deliver information to us or to a third party partner about how you browse and use the Platform and may help us or others provide reports or personalized content and ads.
Cookie Type Name Purpose Further Information Google Analytics Cookies utma, _utmb, _utmc, _utmz The Platform uses Google Analytics cookies to collect information about how visitors use the Website, which the Platform use to help improve it. These cookies collect information in an anonymous form, including the number of visitors to the Website, where visitors have come to the Website from and the pages they visited. Google Privacy Overview
- Data Protection Legislation: we are the data controller under the relevant legislation. For the purposes of this PCP the relevant legislation is (i) unless and until the GDPR is no longer directly applicable in the UK, the General Data Protection Regulation ((EU) 2016/679) (“GDPR”) and any national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK and then (ii) any successor legislation to the GDPR or the Data Protection Act 1998.
- Terms of Service and Definitions: This PCP forms part of our Terms of Service. Except otherwise used in this PCP, all capitalised words have the meaning as defined in our Terms of Service.
- Contact details: If at any time you would like to contact the Platform about your views on this PCP or any enquiry relating to your personal information, you can do so by sending an e-mail to us at email@example.com or write to us at our registered address FAO Data Protection Officer, 163 Bath Street, Glasgow, G2 4SQ, Scotland.