Sensat Digital Limited and its Group Companies (as defined below) (together, "Sensat") understand that your privacy is important to you and that you care about how your personal data (as further defined in Part 4 below) is used.
We respect and value the privacy and the privacy rights of everyone who visits this website, sensat.co, any other Site, or uses any products, software or services operated by us, and will only collect and use personal data in ways that are described in this Privacy Notice, and in a way that is consistent with Sensat’s obligations and your rights under applicable law.
Please read this Privacy Notice carefully and ensure that you understand it; it applies to Sensat’s use and processing of any and all data collected by Sensat in relation to the use of any Sites, the attendance of Sensat events, the subscription to Sensat newsletters, in each case by customers and prospective customers of Sensat as well as Sensat’s suppliers and business partner and their representatives.
1. Definitions and Interpretation
In this Privacy Notice the following terms shall have the following meanings:
"Account" means an account required to access and/or use certain areas and features of a 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. Cookies contain information that is transferred to your computer’s hard drive. Details of the Cookies used by our Site are set out in Part 14, below;
"Cookie Law" means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 (as amended in 2004, 2011 and 2015) as it applies in UK domestic law by virtue of the European Union (Withdrawal) Act 2018 and the UK GDPR;
"Data Protection Law" means the UK GDPR and the Data Protection Act 2018;
"Group Company" means Sensat Digital Limited, Sensat Ltd and those other Sensat entities referred to in Sensat’s Corporate Information page and
"Group Companies" means all of them; and
"Group Companies" means all of them; and
"Site" means any website hosted or operated by Sensat Digital Limited (or any Group Company) including, but not limited, to www.sensat.co; and
"UK GDPR" means the EU Regulation 2016/679 General Data Protection Regulation as it applies in UK domestic law by virtue of the European Union (Withdrawal) Act 2018
2. Information About Sensat
Our Sites are owned and operated by Sensat Digital Limited (or, where applicable, a Group Company), a limited liability company registered in England and Wales under company number 09869690. The "data controller" (as defined in the Data Protection Legislation) in respect of your personal data will be Sensat Surveying Ltd.
- Registered address: 86-90 Paul Street, London, England, EC2A 4NE
- Main trading address: 15 Ironmonger Row, London EC1V 3TJ
- VAT number: 229 146 408
- Data Protection Officer: Harry Atkinson
- Email address: firstname.lastname@example.org
- Telephone number: +4402034882645
- Postal address: 15 Ironmonger Row, London EC1V 3TJ
- We are regulated by the Information Commissioner Officer (Registration number: ZA203170)
3. What Does This Privacy Notice Cover?
This Privacy Notice sets out and describes how Sensat will use and/or process any personal data or information submitted to us by, provided to us by, or otherwise collected by us from, amongst others, visitors and users of the various Sensat products, Sites, services, attendees of Sensat events, Sensat customers (including prospective customers) and their representatives.
Sensat also processes personal data on behalf of our customers subject to a written contract, but Sensat does not control the data processing or protection practices of its customers.
Our Sites may contain hyperlinks to, and details of, third party websites. We have no control over, and are not responsible for, how your data is collected, stored, or used by other websites or the privacy policies and practices of third parties, and therefore advise you to check the privacy policies and practices of any such third parties before providing any data to them.
4. What Is Personal Data?
Personal data is defined by the UK GDPR as any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be directly or indirectly identified, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but less obvious information such as identification numbers, electronic location data, and other online identifiers may also be classed as personal data.
5. What Are My Rights?
Under the Data Protection Legislation and Cookie Law, you have the following rights:
a) The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 15.
b) The right to access the personal data we hold about you. Part 13 will tell you how to do this.
c) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 15 to find out more.
d) The right to be forgotten, i.e. the right to ask us to erase, delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 15 to find out more.
e) The right to restrict (i.e. prevent) the processing of your personal data in certain circumstances. For example, if you have contested the accuracy of the personal data we hold about you, you are entitled to ask us to restrict processing of your personal data while we verify its accuracy.
f) The right to object to us using your personal data for a particular purpose or purposes in certain circumstances. For example, you have the right to object to processing of your personal data for direct marketing purposes. Please contact us using the details in Part 15 to find out more.
g) The right to withdraw consent. This means that, if we are relying on your consent as the lawful basis for using your personal data, you are free to withdraw that consent at any time. In certain cases, we may continue to process your information after you have withdrawn consent if we have a legal basis to do so or if your withdrawal of consent was limited to certain processing activities.
h) The right to data portability. This means that, if (i) you have provided personal data to us directly; (ii) we are using it with your consent or for the performance of a contract; and (iii) that data is processed using automated means, you have the right to receive a copy of this personal data in a structured, commonly used and machine readable format and request that we transmit the data to a third party.
i) Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
j) You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by using the links provided in our emails or by contacting us at email@example.com .
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 15.
It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, for example if you change your email address or if you wish to cancel any request you have made of us, or if you become aware that we have inaccurate personal data about you, please let us know by contacting us using the details set out in Part 15.
Further information about your rights can also be obtained from the Information Commissioner’s Office.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office (www.ico.org.uk). We would however welcome the opportunity to resolve your concerns ourselves, so please contact us first, using the details in Part 15.
Finally, even though we will take all reasonable steps to protect your personal data, we cannot guarantee the security of any personal data you disclose online.
6. What Data Do We Collect and How?
Many of the services offered by us require us to collect personal data about you in order to perform our services, evaluate our marketing activities and provide you access to our products and services to which you or your employer have purchased or subscribed.
We do not collect any ‘special category’ personal data, any personal data relating to children or any data relating to criminal convictions and/or offences. For these purposes, ’special category personal data’ is data revealing racial or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership, genetic data, biometric data, data concerning health or sex life or sexual orientation.
7. How Do We Use Your Data?
Under the Data Protection Legislation, we must always have a lawful basis for collecting and using personal data.
The following table describes how we may use your personal data, and our lawful basis for doing so:
We may process any of your personal data where necessary for the establishment, exercise or defence of legal proceedings. In such a scenario, the legal basis for this processing is our legitimate interests, by virtue of protecting and asserting our legal rights, your legal rights and, if required, the legal rights of others. In addition to the specific purposes for which we may process your personal data set out above, we may also process any of your personal data where such processing is necessary for compliance with legal obligations to which we are subject (such as anti-money laundering obligations).
We will only use your personal data for the purpose(s) for which it was originally collected and the purposes explained in this Privacy Notice unless we reasonably believe that another purpose is compatible with that or those purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original purpose, please contact us using the details in Part 15.
If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.
In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.
8. How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary for our ongoing legitimate business needs, whether that be to provide you with the services requested or for the purposes of satisfying any legal, accounting, or reporting requirements.
Notwithstanding the above, we may retain your personal data where such retention is required for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
9. How and Where Do You Store or Transfer My Personal Data?
Your personal data and files are stored on Sensat servers and the servers of our third party providers we hire to provide services to us. Your personal data may be transferred outside the UK because we have servers located worldwide, we may need to transfer to our Group Companies outside of the UK, and the companies we hire to help us run our business are located in different countries around the world.
We will however not routinely transfer your personal data to, or store it, outside of the United Kingdom. If we do happen to store or transfer any of your data outside the United Kingdom, we will take all reasonable steps to ensure that it is protected and transferred in a manner consistent with applicable legal requirements.
This may be done in a number of different ways, for instance:
- the country that we send the data to might be approved based on ‘adequacy regulations’ enacted under the UK GDPR as offering an adequate level of protection for personal data;
- the recipient might have signed up to a contract based on "Standard Contractual Clauses" approved under the UK GDPR or by the European Commission and the UK Information Commissioner’s Office, obliging them to protect your personal data; or
- in other circumstances, the law may permit us to otherwise transfer your personal data outside the United Kingdom.
The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:
- limiting access to your personal data to those employees, agents, contractors, and other third parties who have a legitimate need to know and ensuring that they are subject to duties of confidentiality at all times. Sensat employees are required to follow all applicable laws and regulations, including in relation to data protection laws;
- procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so.
When you contact us about your file, you may be asked for some personal data. This is a safeguard designed to ensure that only you, or someone authorised by you, has access to your file with us.
It is important to remember that the transmission of data via the internet may not be entirely safe or secure and you are therefore advised to take and put in place suitable precautions when transmitting data to us via the internet.
10. Do You Share My Personal Data?
We may need to share your data if doing so is reasonably necessary to provide a service that you have required, provided that we will take reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, our obligations and the obligations of any applicable and relevant third party under the law. In particular, we may need to share your personal data with third party agents and contractors for the purposes of enabling them to provide data analysis, customer support, storage, web hosting, marketing services, security/monitoring services and other services to us and any entity we may appoint from time to time to evaluate the effectiveness of the Sites. These third parties will be subject to appropriate confidentiality requirements and they will only use your personal data as described in this Privacy Notice.
We may also share your personal data to our Group Companies, and they will only process personal data for purposes that are described in this Privacy Notice or notified to you when we collect your personal data.
If you interact with other users of our Sites, those users may see and, in certain cases, potentially share, your name, profile picture/photo, and descriptions of your activity, including sending invitations to other users and chatting with other users.
If we sell, transfer, or merge all or parts of our business or assets, any relevant personal data of yours may be transferred to a third party as part of, and within the context, of such a sale, transfer or merger. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Notice.
Likewise, we may compile statistics about the use of our Site (including data relating to traffic, usage patterns and user behaviour and numbers). We may from time to time share any such data with third parties (including, but not limited to, potential investors, affiliates and partners), provided that any and all such data will only be shared in accordance with, and within the limits of, applicable law.
In some limited circumstances, we may be legally required to share certain personal data, which might include your own, for example if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority and/or where the disclosure of your personal data is necessary (i) as a matter of applicable law or regulation; (ii) for the establishing, exercise or defence of legal claims or (iii) to protect your vital interests or those of any other person.
11. How Can I Control My Personal Data?
In addition to your rights under the Data Protection Legislation set out in Part 5, when you submit personal data via our Site, you may be given options to restrict our use of your personal data.
In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails, by contacting firstname.lastname@example.org or at the point of providing your details).
There are places within the Sites that allow you to upload or otherwise share content, models, comments, and to communicate with others. You can sometimes limit who can see your contributions, but some places can be seen by other users of the relevant Site. You should make sure you understand with whom you are sharing your information before sharing it.
To remove content you have shared on our Sites, please use the same Site feature you used to share the content. If another user invites you to participate in shared viewing, editing, or commenting of content, you may be able to delete your contributions, but usually the user who invited you has full control.
If you wish to correct, update or request deletion of your personal data, you can do so at any time by contacting us using the contact details provided in Part 15.
12. Can I Withhold Information?
You may access our Site without providing your name or any contact information. Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract. For example, we may not be able to provide you with access to our software and/or platform if you do not supply your name and email address. In this case, we may have to cancel your access to a service.
13. How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a "subject access request".
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 15.
There is not normally any charge for a subject access request. However, if your request is 'manifestly unfounded or excessive' (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
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 first–party Cookies to facilitate and improve your experience of our Site and to provide and improve our services. We do not use first-party Cookies to create behavioural profiles of users.
Cookies do not give us access to your computer or any information about you, other than the data you choose to share with us. These Cookies are also not used to create behavioural profiles of users.
Certain features of our Sites depend on Cookies to function. Cookie Law deems these Cookies to be 'strictly necessary' in that they are essential in order to enable you to move around our Sites and use its features, such as accessing secure areas. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may block these Cookies by changing your internet browser’s settings as detailed below, but please be aware that our Sites may not work properly if you do so.
Furthermore, our Sites use, or may use, analytics services provided by, amongst others, Google Analytics, LinkedIn, Hubspot, WordPress, ClientSuccess and Segment. Website analytics refers to a set of tools used to collect and analyse usage information and user behaviour (for example, about the number of people using our Sites and to better understand how they find and use our Sites), enabling us to better understand how our Sites are used. This, in turn, enables us to improve our Sites and the services offered through them. The above-mentioned analytics service(s) used by our Sites use(s) Cookies to gather the required information and to track web browsing behaviour.
You do not have to allow us to use these Cookies, however whilst our use of them does not pose any risk to your privacy or your safe use of our Sites, it does enable us to continually improve our Sites, making it a better and more useful experience for you.
In addition to the controls that we provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to accept, delete or disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
You can choose to delete Cookies on your computer or device at any time, however you may lose some features or functionality of our Sites and services, and information that enables you to access our Sites and services more quickly and efficiently including, but not limited to, login and personalisation settings.
It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
15. How Do I Contact You?
To contact us about anything to do with this Privacy Notice, your personal data and data protection, including to make a subject access request or to ask us to erase, delete or otherwise dispose of any of your personal data that we hold, please use the following details:
- Email address: email@example.com or firstname.lastname@example.org
- Telephone number: +442034882645
- Postal Address: 15 Ironmonger Row, London EC1V 3TJ (for the attention of Harry Atkinson or Alex Gest)
16. Changes To This Privacy Notice
We reserve the right to update and change this Privacy Notice from time to time in order to reflect any changes to the way in which we process your personal data, in light of changing legal requirements or if we change our business in a way that affects personal data protection.
Any changes will be posted on our Sites. For new users, the change will become effective upon posting. For existing users, if the change is significant, it will become effective 30 days after posting, otherwise it will become effective immediately upon posting. We recommend that you check this page regularly to keep up-to-date and ensure you are happy and comfortable with any changes or updates to this Privacy Notice. If you do not agree to any changes that we make, you should not use or access (or continue to use or access) our Sites.