This is an important notice regarding your privacy and the way in which Symless Limited (referred to as “we”, “our” or “us” in this policy) collects and makes use of your personal data. We want to be open and transparent with you, and therefore encourage you to contact us if you have any questions about this policy or the ways in which we use your personal data.
This policy applies to our applicants, customers and visitors to our offices generally. We take our privacy responsibilities seriously and are committed to protecting and respecting your privacy.
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
For the purpose of applicable privacy legislation, the data controller is Symless Limited of Basepoint Business Centre London Road, Unit 014, 377-399 London Road, Camberley, Surrey, England, GU15 3HL. Our company registration number is 08066283.
Questions regarding this policy should be directed to our Data Protection Compliance Manager. The Data Protection Compliance Manager is responsible for ensuring compliance with the General Data Protection Regulations and this policy. That post is held by our Operations Manager, who can be contacted at [email protected]. Any questions about the operation of this policy or any concerns that the policy has not been followed should be referred in the first instance to the Data Protection Compliance Manager.
Data protection principles
We will comply with data protection law and the GDPR. This says that the personal information we hold about you must be:
- Used lawfully, fairly and in a transparent way.
- Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
- Relevant to the purposes we have told you about and limited only to those purposes.
- Accurate and kept up to date.
- Kept only as long as necessary for the purposes we have told you about.
- Kept securely.
What information do we hold about you?
Personal contact details such as your name, title, address, telephone number, date of birth and e-mail address.
Recruitment information (including personal information such as copies your right to work documents, your CV or cover letter which is sent to us as part of the application process).
Information provided to us by recruitment agencies in relation to your application for employment with us.Customers
Your name, postal address and e-mail address, which is collected when you register an account with us or place an order on our website – www.symless.com (“our website”).
Information you provide to us via our website, for example, by using the ‘Contact’ form on our website or by corresponding with our technical team.
When opening a ticket by reporting an issue to our Customer Service team, you may forward your support logs to us. We may collect personal information such as your IP address and name from your support logs to assist us in providing a quick solution to your problem.
Personal information provided to us by the third party service providers we work with, for example, analytics providers.Business contacts
Contact details such as your name, title, business telephone number and business e-mail address.
Information that you provide or we collect during our interactions with you or your employer, such as how long we have done business with you or how long you have worked at your company.Generally
If you visit our offices, images, videos and audio are recorded by the CCTV system in operation at our offices.
Information gathered when you visit our offices via our visitor sign-in process, including your name.
Any personal information you provide to us during your interactions with us.
Personal information provided to us by third party service providers we work with, for example, payment service or analytics providers.
How will we use your personal information and what is the legal ground we rely on for doing so?
We will only use your personal information when the law allows us to. When we use your personal information, we must have a legal ground for doing so. The following are (amongst others) the legal grounds by which we can use your personal information:
Where you have provided us with your consent for us to do so.
Where we need to perform the contract we have entered into with you or to take steps to enter into a contract with you.
Where we need to comply with a legal obligation to which we are subject.
Where it is in pursuit of our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
More specifically, we will use your personal information in the following circumstances:Applicants:
To evaluate and progress your application for employment with us – to perform the contract with you or to take steps to enter into a contract with you, and in pursuit of our legitimate interests to verify your suitability for our vacancies.
To carry out right to work checks – to comply with a legal obligation.
Using a third party document and signature service to send you a contract of employment if you are successful in a job application with us. We are pursing our legitimate interest as sending documents out using this service is quicker and more reliable.Customers:
Dealing with your enquiry made via the ‘Contact’ page on our website – in pursuit of our legitimate interests to ensure your enquiry is dealt with promptly and efficiently.
Your contact details to provide you with information on our products and services. This may include technical information and/or marketing information – where we have your consent to do so.
To provide you with invoices for our products and services – to perform the contract with you or to take steps to enter into a contract with you.
Dealing with your support request – in pursuit of our legitimate interests to ensure your issue is dealt with promptly and efficiently.
To re-direct you to our secure payment service providers – to perform the contract with you or to take steps to enter into a contract with you.Generally:
Storing your personal data on Google Drive (a cloud storage service). As our storage is hosted, your information is protected by the security measures put in place by Google. We are pursing out legitimate interest in storing all of our documentation and data in one place cheaply and keeping your information secure using the security measures provided by Google.
To ensure our premises are kept secure – in pursuit of our legitimate interests (site security and evidence).
Health and safety purposes – to comply with a legal obligation.
To administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes – in pursuit of our legitimate interests (to better understand how people interact with our website and solve any issues it may have).
To improve our website to ensure that content is presented in the most effective manner for you and your computer – in pursuit of our legitimate interests (to improve our content and your or other third parties’ experience of our products and services).
To improve our services or solve technical issues – in pursuit of our legitimate interest (to improve our content and your or other third parties’ experience of our products and services).
To contact you if we wish to use your personal information for a purpose not set out in this policy – to comply with a legal obligation.
What happens if there is a change of purpose?
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Which type of third parties might we share your personal information with?
We require third parties to respect the security of your personal information and to treat it in accordance with the law. For example, where we instruct third party service providers, we carry out due diligence on those providers to ensure they treat your personal information as seriously as we do.
We may share your personal information with the following types of third parties:
Third party cloud storage providers, such as Google LLC.
Providers assisting us with the facilitation of online signatures, such as HelloSign.
Third party payment solution providers, such as Braintree and Stripe.
Technical and analytical support providers, for example, assisting with improving and developing our website.
Recruitment partners assisting us with filling our vacancies.
Professional advisers such as lawyers, accountants and business analysts.
Providers which help us collate and organise information effectively and securely.
Suppliers and sub-contractors for the performance of any contract we enter into with you or who assist us with marketing or information distribution, such as MailChimp.
When paying for our services or products, you will be re-directed to a secure third-party payment service provider. Please be aware that any personal information you supply to these providers will be processed in accordance with their policies and procedures in place for data protection.
Data retentionHow long will we use your personal information for?
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for.
We assess the appropriate retention period for different information based on the size, volume, nature and sensitivity of that information, the potential risk of harm to you from unauthorised use or disclosure of that information, the purposes for which we are using that information, applicable legal requirements for holding that information, and whether we can achieve those purpose(s) through other means.Applicants
Where your application for employment with us is successful, we will provide you with further information as to how we use your personal information during the course of your employment.
Where your application for employment with us is unsuccessful, we will keep your personal information for 12 months.Customers
The period we keep your personal information depends on a number of circumstances. For example:
Where we have collected your personal information during the course of you or your organisation and us doing business, we will keep your personal information for as long as this business continues, or for as long as we have a commercial interest in holding your personal information, for example, with a view to doing business in the future.
We will keep customer’s IP addresses and name in relation to the support logs for a period of 12 months.
Where we have collected your personal information for marketing distribution, we will keep this information for as long as you wish to receive the marketing information. You can unsubscribe by following the simple process in paragraph 9 below.Business contacts
Where we have collected your personal information during the course of you or your organisation and us doing business, we will keep your personal information for as long as this business continues, or for as long as we have a commercial interest in holding your personal information, for example, with a view to doing business in the future.Generally
Any personal information collected through our CCTV system is stored for 7 days only.
Where we store your personal data
Electronic versions of the information you provide to us or we collect about you is stored on servers provided by our cloud hosting solution provider. The company which provides this service is Google LLC.
Although Google LLC’s servers are based outside of the EEA, we have taken steps to ensure your personal information is adequately protected. Google adheres to the Privacy Shield regime and we have a processing agreement in place governing the transfer of personal information between us and Google.
Rights of access, correction, erasure and restrictionYour rights in connection with your personal information
Under certain circumstances, by law you have the right to:
Request access to your personal information (known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
Request the erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to stop processing personal information where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground.
Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
Request the transfer of your personal information to another party.
No fee usually required
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to another person who has no right to receive it
Right to withdraw consent
Where we are providing you with marketing information, you can also change your marketing preferences by using the unsubscribe button at the bottom of our marketing e-mails sent to you.
Once we have received notification that you have withdrawn your consent, we will no longer process your personal information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so.
What happens if you fail to provide personal information?
If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you (such as providing you with our products or services), or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of visitors to our offices).
Right to complain
You have a right to make a complaint if you wish to do so. The organisation with oversight of our processing is the Information Commissioner’s Office which can be contacted in writing at Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, United Kingdom SK9 5AF, by telephone (0303 123 1113) or by e-mail ([email protected]).