Privacy Policy

Last updated: 9 September 2021

Your trust is extremely important to us. Our privacy policy explains how we collect, store and handle your personal data.

Introduction

Welcome to the Amtivo Group’s privacy policy. The Amtivo Group respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you.

This is the standard privacy policy that applies to the following Amtivo Group companies:

When we use “Amtivo Group”, “we”, “us” or “our” in this privacy policy, we are referring to the relevant company in the Amtivo Group responsible for processing your data. When you purchase a product or service with us, or enter into a working relationship with us, we will tell you which Amtivo Group company you are dealing with.

What is the purpose of this document?

This privacy policy describes how we collect and process your personal data during and after your working relationship with us, in accordance with the General Data Protection Regulation (GDPR) and associated data protection legislation.

It is important that you read this privacy policy together with any other privacy policy or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements the other policies and notices and is not intended to override them.

Data protection principles

We will comply with data protection law. This says that the personal information we hold about you must be:

  1. Used lawfully, fairly and in a transparent way.
  2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
  3. Relevant to the purposes we have told you about and limited only to those purposes.
  4. Accurate and kept up to date.
  5. Kept only as long as necessary for the purposes we have told you about.
  6. Kept securely.

The data we collect about you

Personal data means any information relating to an identified or identifiable individual. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

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 we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a service you have with us, but we will notify you if this is the case at the time.

How is your personal data collected?

We use different methods to collect data from and about you, including through:

How we will use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  1. Where we need to perform the contract we are about to enter into with you, or have entered into with you.
  2. Where we need to comply with a legal or regulatory obligation.
  3. 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.

Generally, we do not rely on consent as a legal basis for processing your personal data.

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you as a new customer (a) Identity

(b) Contact

Performance of a contract with you
To process and deliver your order (a) Identity

(b) Contact

(c) Marketing and Communications

Performance of a contract with you
 

To process and deliver a service on behalf of a third party (e.g. public body or regulatory body):

(a) Identity

(b) Contact

(c) Profile

(a) Necessary for the performance of a task carried out carried out in the public interest or in the exercise of official authority

(b) Necessary for our legitimate interests (providing our business services)

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To enable you to partake in a prize draw, competition or complete a survey (a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communication

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity

(b) Contact

(c) Technical

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you (a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences (a) Technical

(b) Usage

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you (marketing) (a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

Necessary for our legitimate interests (to develop our products/services and grow our business)

 

We will only use your personal data 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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table above.

International transfers

If you are based in the EEA, we may transfer your personal data to the UK if we share it with other members of the Amtivo Group.

We may also use service providers and organisations based outside the UK or EEA for the purpose of processing your personal data; where this is the case we will ensure that the transfer of your personal data is compliant with data protection law. You can obtain more details about the protection given to your personal data when it is transferred outside the UK or EEA by contacting us at dataprotection@amtivo.com.

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data retention

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, regulatory, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Your legal rights

Under certain circumstances, by law you have rights under data protection laws in relation to your personal data, as follows:

If you want to review, verify, correct or request erasure of your personal data, object to the processing of your personal data, or request that we transfer a copy of your personal data to another party, please contact dataprotection@amtivo.com. You have the right to make a complaint at any time to your local data protection authority as set out below. We would, however, appreciate the chance to deal with your concerns before you approach your data protection authority so please contact us in the first instance.

Region Data Protection Authority
UK Information Commissioner’s Office (ico.org.uk).
Republic of Ireland Data Protection Commission (dataprotection.ie)
Italy Garante per la Protezione dei Dati Personali (garanteprivacy.it)

 

Changes to this privacy policy

We keep our privacy policy under regular review. The date that this privacy policy was last updated can be found at the top of the document. If we decide to change our privacy policy, we will update all the relevant documentation and post the updated version on our website. We may also notify you by email if we hold that information.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Contact details

If you have any questions or comments regarding how we handle your personal data, please contact us at:

Email: dataprotection@amtivo.com

Post: Data Protection, Amtivo Group, 30 Tower View, Kings Hill, West Malling, Kent ME19 4UY

If you are a user of the Activ software system, you can also contact the data protection officer for MyActiv Limited at dpo@myactiv.co.uk

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