- Your personal information we collect and how we use it
- Who we share your personal information with
- How long we will retain your personal information for
- Safeguarding your personal information
- Your rights
- Your right to complain to a supervisory body
- Transfer of your personal information
- Other websites
- Changes to this policy
- Contact us
2. Your personal information we collect and how we use it
We collect information about you that you supply to us in various ways which include but are not limited to:
- From emails, telephone calls, website contacts/registrations, requests for services, incoming mail
- Registration to purchase and/or download products from Easysoft
- Information from other organisations e.g. LinkedIn
- Receipt of applications for employment and associated correspondence
- Ongoing conduct of business relationships and exchange of correspondence
This information may include, but is not limited to your name, address, email address, and phone/mobile number.
Specifically, for job applicants this may also include recruitment and onboarding information that we require to assess your application and establish your suitability for employment. This may include but is not limited to: CV, work history, identity documents, National Insurance Number, Disclosure and Barring Service checks, health information, references, credit history, personal financial information. Health information will only be required where relevant to comply with Health and Safety or Disability discrimination obligations.
Our lawful bases for processing are:
- Contract: for setting up and managing your business relationship with us (as a supplier or a client); purchasing/downloading products and updates
- Contract: Processing employment applications
- Legal obligation: to comply with our legal and regulatory obligations
- Legitimate interest: management of business risks and providing product/market information and updates to interested third parties
If you intend to buy and download software from us, you will have to create an account with us. Our web server also logs information about your visit to the Easysoft website such as your IP address, browser type and, when applicable, your referring domain (e.g. "www.google.com"). We use this information to identify trends that can help us improve the web site.
Website usage information is also collected using cookies. Cookies are text files placed on your computer to collect standard internet log and visitor behaviour information. We use it to track visitors' use of the exchange, personalise repeat visits and to compile statistical reports on exchange activity. For further information visit www.aboutcookies.org or www.allaboutcookies.org. Cookies do not give us access to your computer or any information about you. We do not store any of your personal information in your Cookies.
You can set your browser to not accept cookies. The above websites tell you how to decline cookies and remove them from your browser. However, in a few cases some of the functionality of our website may not operate as a result e.g. you will not be able to purchase or download software.
We may record our telephone conversations with you for training and monitoring purposes and for effective resolution of any complaints or disputes that may arise.
In our legitimate interest, we may carry out profiling and analysis of your data. This process may involve automated decision-making processes e.g. to determine your eligibility to open an account with us, although all such decisions are supported by a human intervention.
Your personal information may also be used to notify you about important changes, new services and special offers which may be of particular interest to you. We will not send you offers without your express consent.
Your data may be used to create aggregated and anonymised statistical data.
When accessing our website and Services and agreeing to our Terms & Conditions, you consent to us collecting, using, maintaining and disclosing personal information that you provide to us as described in this Policy.
3. Who we share your personal information with
We do not sell or provide personal information to third parties for marketing purposes.
Your data may be shared with other companies within the Steve Ltd. Group of companies.
We may share your data with legal or regulatory bodies where we are required to do so by law.
4. How long we will retain your personal information for
Your information will only be retained for as long as we reasonably need it for legal and/or legitimate business purposes as is necessary to allow us to conduct our business relationship. Typically, this will not exceed 7 years after account closure. However, we may need to retain your information indefinitely e.g. to comply with legal requirements, for loss prevention, to protect our rights, privacy, safety, or property, or those of other persons in accordance with our legitimate interests.
In the case of data supplied in support of an unsuccessful employment application, we will retain the minimum data required to support future recruitment activities for one year or for legal purposes for seven years from the date of the decision being advised to you. All other data will be destroyed immediately after the decision has been taken.
We will employ industry best practices to ensure that your data remains secure at all times including its secure disposal.
5. Safeguarding your personal information
We are committed to safeguarding your information. Any information provided by you will be handled with high security and confidentiality and in accordance with the GDPR and Data Protection Act. In order to prevent unauthorised access or disclosure, accidental loss or destruction of personal data, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect. When you place an order on the Easysoft web site, your information is encrypted using the Secure Socket Layer (SSL) protocol.
Generally, e-mail is not considered a secure medium of communication, hence, we advise that you take all reasonable care when sending us private and sensitive information via e-mail. Ensure that your network is secure for personal communication.
Although we take reasonable steps to ensure information security, we cannot be responsible for any acts of unauthorised access or abuse of our website. We make no warranty that we will always be able to prevent such access.
6. Your rights
The GDPR gives you certain rights about your data. These rights may be passed on to any third party with whom we have shared your data. Your rights may be exercised at any time by contacting us (contact details are below). They are summarised as follows:
The right of access: You have the right to request a copy of the information that we hold about you. This will be provided free of charge within 1 month, subject to confirmation of your identity.
The right to rectification: we will rectify any inaccurate or incomplete data within one month of notification by you.
The right to erasure of your data, if: it is no longer required for the purpose for which it was collected; you withdraw your consent to its use and there is no legitimate interest to retain it; it was unlawfully processed or needs to be erased for a legal reason; it relates to a child. This right does not apply where we need to retain the data due to a legal obligation or in defence of any claim.
The right to restrict processing: where you contest the accuracy of the data; you object to its processing; processing is unlawful; you require the data for a legal claim and we no longer require it.
The right to data portability: you may move, copy or transfer your data to another IT environment in a commonly used format free of charge within one month of the request (subject to confirmation of your identity). This right applies only to data which you personally supplied to us consensually or contractually and which is processed automatically.
The right to object to: processing based on legitimate interests; direct marketing (including profiling). Such requests will be responded to immediately unless overriding legal or legitimate grounds exist.
The right not to be subject to automated decision making and profiling: For automated decisions, you can insist on human intervention, can express your point of view and request an explanation of any automated decision and challenge that decision. This right does not apply where the automated decision is contractual, authorised by law, consensual or where it has no legal or significant effect on you. In all cases, we will ensure that we are fair and transparent about the logic involved, we use appropriate decision-making procedures, inaccuracies and errors are minimised and data is kept secure.
7. Your right to complain to a supervisory body
Should you remain dissatisfied with how we have dealt with your complaint or handled your information, you have the right to complain to the Information Commissioner's Office (ICO). Further details can be found on the Information Commissioner's website at https://ico.org.uk/concerns/.
8. Transfer of your personal information
Although unlikely, we may need to transfer your information outside the European Economic Area. All such transfers will be carried out in full compliance with the GDPR and any other applicable legislation.
9. Other websites
10. Changes to this policy
11. Contact Us information
The Data Controller of your data is Easysoft Ltd, Thorp Arch Grange, Thorp Arch, Wetherby, LS23 7BA. Our Data Protection Officer may be contacted at this address or as follows:
Telephone: 01937 860000
We are registered with the Information Commissioner's Office (ICO) as a data controller. Our registration number is ZA348342. You may view our details on the register: https://ico.org.uk/ESDWebPages/Entry/ZA348342.
PUBLIC v.1.0 May 2018