1. General

S.G.F.E. is committed to protecting and respecting personal privacy. This privacy notice sets out how we collect and process the personal data of general visitors to our website as well as of clients and prospective clients with whom we may interact by means of other marketing and communication channels in addition to our website.

For the purposes of data protection legislation, we are the data controller and we will process personal data in accordance with the General Data Protection Regulation (“GDPR”).  Our contact details are as follows:

Company name:  S.G.F.E. Limited

Postal address: 5 Flag Business Exchange, Peterborough, Cambs, PE1 5TX

Email contact:  privacy@sgfe.co.uk

According to the criteria set out in Article 37 of the GDPR we are not required to appoint a Data Protection Officer and have not done so.  Any questions, concerns or complaints relating to data privacy issues should be addressed to the email address above.

  1. Personal data, purpose and lawful basis for processing

Personal data means any information capable of identifying an individual.  We may process the following categories of personal data about you:

Contact Data:  this includes data relating to your contact details such as your name, address, phone number, email address, and social media contact details.  We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defence of legal claims. Our lawful basis for this processing is our legitimate interests which in this case are to communicate with clients, potential clients and general visitors who wish to communicate with us, to keep records and to establish, pursue or defend legal claims.

Contextual Data:  this includes data relating to your personal and business background that provides the necessary context for understanding your requirements of us and how we may best service your needs. By its very nature the scope of this kind of information is likely to vary widely from individual to individual, but may include details of personal objectives, motivations, values and aspirations.  We process all contextual data for the purposes of tailoring our services to match your specific personal and business needs.  Our lawful basis for this processing is our legitimate interests which in this case are to service our target market by being able to properly evaluate and meet the specific individual requirements of clients and prospective clients, to keep records and to establish, pursue or defend legal claims.

Transaction Data: this includes data relating to any purchases of goods and/or services such as your name, title, billing address, delivery address, email address, phone number, purchase details and payment-related details. We process this data to supply the goods and/or services you have purchased and to keep records of such transactions. Our lawful basis for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract.

User Data: this includes data about how you use our website and any online services together with any data that you post for publication on our website or through other online services. We process this data to operate our website and ensure relevant content is provided to you, to ensure the security of our website, to maintain back- ups of our website and/or databases and to enable publication and administration of our website, other online services and business. Our lawful basis for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business.

Technical Data: this includes data about your use of our website and online services such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is from our analytics tracking system. We process this data to analyse your use of our website and other online services, to administer and protect our business and website, to deliver relevant website content and advertisements to you and to understand the effectiveness of our advertising. Our lawful basis for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business and to grow our business and to decide our marketing strategy.

Marketing Data: this includes data about your preferences in receiving marketing from us and our partners and your communication preferences. We process this data to enable you to partake in our promotions, to deliver relevant website content and advertisements to you and measure or understand the effectiveness of this advertising. Our lawful basis for this processing is our legitimate interests which in this case are to study how clients use our products and services, to develop them, to grow our business and to decide our marketing strategy.

We may use Contact Data, Contextual Data, Transaction Data, User Data, Technical Data and Marketing Data to deliver relevant website content and advertisements to you (including social media adverts or other display advertisements) and to measure or understand the effectiveness of our advertising. Our lawful basis for this processing is legitimate interests which is to grow our business. We may also use such data to send other marketing communications to you. Our lawful basis for this processing is either consent or, in circumstances where consent is neither appropriate nor practical, our legitimate interests which in this case are to grow our business.

Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have ordered but if we do, we will notify you at the time.

We will only use your personal data for a purpose it was collected for, as set out in this privacy policy. For more information on this please email us at privacy@sgfe.co.uk. In case we need to use your details for an unrelated new purpose we will let you know and explain the lawful basis for processing.

We may process your personal data without your knowledge or consent where this is required or permitted by law.

We do not carry out automated decision making or any type of automated profiling.

 

  1. Special categories of personal data

As stated in section 2 above in relation to processing Contextual Data about you, we may process some special categories of personal data that includes details of your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data.

In addition to the requirement under Article 6 of the GDPR for a lawful basis for processing of such special categories of personal data, as has been set out above under Contextual Data, the GDPR additionally requires that at least one of the conditions of Article 9 of the GDPR must also be met.  Any special categories of your personal data that we process will be in accordance with Article 9(2)(a) of the GDPR, namely where you have given explicit consent to the processing of such data for one or more purposes.

We do not collect any information about criminal convictions and offence.

  1. How we collect personal data

We may collect personal data in a number of ways, including:

  • From contact forms on our website
  • From registration forms for events we run
  • Through person to person contact – meetings, phone calls, events etc
  • Through our team’s legacy personal and business contacts
  • Through referrals from our clients or other personal and business contacts
  • From social networking platforms such as LinkedIn
  • From software on our website such as cookies (please note that we do not currently use cookies on our website)

In general, we do not collect any personal data on clients or prospective clients from third party sources.  If we do occasionally collect personal data through such third party sources, we will ensure that an appropriate lawful basis under the terms of the GDPR exists for the processing of such data by both the relevant third party and ourselves.

  1. Individual rights

Under the GDPR you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent.

You can see more about these rights at:

https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

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

The GDPR gives you the right to object to the processing of your personal data in certain circumstances or withdraw your consent to the processing of your personal data where this has been provided.  If you wish to object to the processing of your personal data or to withdraw your consent (where applicable), please email us at privacy@sgfe.co.uk.

You also have the right to access information held about you and for this to be provided in an intelligible form. If you would like a copy of some or all of your personal data, please email us at privacy@sgfe.co.uk.

You can also ask us to undertake the following:

  • update or amend your personal data if you feel this is inaccurate
  • remove your personal data from our records entirely
  • restrict the use of your personal data so that it is only used for certain purposes (e.g. you may require us only to hold your data for the purpose of providing services to you but not for marketing purposes).

We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the personal information that we hold about you or make your requested changes. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Data protection legislation may allow or require us to refuse to provide you with access to some or all the personal information that we hold about you. If we cannot provide you with access to your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

If you wish to exercise any of the rights set out above, please email us at privacy@sgfe.co.uk.

You will not have to pay a fee to access your personal data or to exercise any of the other rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive or refuse to comply with your request in these circumstances.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you.

  1. Complaints

If you are not happy with any aspect of how we process your data, you can contact us at the email address in section 1 and we will investigate the matter and try to resolve it to your satisfaction.

You also have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk).

  1. Security

The transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of any personal data that you transmit to our website; any transmission is at your own risk.

We have put in place appropriate physical, technical and organisational measures designed to secure your personal data against accidental loss and unauthorised access, use, alteration or disclosure. We allow access to your personal data only to those staff, contractors and third parties who have a business need to know such data.

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

  1. International (non-EEA) processing

We may share your personal data with third party service providers that are based outside the European Economic Area (EEA), so their processing of your personal data will involve a transfer of data outside the EEA.

Even though such third parties are based outside the EEA, they are legally bound by the terms of the GDPR.  We will take appropriate steps, including meeting the requirements of the GDPR for written contracts with data processors that include specific terms, to ensure that any such non-EEA providers are properly observing the requirements of the GDPR.

If you are not satisfied that your personal data is appropriately protected under such arrangements with third parties outside of the EEA, then you may exercise your right to object as set out in section 5 above at any time.

  1. Sharing of personal data

We may have to share your personal data with the parties set out below:

  • Staff, contractors and partners to facilitate the provision of services to you
  • Other related companies and companies who we work closely with to provide an overall service offering to our clients
  • Any third parties who provide services to us
  • Service providers who provide IT and system administration services
  • Professional advisers including lawyers, bankers, auditors and insurers
  • Government bodies that require us to report processing activities
  • Third parties to whom we sell, transfer, or merge parts of our business or our assets
  • The police, regulatory bodies, legal advisors or similar third parties where we are under a legal duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our website terms and conditions of use and other agreements; or to protect our rights, property, or safety of our clients, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

We will not sell or distribute your personal data to other organisations without your approval.

  1. Data retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

When deciding what the correct time is to keep the data for we look at its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.

UK tax law requires us to keep basic information about our clients (including Contact, Identity, Financial and Transaction Data) for a minimum six years after they stop being clients.

In some circumstances we may anonymise your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

  1. Website links

Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy policies. When you leave our website, we encourage you to read the privacy notice of every website you visit.

  1. Policy review

We will review this policy on a regular basis to ensure it is kept up-to-date.  Any changes we make to our privacy policy will posted here and we encourage you to check this policy from time to time for any changes.

This policy was last updated on 18 May 2018.