We are Chalkboard Software Limited, a company registered in England and Wales with company number 09192721, whose registered office is at 7 Bell Yard, London, WC2A 2JR (the "Company" or "we" or "us").
The Company and personal information: We are committed to lawful, fair and transparent processing of all personal information about our employees, customers, suppliers and other third parties during the course of our business activities. We will always comply with any applicable data protection legislation and we will ensure that the collection and use of personal information is carried out in accordance with applicable data protection laws. The main law governing data protection is the Data Protection, Privacy and Electronic Communications (Amendments etc.) (EU Exit) Regulations 2019 (SI 2019/419) “DPPEC” and the Data Protection Act 2018 (UK-GDPR).
What this policy is: This policy (and any other documents referred to in it, together with any privacy notice displayed on our website) sets out the basis on which we will process any personal information about you or individuals generally - whether it's information we collect from those individuals or that is provided to us from other sources. This policy sets out rules on data protection and the legal conditions that must be satisfied when we obtain, handle, process, transfer or store personal information.
Registration: While the Data Protection Act 1998 requires us to be registered with the Information Commissioner's Office, we will remain registered under registration number: [ZA081718]. We will also comply with any successor notification requirements. Please note that, as explained below, we may only be processing your personal data on behalf of another party, who will be the data controller in respect of that information
Controlling and processing information: We are the controller of all personal information used in our business for our own commercial purposes. Sometimes though, we will process personal information on behalf of another data controller - and when this is the case, we will do so only in accordance with the instructions of that data controller and otherwise in accordance with the UK-GDPR. If we are processing on behalf of another data controller, that data controller will provide relevant information to you about how your data is being shared.
Why you should read this policy: It is important that you read this policy, together with any other documents referred to in it, so that you are aware of how any personal information relating to you will be dealt with by us.
We are accountable for demonstrating compliance with the UK-GDPR's six principles of processing personal information. These provide that personal information we deal with must be:
Personal information: In this policy, when we use the term "personal information" we mean any information relating to an identified or identifiable human being. (An "identifiable" natural person is one who can be identified, directly or indirectly, for example, 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, biometric, mental, economic, cultural or social identity of that person.)
Sensitive personal information: In this policy, when we use the term "sensitive personal information" we mean special categories of information which are personal information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying someone, data concerning health or data concerning someone's sex life or sexual orientation.
We may collect, record, organise, structure, store, adapt, alter, retrieve, consult, use, disclose by transmission, disseminate or otherwise make available, align or combine, restrict, erase or destroy the following types of personal information about you:
We do not collect, store or use sensitive personal information.
In the course of our business, we may collect personal information directly from an individual
We may also collect personal information about individuals from other sources such as:
We will only collect personal information to the extent that it is required for the specific purpose notified to individuals about whom we are collecting it and/or as instructed by any data controller on whose behalf we are acting - and we will keep it only as long as is necessary.
We will only use personal information when the law allows us to do so and relying on a relevant basis for lawful processing in each instance. We will use your personal information in the following circumstances, relying on the basis of processing indicated:
Basis of processing: Where we need to perform a contract we are about to enter into or have entered into with you.
Basis of processing: Where it is necessary for our legitimate interests (or those of a third party, such as a client using our services) and we have undertaken an assessment to determine that processing for those interests (listed below) does not outweigh your interests and fundamental rights, considering the nature and impact of the processing and any relevant safeguards we can put in place.
Basis of processing: Where we need to comply with a legal or regulatory obligation.
Basis of processing: Where you have consented to the processing.
Other issues about how we use personal information:
We may use your personal information to provide you (and you only) with information relating to the goods and/or services that you use. Examples of such information may be: emails about new products, special offers, customer events or other information which we think you may find useful or interesting. Under no circumstances will we ever use personal information held by you on behalf of your customer in any way.
We will only ever process personal information for the above purposes with your specific consent, which you give us when you sign-up for an account. You have the right to withdraw this consent at any time. Information about how to withdraw your consent is set out below.
We may also disclose your information to our subsidiaries for the purpose of marketing. Again, we will only do this with your explicit consent and you have the right to withdraw this consent at any time. Information about how to withdraw your consent is set out below. Please see "Data Sharing" below for further details.
In this policy, where we have referred to needing your consent for any processing, we will make sure that the consent:
Automated decision-making takes place when an electronic system uses personal information to make a decision relevant to you without human intervention.
We do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes.
Transfer of personal information outside of the EEA: We may transfer certain personal information that we hold on individuals living in the European Union to a country outside the European Economic Area ("EEA"), provided that one of the following conditions applies:
Subject to the requirements set out above, the personal information we hold may also be processed by individuals operating outside the EEA who work for us or for one of our suppliers. Those individuals may be engaged in, among other things, the fulfilment of contracts with the relevant individual, the processing of payment details and the provision of support services.
Safeguards: If we use a third party data processor to process personal information on our behalf, we will obtain contractual commitments to safeguard the security of the personal information to ensure that the third party only acts on our instructions when using that personal information and that the third party has in place appropriate technical and organisational security measures to safeguard the personal information. Whenever we transfer your personal information out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
Please contact us if you want further information on the specific mechanism used by us when transferring your personal information outside the EEA.
Why we might share your personal information with third parties: We may share personal information we hold with:
(i) any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries and/or
(ii) in the event that we sell or buy any business or assets, or sell the Company, we will disclose your personal data to the prospective seller or buyer of such business or assets. We may also disclose personal information we hold to third parties if we are under a duty to disclose or share an individual's personal information in order to comply with any legal obligation, or in order to enforce or apply any contract with that individual or other agreements; or to protect our rights, property, or safety of our employees, customers or others. This includes exchanging personal information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
We may also share personal information we hold with selected third parties for the purposes set out below.
Third party service providers who may process your personal information: When we use the term "third party", we mean any entity who is not the Company, including third party service providers, contractors and designated agents and any member of our group. The third party service providers listed at Appendix A may have access to your personal information:
We have put in place internal procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
We will not keep personal information in a form which permits identification of individuals for longer than is necessary for the purpose or purposes for which they were collected. We will take all reasonable steps to destroy, or erase from our systems, all data which is no longer required (or, where we are processing on behalf of another data controller, return their information to them). To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of personal information, the purposes for which we process information and whether we can achieve those purposes through other means, and the applicable legal requirements. Information marked as no longer required it automatically, permanently deleted after no more than 7 days.
We will only keep personal information for as long as is necessary for the purpose or purposes for which that personal information is processed; and we will explain to anyone about whom we process data how long that is or the criteria that go into deciding how long that is.
We may sometimes anonymise your personal information (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Our website may, from time to time, contain links to and from the websites of partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies or the security of these websites. Please check the relevant policy before you submit any personal information to these websites.
Under certain circumstances, you have rights under data protection laws in relation to your personal information, as summarised below.
You have the right to:
If you wish to exercise any of the rights set out above, please contact us at [email protected] or contact our Information Officer as detailed below. We aim to respond to all legitimate requests within one month (and if we are only processing the data in question on behalf of another party, the response may actually come from that other party as the relevant data controller). 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 and keep you updated.
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 is clearly unfounded, repetitive or excessive - alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask for further information in relation to your request to speed up our response.
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The person nominated to oversee how the Company deals with personal information, our Information Officer, is responsible for ensuring compliance with UK-GDPR and with this policy. The Information Officer is contactable on +44 (0)20 8720 9212, [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 Information Officer.
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.
You have the right to make a complaint at any time to the Information Commissioner's Office, the UK supervisory authority for data protection issues (https://www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the Information Commissioner's Office, so please contact us in the first instance.
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