1. Important information and who we are
This website is not intended for children and we do not knowingly collect data relating to children.
Addressee: Chief Information Security Officer, Netacea Limited
Email address: firstname.lastname@example.org
Postal address: 4th Floor Maybrook House, 40 Blackfriars Street, Manchester, M3 2EG
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
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.
2. The data we collect about you and the type of data you may need to send to us
Personal data, or personal information, means any information about an individual from which that person can be identified. 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:
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender of people at your organisation who we may need to speak to in order to provide our services.
- Contact Data includes email address and telephone numbers of people at your organisation who we may need to speak to in order to provide our services.
- Technical Data includes internet protocol (IP) addresses of your customers that are used to visit your website or application (if we are providing our bot management and API protection services) and their anonymous website activity. We do not view this type of technical data as personal data but appreciate some customers in certain countries may take a different view, so we include it here to be safe. Please see the data processing addendum in our standard terms and conditions for a further breakdown of the technical data we need to deliver our services to you.
We do not collect any Special Categories of Personal Data about you (this includes details about 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) or your customers. Nor do we collect any information about criminal convictions and offences.
We do not collect personal data of your customers when providing our services and you agree that you will not send us any personal data of your customers. It is important that you agree not to do this and you will impose all the required controls within your organisation to ensure that you don’t send us personal data of your customers.
In particular, you absolutely must never send us any cardholder data of customers visiting your website. If you do, we may cease providing our services to you without any liability to you.
If you fail to provide personal data
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 goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity and Contact by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- enquire about our products or services;
- subscribe to our service or publications;
- request marketing to be sent to you;
- enter a promotion, prize draw or survey; or
- give us feedback or contact us.
Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
Technical Data from the following parties:
(a) analytics providers such as Google;
(b) advertising networks; and
(c) search information providers.
Technical Data of your website visitors that you send to our technical platform to allow us to provide our services to you, including internet protocol addresses. Please see section 11 for information about when we provide a “Log File” Proof of Value of our services.
Contact from providers of technical services.
Identity and Contact Data from data brokers or aggregators.
Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the UK.
When we provide our services to you, you will be expected to send us the required data and we will provide the necessary access rights for an Amazon Web Services S3 Bucket for you to be able to do this securely. We will speak to you about this in more detail as and when required.
4. How we 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:
- Where we need to perform the contract we are about to enter into or have entered into with you (i.e. to provide our services to you, whether for free or for a charge).
- 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.
- Where we need to comply with a legal obligation.
- You consent to us processing your personal data in a certain way.
We will always get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use 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 or the organisation you are from as a new customer||(a) Identity (b) Contact||Performance of a contract with you|
|To process and deliver your order for products and services, you order them via our website||(a) Identity (b) Contact (c) Technical||(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us)|
|To manage our relationship with you which will include:|
(b) Asking you to leave a review or take a survey policy
|(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|
|(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 this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)|| (a) Identity|
(b) Contact(a) Identity
|(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) 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|
|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|| (a) Identity|
(b) Contact(c) Technical
|Necessary for our legitimate interests (to develop our products/services and grow our business)|
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You will be able to opt in and opt out of marketing emails whenever you require.
Promotional offers from us
We may use your Identity and Contact data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at email@example.com at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions made by you (whether that be on behalf of a company or other legal entity or not).
Change of purpose
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.
5. Disclosures of your personal data
We may share your personal data with the parties set out below for the purposes explained in the table above, titled “Purposes for which we will use your personal data”.
- Internal Third Parties as set out in the Glossary at the end of this policy.
- External Third Parties as set out in the Glossary at the end of this policy.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. International transfers
We share your personal data within the Netacea Group. This may therefore involve transferring your data outside the UK to the USA. We have implemented a robust data processing agreement between Netacea Limited and Netacea, Inc. to facilitate a secure transfer of data between the two group companies.
Additionally, many of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK. Most notably, Amazon Web Services provides hosting services to us and they are based in Ireland, whilst Google provides certain services as part of our product offering.
Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- Where practicably possible, we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
- Where we use certain other service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK. This may include the implementation of standard contractual clauses in our contracts to ensure that the relevant parties outside of the UK only process your data in a safe and secure way, and in a manner that would be expected had your data not left the UK.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
7. 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.
8. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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, regulatory, tax, accounting or other requirements.
Details of retention periods for different aspects of your personal data are available in our retention policy. You may request a copy of our data retention policy by emailing firstname.lastname@example.org. Provision of a copy is at the discretion of the Legal team and the CISO, and they reserve the right to only disclose contents of Netacea’s retention policy that are (i) relevant to you and (ii) not going to cause us to be in breach of our confidentiality obligations owed to other third parties.
In some circumstances you can ask us to delete your data: see the section titled “Your Legal Rights” below for further information.
In some circumstances we will anonymise your personal data (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.
Service Providers and Sub-processors
Netacea uses third party services in its provision of its services to you, including the use of third party cookies when our platform and code is integrated into your website. It is your responsibility to keep your own privacy and cookie notices up to date to reflect that Netacea is a service provider to you, and may be a sub-processor of data (although we do not consider such data to be personal data). For your awareness and benefit, here is a list of our third party service providers included in our provision of services, and where they process data (but not personal data):
|Amazon Web Services||Hosting Services||Ireland|
|GitHub||Platform as a service||Netherlands|
|Google RECAPTCHA v2||Mitigation tool||USA|
|Microsoft Azure Databricks||Data Analytics and Architecture||USA|
|Magazzini Alimentari Riuniti||Giovanni Rovelli||Italy|
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see below for further detail about your rights. If you have any questions about these rights or wish to exercise any of them, please contact email@example.com.
You may request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
You may request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
You are entitled to request erasure of your personal data. We often also call this your right to be forgotten. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request, including when we are providing our services to you.
You can object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
You may request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data's accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
You can request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
You may withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
No fee usually required
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. Alternatively, we could refuse to comply with your request in these 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 your personal data (or to exercise any of your other rights). 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. This might include proof of authority from the business that you are requesting on behalf of and to whom we are providing a service.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could 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.
Log File Proof of Value
(i) You gave us express permission to receive the Your Technical Data;
(ii) You gave us express permission to analyse the Your Technical Data; and
(iii) You gave us express permission to prepare a report on your Technical Data.
What your Technical Data needs to consist of for us to provide this proof of value can vary depending on variables such as the nature of your technical environment and who provides hosting services to you. However, generally the Technical Data will need to include the following:
|Timestamp||Common/Combined Log Format||The time which the request was received|
|IP Address||Common/Combined Log Format||The IP address from which the request was made|
|Common/Combined Log Format||cvcv|
|Status||Common/Combined Log Format||hhgh|
|User Agent||Combined Log Format||hghgh|
|Bytes Sent||Common/Combined Log Format||Size of data being sent from the origin back to the visitor giving indications of failed/successful logins|
|Referrer||Common/Combined Log Format||URL that referred the visitor to hit the page, useful to validate the user journey|
- We call this the “Minimum Data Set” to be able to provide the Log File POV to you, and so if you would like to receive one you agree to (i) send us the Minimum Data Set and (ii) us providing a report on it.
- For the avoidance of doubt, no personal data ever makes up the Minimum Data Set.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
Internal Third Parties
Other companies in the Netacea Group acting as joint controllers or processors as the case may be, and who are based the UK and USA and provide sales and management services and undertake leadership reporting.
External Third Parties
- Service providers acting as processors based Ireland who provide hosting services, including Amazon Web Services.
- Service providers acting as processors based in the US who provide components of our service, but do not process personal data, including Google.
- Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK and US who provide legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.