Privacy Policy.

What this privacy policy covers

 

This privacy policy explains how and why Entroxy Ltd (“we”, “us” or “Entroxy”) may collect and process personal data (including through your use of our website www.entroxy.com, when you purchase a service or product from us, when you complete one of our surveys or if you apply for a job with us) and the rights you have in relation to your personal data.

 

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

 

This privacy policy is provided in a layered format so you can click through to the specific areas set out below.  Alternatively, you can download a pdf version here.

 

Our details

 

For the purposes of our business we are the data controller.  We are registered with the Information Commissioner’s Office under registration number ZA769973.

 

In respect of processing that we undertake on behalf of our clients we are the data processor and our client is the data controller who determines the purpose and means of the processing of personal data which they provide us with.   There may be instances where we are a joint controller with our client.

 

We have appointed a Data Protection Lead who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your rights, our Data Protection Lead (Chris Toogood, CEO) can be reached at chris@entroxy.com.

 

Our commitment to you

 

We respect your privacy and are committed to protecting your personal data. Furthermore, we fully endorse and will adhere to the General Data Protection Regulation (Regulation (EU) 2016/679) (the “GDPR”) and all UK data protection legislation including the Data Protection Act 2018.

 

In particular we will comply with our legal obligations to keep personal data up to date, to store and destroy it securely, to not collect or retain excessive amounts of data, to use reasonable measures to protect personal data from loss, misuse, unauthorised access and disclosure and to ensure that appropriate technical measures are in place to protect personal data.

 

How you acknowledge this privacy policy

 

By using any of our services (including our website) and by providing us with any personal data, you acknowledge that you understand that the use of the personal data will be in accordance with this policy.

Please do not send us any information if you do not want it to be used in this way.

Please note that if you do not provide certain requested information we may be unable to provide certain of our services to you and you may be unable to access certain content via our website.

 

Personal data which you provide on behalf of someone else

 

If you give us information on behalf of someone else, you confirm that the other person has appointed you to act on his/her behalf and has agreed that you can (i) give consent on his/her behalf to the processing of his/her personal data and (ii) receive on his/her behalf any data protection notices.

 

This website is not intended for children and we do not knowingly collect data relating to children.

 

The personal data we collect about you

 

Personal data means any information about a living individual which allows them to be identified from that data. Identification can be by the information alone or in conjunction with any other information.  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 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.

  • Contact Data includes physical address, email address and telephone numbers.

  • Financial Data includes bank account and payment card details.

  • Transaction Data includes details about payments and services and products purchased.

  • Technical Data includes internet protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform.

  • Profile Data includes username and password, purchases or orders made, your interests, preferences, feedback and survey responses.

  • Usage Data includes information about how you use our website, services and products.

  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

 

We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose.  Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will 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 policy.

 

We do not anticipate collecting any special category 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).  Nor do we anticipate collecting any information about criminal convictions and offences.  We would only collect such information if you have been properly informed of the nature of the processing, the purpose for which it is being carried out and the legal basis we are relying on.

 

 

How we obtain information about you

1. Information which you provide us

You may provide us with personal data if, for example, you:

  • fill in a form on our website www.entroxy.com (for example a contact or enquiry form);

  • talk to our online Chatbot;

  • email or phone us;

  • meet us in person or by telephone or video conference call;

  • provide us with your business card;

  • register to join our mailing list;

  • enter a competition or promotion; or

  • complete a survey.

 

2. Information we collect about you

We collect information about you when you engage with us online or by email e.g. when you visit our website, open or forward an email sent by us, engage with us on social media networks or when you are served one of our tailored adverts.  Information may be collected via cookies and similar technologies, as detailed below.

3. Information we receive from other sources

We may also collect information about you from reputable third parties that operate in accordance with UK data protection legislation or other publicly available sources, if this is permitted by law, such as:

  • social media sites e.g. LinkedIn (see https://www.linkedin.com/legal/privacy-policy for LinkedIn’s privacy policy);

  • advertising networks;

  • analytics providers e.g. Google (see https://policies.google.com/privacy for Google’s privacy policy);

  • search information providers;

  • data brokers and aggregators;

  • providers of technical, payment and delivery services;

  • business partners; and

  • identity and credit reference agencies.

Use of cookies and similar technologies

 

We may use cookies and similar technologies such as pixel tags and web beacons on our website and in our some of our emails.

What is a cookie?

A cookie is a small file of letters and numbers which is sent to and stored on your computer (or other electronic device) to identify you whenever you visit a website.

There are many types of cookies but broadly they can be grouped by purpose:

  • strictly necessary cookies – i.e. those cookies that are required for the operation of a website and include, for example, cookies that enable website users to log into secure areas of a website, use a shopping cart or make use of e-billing services;

  • analytical or performance cookies – these allow website owners to recognise and count the number of visitors and to see how visitors move around their website when they are using it (this helps them to improve the way their website works, for example, by ensuring users are finding what they are looking for easily);

  • functionality cookies – these are used to recognise a website user when they return to a website (this enables a website owner to personalise content for users, greet users by name and remember user preferences when they return to a website e.g. their choice of language or region);

  • targeting cookies – these cookies record a website user’s visit to a website, the pages they have visited and the links they have followed (this enables website owners to make their website and the advertising displayed on it more relevant to user interests).

 

Cookies can also be grouped according to whether they are ‘first-party’ cookies or ‘third-party’ cookies. The difference is that first-party cookies are placed and controlled by the website you are visiting whereas third-party cookies are placed and controlled by a third-party.

 

What are pixel tags and web beacons?

Pixel tags and web beacons are tiny graphic images embedded in a web page or in emails to achieve similar purposes as those described above.

 

How and why we use cookies and similar technologies

We use strictly necessary and analytical/performance cookies as described above, including Google analytics cookies for statistical purposes to collect data about website usage (for example page views and time spent on our website). This data does not include personally identifiable information.

 

To learn how to manage cookies and control your privacy and how to opt out of receiving email notifications or marketing materials from us please read the relevant sections below. For a detailed cookie report, please contact us.

 

How to manage cookies and control your privacy

 

Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, please visit www.allaboutcookies.org and www.youronlinechoices.eu. For a video about cookies visit www.google.co.uk/policies/technologies/cookies.

 

The exact procedure to prevent new cookies from being installed and how to delete existing cookies depends on which browser you are using but the following links may be helpful:

 

If you do not want your website visits to be recorded by Google Analytics you can opt-out with the addition of the Google Analytics Opt-out Browser Add-on which is available for Microsoft Internet Explorer 11, Google Chrome, Mozilla Firefox, Apple Safari and Opera.

You can choose to disable cookies in your internet browser but please note that if you delete cookies or decline to accept them you may not be able to use all of the features we offer, or store your preferences; in addition, some of our web pages might not display properly. If you want to turn off the more invasive cookies but leave most other functionality in working order, then a good option is to turn off third-party cookies using your browser settings.

In addition, we recommend that you check your privacy settings on any site which requires you to register or login, and that you never save your passwords in your browser or on your device, other than in a reputable password management system.

 

How we use your personal data

 

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

 

  • where we need to perform a contract we are about to enter into or have entered into with you;

  • 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; or

  • where we need to comply with a legal obligation

 

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

 

Please note that we may process 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.  We have set out below, in a table format, a description of the ways we may use 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.

 

Purpose of processing

Categories of Individuals

Type of data

Lawful basis for processing including basis of legitimate interest

We will only use your information for the purpose it was collected (or for similar/related purposes).  If we need to use personal data for an unrelated purpose we will notify you and we will explain the legal basis which allows us to do so.

 

Who your personal data may be shared with

 

We recognise that your information is valuable and will take all reasonable measures to protect your information while it is in our care (see how below).

Your personal data may be transferred to:

  • Third party service providers who store/process information on our behalf, including providers of:

    • payment services;

    • survey services;

    • telephone/video conferencing services;

    • information technology;

    • system administration;

    • identity management;

    • website hosting and management;

    • data analysis;

    • data back-up; and

    • security and storage services

​​

​​

  • contractors, consultants and advisers that provide a service to us or act as our agents;

  • professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services;

  • mailing or printing agents;

  • law enforcement, regulatory, or other government agencies (including, for example, HM Revenue & Customs) for the purposes of fraud prevention and/or to comply with any legal and regulatory issues and disclosures; and

  • third parties to whom we may choose to sell, transfer or merge parts of our business or our assets and if a change happens to our business then the new owners may use your personal data in the same way as set out in this privacy policy.


We may also share certain pieces of aggregated, non-personal data about you with third parties.  For example, we may provide a third party with information such as the number of users who searched for a particular term or how many users clicked on a particular advertisement.  This information does not identify you individually.


We do not sell, rent, distribute or otherwise make personal data commercially available to any third party except as described in this policy or with your prior permission.


 

Security and protection of your personal data

 

We use reasonable technical, administrative and physical controls to safeguard your personal data from unlawful use and unauthorised disclosure.  In addition, we limit access to your personal data to those directors, employees, agents, consultants, contractors and other third parties who have a business need to know.  They are bound by law or contract to protect your personal data, are subject to a duty of confidentiality and will only process your personal data on our instructions.  In all cases we will ensure that any access or transfer of your personal data is compliant with UK data protection law.


We normally only store your personal data within the European Economic Area (“EEA”).   If one of our service providers needs to transfer your personal data outside of the EEA then we will either ensure a data protection level equal to the one in the EEA or we will obtain your consent to the transfer.  The way we ensure a data protection level equal to the one in the EEA is by ensuring at least one of the following safeguards are implemented:
 

​​

For example, Google LLC (the provider of G Suite for business) and Slack Technologies, Inc (who we use to correspond with our clients and staff) may transfer your personal data outside of the EEA as they are US organisations – they however participate in and comply with the EU-US Privacy Shield Framework and accordingly the European Union allows the transfer.


While we will use all reasonable efforts to safeguard your personal data you acknowledge that the use of the internet is not entirely secure and understand that we cannot guarantee the security or integrity of any personal data that is transferred from you or to you via the internet. If you want detailed information on how to protect your information and your computers and devices against fraud, identity theft, viruses and other online problems you can visit Get Safe Online, which is supported by HM Government and leading businesses.

 

Data retention

 

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.

 

By law we have to keep basic information about our clients (including Contact, Identity and Transaction Data) for seven years after they cease being clients.

 

In some circumstances you can ask us to delete your data: see your rights below for further information.

 

We may 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.

 

Links to third-party sites

 

This privacy policy only addresses the use and disclosure of personal data by us. Our website may include links to third-party websites, plug-ins and applications which may be of interest to you. In addition, we may provide social sharing and follow buttons on our website. If you use or follow these links or buttons to any of these third party sites, please be aware that they have their own cookies and privacy policies which we recommend you read. We do not control these other sites and we cannot be responsible for the content of these sites or for protection of any information you provide to other sites.  You should be cautious when entering personal data online.

Your rights

 

We want to ensure you remain in control of your personal data.  Part of this is making sure you understand your legal rights.

 

You have a number of legal rights under applicable data protection legislation in relation to your personal data, including:
 

  • The right to request access to a copy of the personal data that we hold and certain supplementary information (e.g. the sources from which we acquired the information, the purposes for processing the information and the persons/entities with whom we are sharing the information). We may (i) refuse to provide details and/or (ii) charge a small fee, if relevant legislation allows us to do so, in which case we will provide reasons for our decision as required by law.

  • The right to request erasure of your personal data in certain circumstances. 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.  Please note that there may be circumstances where you ask us to erase your information but we are legally entitled to retain it (the specific legal reasons will be notified to you, if applicable, at the time of your request).

  • The right to withdraw your consent to the use of your information where we are relying on that 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 services or products to you.  We will advise you if this is the case at the time you withdraw your consent.  Please note that we may still be entitled to process your information if we have another legitimate reason (other than consent) for doing so.

  • In some circumstances, you have the right to receive some of your information in a usable format and/or request we transmit that data to a third party where this is technically feasible. Please note that this right of transfer only applies to information which you have provided to us.

  • The right to request correction of the personal data we hold free of charge, if it is inaccurate or incomplete (though we may need to verify the accuracy of the new data you provide to us).

  • The right to 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.

  • The right to 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.

  • Again, there may be circumstances where you ask us to restrict the processing of your information, but we are legally entitled to refuse that request.

  • The right to make a complaint with the Information Commissioner if, after raising your concern with us and making a privacy complaint, you think that any of your rights have been infringed by us.


You can exercise your rights by contacting us. Please note that we usually act on requests and provide information free of charge. We may however be entitled to refuse to act on a request and we may charge a reasonable fee in relation to our administrative costs if the request is baseless, excessive or repeated.

We will respond to you as soon as we can. This will generally be within one month from the date we receive your request but if your request is going to take longer to deal with we will let you know.


 

How to opt out of receiving marketing materials

 

You have the right to opt out from receiving marketing materials from us. You can do this by contacting us or by clicking on the relevant link in the email itself. You may choose to opt out of one or all lists.

Making a privacy complaint
 

If you want to submit a written complaint about how we handle your personal data, please contact us or email our Data Protection Lead at chris@entroxy.com.

If you make a privacy complaint, we will respond to let you know how your complaint will be handled.  We may ask you for further details, consult with other parties and keep records regarding your complaint.

 

Contact and further information

 

If you have any questions or concerns about this privacy policy or the information we hold about you please contact us or email our Data Protection Lead at chris@entroxy.com.

 

Changes to our privacy policy and your duty to inform us of changes

 

This privacy policy is subject to change from time to time without notice.  Changes may be made when our business practices change or when data privacy laws are updated.  You should therefore check this policy regularly to ensure that you are aware of any changes.  This version was last updated in July 2020 and historic versions can be obtained by contacting us.

 

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.