1. Data protection responsibilities
1.1 We are committed to safeguarding the privacy of our website visitors at statpro.com.
1.2 StatPro Group Plc (“we”, “us” and “our”) is a “controller” of your personal data. This is a legal term – it means that we make decisions about how and why we process your personal data, and, because of this, we are responsible for making sure it is used in accordance with data protection laws.
1.3 You should read this notice, so that you know what we are doing with your personal data. Please also read any other privacy notices that we give you, that might apply to our use of your personal data in specific circumstances in the future.
1.4 “Personal data” means any information that relates to an identifiable natural person. Your name, address, contact details, IP address and job title are all examples of your personal data, if they identify you.
1.5 The term “process” means any activity relating to personal data, including, by way of example, collection, storage, use, consultation and transmission.
1.6 We will ask you to consent to our use of certain cookies when you first visit our website. Please see StatPro’s cookie’s policy for more information about the cookies we use. To the extent personal data is gathered using cookies our use of this personal data is further explained in this privacy notice.
2. What types of personal data we collect, where we get it from, the purposes for which we use it and the legal basis we rely on
2.1 In this Section 2 we have set out:
(a) the general categories of personal data that we may process;
(b) the source of the personal data that we may process;
(c) the purposes for which we may process personal data; and
(d) the legal bases or reasons we rely on in order to process personal data lawfully.
2.2 We may process personal data about your use of our website (“usage data“). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system (Google Analytics). This usage data may be processed for the purposes of analysing the use of the website. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website.
2.3 We may process your personal data information provided by you in forms on our website, which includes personal data you provide when registering for our events (“profile data“). The profile data may include your name, title, address, telephone number, email address, job title and dietary and access (to venue) requirements in the case of registering for events. The profile data may be processed for the purposes of enabling and analysing (on an anonymised basis) your use of our website and services, along with sending marketing information and product update emails where requested and accommodating your requirements at events.
The legal basis for this processing is consent which we collect via an opt in from you (in respect of direct marketing) and our legitimate interests (in respect of the other processing mentioned here), namely the proper administration of our website and business. Please see Section 6 on direct marketing for more information on that use.
2.4 We may process information contained in any online form enquiry you submit to us regarding goods and/or services, which includes personal data provided when enquiring about or registering for events (“enquiry data“). The enquiry data may include your name, title, address, telephone number, email address, job title and dietary and access (to events) requirements in the case of registering for events (which is deleted immediately following the event). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is consent.
2.5 We may process information that you provide to us for the purpose of subscribing to our email blog and product notifications and/or newsletters (“notification data“). The notification data may be processed for the purposes of sending you the requested relevant notifications and/or newsletters. The legal basis for this processing is consent. Please do not supply any other person’s personal data to us, unless we prompt you to do so.
3. Who we share your personal data with and why?
3.1 We may disclose your personal data to any member of the StatPro Group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as we determine it may be reasonably necessary for the purposes, and on the legal bases, set out in this policy.
3.2 We may disclose extracts of your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
3.3 We may disclose usage, profile, enquiry, and notification data to our suppliers or subcontractors identified at googleanalytics.com , www.hubspot.com , www.sumo.com and www.salesforce.com insofar as we determine it may be reasonably necessary for usage tracking, and customer relationship management purposes.
3.4 In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where we determine that such disclosure may be reasonably necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
4. International transfers of your personal data
4.1 In this Section 4, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).
4.2 We and our other StatPro Group companies have offices and data processing facilities in Canada and the United States. The European Commission has made an “adequacy decision” with respect to the data protection laws of Canada. Your personal data can therefore be transferred to Canada lawfully without the need for any additional safeguards, as the European Commission deems the data protection laws in Canada to adequately protect your personal data. Transfers to the United States require that appropriate safeguards are put in place, in order for the transfer to be lawful, namely via the use of standard data protection clauses approved by the European Commission and the UK Information Commissioner. We have adopted the standard EU data protection Model Clauses which are standardized contractual clauses used in agreements between service providers and their customers to ensure that any personal data that leaves the EEA will be transferred in compliance with EU data-protection law and meet the requirements of the EU Data Protection Directive 95/46/EC.
4.3 The hosting facilities for our website and StatPro Revolution services are situated in the United States and Canada, and therefore your personal data will be transferred to the United States and Canada and processed and stored there. As per Section 4.2, we have appropriate safeguards in place, in order to protect your personal data.
4.4 Our service providers include Hubspot.com, Sumo.com, and Google Analytics who are situated in the United States. Please see Section 4.2 for more information on the appropriate safeguards we use when transferring personal data to these service providers.
5. Retaining and deleting personal data
5.1 This Section 5 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
5.2 Personal data that we process for any purpose or purposes shall not be kept for longer than we determine is reasonably necessary for that purpose or those purposes.
5.3 We will retain your personal data as follows: Usage, profile (save for dietary and access requirements), enquiry (save for dietary and access requirements), and notification data for non-subscribers will be retained for a maximum period of 12 months. Dietary and access requirements, which form part of profile data and enquiry data, will be deleted shortly after events unless required to retain for legal or regulatory reasons following those events in which case it will be held for the relevant statutory record period or claims limitation period.
5.5 Notwithstanding the other provisions of this Section 5, we may retain your personal data where we determine such retention may be reasonably necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
6. Direct Marketing
6.1 We may use your personal data to market to you, in particular your profile and enquiry data, where you have provided your express consent. To view or update your preferences, click the “email preferences” link at the bottom of any of our emails or contact [email protected]
6.2 Our direct marketing may include information about:
(a) new product releases;
(b) event invitations;
(c) news and content; and
(d) blog notifications.
6.3 We may from time to time send you service communications (rather than direct marketing communications) providing information about the functionality of new releases, updates and fixes that are provided as part of the services subscribed for. These are provided in our legitimate interest of keeping you informed as a user of the services about changes made to the service subscribed to.
6.4 If you would like to receive direct marketing from us, please visit StatPro’s “subscribe” web page.
6.5 If you have previously asked to receive marketing communications and wish to opt out of doing so, please visit StatPro’s “unsubscribe” web page.
7. Amendments to this policy
7.1 We may update or amend this policy from time to time by publishing a new version on our website. This policy is available at statpro.com/privacy-policy
7.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
7.3 We may notify you of changes to this policy by email or through a notification pop up message when you visit the website.
8. Your rights
8.1 In this Section 8, we have summarised the rights that you have under the EU General Data Protection Regulation (GDPR). Not all of the rights listed in Section 8.2 below are engaged in all circumstances. On receipt of a rights request, we will assess whether the right you are seeking to exercise is engaged.
8.2 Your rights under EU General Data Protection Regulation are (note, as above, that not all of these rights are absolute):
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent, where we are relying on consent to process your personal data.
8.3 You have the right to ask us to confirm whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. Please email [email protected] with your request.
8.4 You have the right to have inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
8.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include where: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
8.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
8.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
8.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
8.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
8.10 To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
8.11 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
8.12 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
8.13 You may exercise any of your rights in relation to your personal data by email or written notice to us.
9. Our details
9.2 StatPro Group Plc is registered in England and Wales under registration number 02910629, and our registered office is at StatPro, Mansel Court, Mansel Road, Wimbledon, London, SW19 4AA.
9.3 Our principal place of business is at StatPro, Mansel Court, Mansel Road, Wimbledon, London SW19 4AA.
9.4 You can contact our data protection officer:
(a) by post, to the postal address given above;
(b) using our website contact us form;
(c) by telephone, on the contact number published on our website from time to time;
(d) or by email, using [email protected]statpro.com