Wiresmith Technology Privacy Policy

Updated: 26th April 2018

Introduction

When you use our services or access our website, you entrust us with your information. We take this obligation seriously, and this policy aims to be clear and transparent on what we collect and why. We will keep this policy as clear and concise as possible.

Data Controllers

The data controller for the data described here is Wiresmith Technology Ltd, Suite 14 Liberty House, Greenham Business Park, Thatcham, RG19 6HS. Through this document “we”, “us” and “our” refers to Wiresmith Technology Ltd.

You may contact us regarding any concerns through dataprotection@wiresmithtech.com.

Scope of Policy

This policy covers all personal data collected by Wiresmith Technology. The data is collected through three primary services:

Our main site – www.wiresmithtech.com
Our developer site – devs.wiresmithtech.com
Our business services.

This privacy policy covers personally identifiable data (PII) such as emails, IP addresses and names of individuals. Our service agreements cover protection of your commercial data.

Policy Changes

We will make changes to this policy as our business changes in the future to ensure you have up-to-date information on your data. These changes will be updated here

Data We Collect

Subscriber Information

When you sign up to receive emails from our sites, we collect your name and email that you provide on the subscription form. If you provide this information for other purposes, you must provide consent by selecting to receive emails from us. This is collected to provide email updates to you about services and details that may interest you.

Contact Information

When you sign up to receive emails from our sites, we collect your name and email that you provide on the subscription form.

If you provide this information for other purposes, you must provide consent by selecting to receive emails from us.

This is collected to provide email updates to you about services and details that may interest you.

Data Collection

We may collect your data in the following ways:

Source	Data Type	Basis for Collection
Web Subscription Forms	Subscriber Information	Consent
Web Resource Downloads	Subscriber Information	Consent
Customer Enquiry Form	Contact Information	Legitimate Interest
From Referral Partners	Contact Information	Legitimate Interest
Web Post Comments	Email, Name	Legitimate Interest

How We Use Your Data

Service Delivery

Contact information is used throughout our service delivery to work with you successfully. For example, providing contracts to sign, support access and deliverable access.

This use of data is necessary to our service. If you are unhappy with any purposes then you may provide a different contact at your company for us to complete the service.

Service Updates

Subscriber information and contact information is used to provide business updates such as new services, changes to existing services or availability.

Article and Informational Product Updates

Subscriber information is used to send you new articles or downloads we produce that we think may be of interest to you. Each of these will come with an unsubscribe link to opt-out of this.

Web SPAM and Abuse Protection

We host comments sections on our sites which need protecting from SPAM and abusive behaviour to provide you and others with a safe environment.

Web Analytics

Behavioural data is used to track user visits to the site to gauge how useful our content and website is to them. The analytics are aggregated and anonymised for analysis but can be traced to your IP address. You can block cookies to opt-out of this on the individual processors below.

Sales and Marketing Analytics

Behavioural data is used to track interest shown in different emails sent or promotional activities. We may review this data in aggregate or at an individual level.

We only track data where it is immediately useful to us to improve our activities. You can opt-out of this based on the individual processors below.

Data Processing

International Data Transfer

We utilise some 3rd party data processors as outlined below. To protect your privacy, we only work with providers who:

Hold and process your data inside the EEA or UK.
If there is not an option for inside the EEA, work with providers who are certified to hold EEA data under the EU-US Privacy Shield.

Providing Your Data To Others

We may need to provide your data to others in certain circumstances:

Contact information may be provided to our suppliers or subcontractors to provide you with our services. Data is only shared by us where it is necessary for us to provide our business services. You will be notified by email when this occurs.
Contact information may be provided to our insurers and professional advisors where it is necessary for us to obtain professional advice, manage risk or obtain and maintain insurance.
Any of your data may be provided to appropriate legal entities where it is necessary due to a legal obligation to which we are subject or when it can be considered in the vital interests of you or another natural person.
Subscriber information, contact information and behavioural data may be provided to our nominated data processors for different parts of our data usage. These are listed below in the 3rd Party Processors section.

3rd Party Processors

This section contains our current 3rd party processors and will be kept up to date as the business changes.

We vet each of our processors to the same standards as our confidential data, ensuring we are happy with the levels of protection and service they provide with your data.

Processor	Data	Processing Purpose	Processing Location
Active Campaign	Subscriber Information Contact Information Behavioural Data	Service Updates Article and Informational Product Updates Sales and Marketing Analytics	US (EU-US Privacy Shield)
Pipedrive	Contact Information	Service Delivery	EEA
Microsoft	Contact Information	Service Delivery	UK
Atlassian	Contact Information	Service Delivery	US (EU-US Privacy Shield)
Intuit	Contact Information	Service Delivery	US (EU-US Privacy Shield)

Data Retention

We have the following data retention policies for the different data items.

Information Type	Retention Policy	Basis for Time
Subscriber Information	1 Year from Unsubscribe	Access to subscription preferences system.
Contact Information	5 Years from service delivery completion or no contact.	Service records Potential future development.
Contact Information – Online Comment	Duration of Article	Required for comment to be present.
Behavioural Data - Sales and Marketing Analytics	5 Years	Tied to contact information.

Managing Your Data

You can control your data in 3 ways:

For subscriber data, see the bottom of our emails for links to unsubscribe or update your details.
To prevent the use of cookies for web analytics, see our cookie policy.
In all other instances, contact dataprotection@wiresmithtech.com

Your Rights To Your Data

You have specific rights under EU law about your data. These are:

The right to access;
The right to rectification;
The right to erasure;
The right to restrict processing;
The right to object to processing;
The right to data portability;
The right to complain to a supervisory authority; and
The right to withdraw consent.

Right to Access

You may request access to your data at any time by contacting us. We shall provide you will detail of all the personal data we hold related to you. The first copy shall be free of charge. Additional copies may be subject to a reasonable fee.

Right to Rectification

You may have your data corrected or completed at any time by contacting us with the new data to be included.

Right to Erasure

You have the right to request erasure of your personal data without undue delay. Examples of when your data can be erased are when the data is no longer needed for the purpose it was collected for, you withdraw consent or object to processing, or the data was collected or processed unlawfully.

We may not be able to delete your data if it is required for service delivery, compliance with a legal obligation or if it is subject to a legal claim. Where we are unable to delete your data immediately, we will work with you to identify options to remove as much as possible.

Right to Restrict Processing

You have a right to restrict the processing of your data when you don’t wish for it to be deleted. This has the same restrictions as the right to erasure, but we will provide the best solutions available to us.

Right to Data Portability

We will provide data in access requests in a machine-readable format that can be accepted by other vendors where desired.

Right to Complain to A Supervisory Authority

We are registered with the DPO in the UK. You have every right to make a complaint to them if we are unable to meet your rights. Please contact us first to remedy the situation.

You may withdraw consent at any time to consent-based processing.