GOSPEL TECHNOLOGY LIMITED – WEBSITE PRIVACY POLICY

 

What is this?

Gospel Technology Limited (Gospel/we/us/our) is committed to protecting and respecting your privacy.

This policy sets out the basis on which any personal information we collect from you, or that you provide to us, will be processed by us or our group companies. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting http://gospel.tech/ you are accepting and consenting to the practices described in this policy.

This policy was last updated on 10/8/2018. Please see Changes to our privacy policy for more information.

 

Who we are

We are Gospel Technology Limited whose registered address is 33 Cavendish Square, London, England, W1G 0PW (company number: 10514646). We are the data controller in relation to the processing activities described below, save for where stated otherwise. This means that we decide why and how your personal information is processed.

 

Information we collect from you

When you use this website, our products or services, we may collect and process the following categories of information about you:

Personal information you give to us. You may give us information about you voluntarily by filling in forms on our site (https://gospel.tech/contact), providing it at the time of subscribing to the services we provide through our site, posting material or requesting further services, managing your account online or by corresponding with us by phone, e-mail (via our [email protected] address) or otherwise. The information you give us may include your name, address, e-mail address and phone number, area of interest, the name of your organisation/company, your business card and, any other information you include in correspondence with us. We may also ask you for information when you report a problem with our site.

Personal information we collect about you. With regard to each of your visits to our site we may collect the following information (automatically or otherwise):

* anonymous data collected by the hosting server for statistical and analytical purposes;

* technical information, including the Internet protocol (IP) address used to connect your computer to the Internet; and

* information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), page response times, page interaction information (such as scrolling, clicks, and mouse-overs) and methods used to browse away from the page.

Please see Cookies & other technologies for further information. We may also collect any personal information which you allow to be shared that is part of your public profile or third party social network, type and version, time zone setting, browser plug-in types and versions, operating system and platform.

Personal information we may receive from other sources:

We may obtain certain personal information about you from sources outside of our business which may include our group companies or other third party companies. The personal information received is as described in the two paragraphs above. The third parties that may send us personal information about you are as follows:

 

Uses made of the information

The purposes for which we use your information and the legal basis under data protection laws on which we rely to do this are explained below.

Where you have provided consent. We will use your personal information:

* to provide you with information about other services we offer that are similar to those that you have already used or enquired about; and / or

* to make suggestions and recommendations to you and other users of our site about goods and services that may interest you or them; and / or

*  to qualify you as a lead contact.

You may withdraw your consent for us to use your information in any of these ways at any time. Please see Withdrawing your consent for further details.

Where it is in your vital interest. We will use your personal information to:

* contact you (where we have supplied you with any products) where we reasonably believe that the processing of your personal information will prevent or reduce any potential harm to you. It is in your vital interests for us to use your personal information in this way.

Where there is a legitimate interest. We may use and process your personal information where it is necessary for us to pursue our legitimate interests as a business, or that of a third party, for the following purposes:

* to correspond or communicate with you for our legitimate interest of ensuring that we are providing you with the necessary support and to improve our services, including to notify you about any changes to our service;

* to improve our site to ensure that content is presented in the most effective manner for you and for your computer for our legitimate interest of ensuring that we are offering relevant services based on users’ needs;

* to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes (primarily through Google Analytics – see below) for our legitimate interest of ensuring that our website runs smoothly and in the best possible way for users;

* to allow you to participate in interactive features of our service, when you choose to do so, for our legitimate experience of ensuring a seamless user experience where users choose to use interactive features of our site;

* to verify the accuracy of data that we hold about you and create a better understanding of you as a customer for our legitimate interest of ensuring that all information held is up to date;

* for network and information security in order for us to take steps to protect your information against loss or damage, theft or unauthorised access and to operate our website securely;

* for the management of queries, complaints, or claims for our legitimate interest of ensuring that we are providing you with the necessary support and to improve our services; and

* for the establishment and defence of any legal claims for our legitimate interest of ensuring that our business interests are protected.

Where there is a legal requirement. We will use your personal information to comply with our legal obligations:

* to assist The Information Commissioners Office or other public authority or criminal investigation body where we are legally obliged to provide such assistance;

* for the prevention of fraud and other criminal activities;

* to comply with a request from you in connection with the exercise of your rights (for example where you have asked us not to contact you for marketing purposes, we will keep a record of this on our suppression lists in order to be able to comply with your request);

* to identify you when you contact us; and/or

* to verify the accuracy of data we hold about you.

Where it is required to create, perform or complete a contract. We may use and process your personal information where:

* we have supplied you (or continue to supply you) with any products or services;

* we have arranged for the supply of another company’s products or services to you; or

* where you are in discussions with us about any new product or service.

We will use this information in connection with the contract for the supply of products or services when it is needed to carry out that contract with you or for you to enter into it. Please see Information we collect from you above for details of the types of personal information we process for these purposes.

 

Data anonymisation and use of aggregated information

Your information may be converted into statistical or aggregated data in such a way as to ensure that you are not identified or identifiable from it. Aggregated data cannot be linked back to you as a natural person. We may use this data for analytical and research purposes.

 

Disclosure of your information

Group companies. We may share your information with the other company in our group, Bedrock Capital Limited (10470485). They may use your personal information in the ways set out in Uses made of the information, in connection with the products and/or services that complement our own range of products and/or services. Where information is shared or transferred to Bedrock Capital Limited, appropriate technical and organisational security measures will be put in place.

Our suppliers and service providers. We may disclose your information to our business partners, suppliers and sub-contractors, third party service providers, agents, subcontractors and other organisations for the purposes of providing services to us or directly to you on our behalf. Such third parties may include:

* cloud service providers (such as Dropbox – based in the US – who provide us with cloud storage solutions – https://www.dropbox.com/privacy);

* customer relationship management providers (such as Salesforce – based in Germany and France – who provide us with CRM solutions – https://www.salesforce.com/uk/company/privacy/);

* administrative service providers;

* technical support agents;

* network providers;

* installers or IT service providers; and

* other third parties who provide services to us.

Most of these third parties are located in the European Economic Area (EEA) (meaning, the 27 EU member states, the UK, Norway, Iceland and Liechtenstein) however some may be based elsewhere. For further information as to our suppliers and service providers are based and where your personal information may be stored, please see Where we store your personal information.

When we use third party service providers, we only disclose to them any personal information that is necessary for them to provide their service and we have a contract in place that requires them to keep your information secure and not to use it other than in accordance with our specific instructions.

Third parties who provide products and services. In processing your order and/or handling your account, we may send your details to, and also use information received from fraud prevention agencies. Other than as stated above, we do not share any personal information collected through our website with any third parties. Should this position change, we will make clear what third parties any personal information is shared with and for what purpose(s).

Other ways we may share your personal information. We may transfer your personal information to any third party in connection with a sale of some or all of our business and assets to any third party or as part of any business restructuring or reorganisation. We may also transfer your personal information if we’re under a duty to disclose or share it in order to comply with any legal obligation, to detect or report a crime, to enforce or apply the terms of our contracts or to protect the rights, property or safety of our visitors and customers. We will always take steps with the aim of ensuring that your privacy rights continue to be protected.

 

Where we store your personal information

All information you provide to us or Bedrock Capital Limited may be transferred to countries outside the EEA. By way of example, this may happen if any of our servers or those of our third party service providers are from time to time located in a country outside of the EEA. These countries may not have similar data protection laws to the UK and EU.

Where we transfer your personal information to, or store it in, countries located outside of the EEA in this way, we will take steps to ensure that appropriate security measures are taken with the aim of ensuring that your privacy rights continue to be protected as outlined in this policy. These steps include imposing contractual obligations on the recipient of your personal information or ensuring that the recipients are subscribed to ‘international frameworks’ (such as the US Privacy Shield arrangement or are subject to an adequacy decision by the EU Commission) that aim to ensure adequate protection. Please contact us using the details at the end of this policy for more information about the protections that we put in place.

In particular, some or all of the personal information may be transferred to or stored on Dropbox‘s secure servers in the US – being subject to the US Privacy Shield regime.

When we receive information in relation to job applications via email or otherwise, this information is stored in accordance with our Applicant Data Privacy Notice a copy which can be provided on request from the contact at the end of this policy.

If you use our services whilst you are outside the EEA, your information may be transferred outside the EEA in order to provide you with those services.

 

How long we keep your personal information for

If we collect your personal information, the length of time we retain it is determined by a number of factors including the purpose for which we use that information and our obligations under other laws. We do not retain personal information in an identifiable format for longer than is necessary.

Where personal information is transferred to one of our suppliers, service providers or any other third party, it will be retained in line with that organisation’s privacy policy (see link to Dropbox’s privacy policy above).

We retain your personal information as follows:

The only exceptions to the periods mentioned above are where:

* the law requires us to hold your personal information for a longer period, or delete it sooner;

* you exercise your right to have the information erased (where it applies) and we do not need to hold it in connection with any of the reasons permitted or required under the law (see further Erasing your personal information or restricting its processing below);

* we bring or defend a legal claim or other proceedings during the period we retain your personal information, in which case we will retain your personal information until those proceedings have concluded and no further appeals are possible; or

* in limited cases, the law permits us to keep your personal information indefinitely provided we put certain protections in place.

 

Security & links to other sites

All information provided to us is stored on secure servers. In spite of this, unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your information transmitted to our website and any transmission is at your own risk. Once we have received your personal information, we put in place reasonable and appropriate controls to ensure that it remains secure against accidental or unlawful destruction, loss, alteration, or unauthorised access.

Where we have given (or where you have chosen) a password which enables you to access an account, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Our website contains hyperlinks to other websites owned and operated by third parties, who have their own privacy policies. When you click on a hyperlink and are redirected to a third party website, the use of your personal information is then governed by that third party, even though you may have entered the website through hyperlinks on our own website. We do not assume any responsibility or liability for the use of your personal information when on a third party website and the use of these websites is at your own risk.

 

Cookies & other technologies

The only information we gather is aggregated and anonymised for analytics purposes (through Google Analytics) such as registering visitor trends allowing us to optimize user experience and ensure visitors can successfully dissimilate our website information.

Currently, we do not use cookies on our website. ‘Cookies’ are small pieces of information sent to your computer or device and stored on its hard drive to allow our websites to recognise you when you visit. Should this change, this policy shall be updated accordingly.

 

Marketing

We may collect your preferences to receive marketing information from us about our products and services in the following ways:

* when you indicate that you would like to receive such marketing from us; or

* when you refresh your marketing preferences when responding to a request from us to do so from time to time.

The way we communicate with you will depend on what method(s) you selected at the time of opting in to our marketing communications.

You have the right to withdraw your consent (opt out) at any time to our use of your personal information for marketing purposes. Please see Withdrawing your consent below for further details on how you can do this.

We do not share personal information for marketing purposes with third parties.

We do not make automated decisions about you based on your personal information.

 

 

You have a number of rights in relation to your personal information under data protection laws. In relation to certain rights, we may ask you for information to confirm your identity and, where applicable, to help us to search for your personal information. Except in rare cases, we will respond to you within one month from either (i) the date that we have confirmed your identity or (ii) where we do not need to do this because we already have this information, from the date we received your request.

Accessing your personal information. You have the right to ask for a copy of the information that we hold about you by emailing or writing to us at the address at the end of this policy. We may not provide you with a copy of your personal information if this concerns other individuals or we have another lawful reason to withhold that information.

Correcting and updating your personal information. The accuracy of your information is important to us and we are working on ways to make it easier for you to review and correct the information that we hold about you. In the meantime, if you change your name or address/email address, or you discover that any of the other information we hold is inaccurate or out of date, please let us know by contacting us in any of the details described at the end of this policy.

Withdrawing your consent. Where we rely on your consent as the legal basis for processing your personal information, as set out under Uses made of the information, you may withdraw your consent at any time by contacting us using the details at the end of this policy. If you would like to withdraw your consent to receiving any direct marketing to which you previously opted-in, you can do so using our unsubscribe tool. If you withdraw your consent, our use of your personal information before you withdraw is still lawful.

Objecting to our use of your personal information and automated decisions made about you. Where we rely on your legitimate business interests as the legal basis for processing your personal information for any purpose(s), as out under Uses made of the information, you may object to us using your personal information for these purposes by emailing or writing to us at the address at the end of this policy. Except for the purposes for which we are sure we can continue to process your personal information, we will temporarily stop processing your personal information in line with your objection until we have investigated the matter. If we agree that your objection is justified in accordance with your rights under data protection laws, we will permanently stop using your data for those purposes. Otherwise we will provide you with our justification as to why we need to continue using your data.

You may object to us using your personal information for direct marketing purposes and we will automatically comply with your request. If you would like to do so, please email [[email protected]] expressing this. You may also contest a decision made about you based on automated processing by emailing the same address.

Erasing your personal information or restricting its processing. In certain circumstances, you may ask for your personal information to be removed from our systems by emailing or writing to us at the address at the end of this policy. Unless there is a reason that the law allows us to use your personal information for longer, we will make reasonable efforts to comply with your request.

You may also ask us to restrict processing your personal information where you believe it is unlawful for us to do so, you have objected to its use and our investigation is pending or you require us to keep it in connection with legal proceedings. In these situations we may only process your personal information whilst its processing is restricted if we have your consent or are legally permitted to do so, for example for storage purposes, to protect the rights of another individual or company or in connection with legal proceedings.

Transferring your personal information in a structured data file. Where we rely on your consent as the legal basis for processing your personal information or need to process it in connection with your contract, as set out under Uses made of the information, you may ask us to provide you with a copy of that information in a structured data file. We will provide this to you electronically in a structured, commonly used and machine readable form.

You can ask us to send your personal information directly to another service provider, and we will do so if this is technically possible. We may not provide you with a copy of your personal information if this concerns other individuals or we have another lawful reason to withhold that information.

Complaining to the UK data protection regulator. You have the right to complain to the Information Commissioner’s Office if you are concerned about the way we have processed your personal information. Please visit www.ico.org.uk for further details.

 

Changes to our website privacy policy

We may review this policy from time to time and any changes will be notified to you by posting an updated version on our website and/or by contacting you by email where appropriate. We recommend you regularly check for changes and review this policy whenever you visit our website. If you do not agree with any aspect of the updated policy you must immediately notify us and cease using our services.

 

Contact us

If you have any queries about this policy or about the way we process your personal information please contact us using the contact details below.

If you wish to write to us, please write to the address given at the start of this policy.

Our email address for data protection queries is [email protected].

If you would prefer to speak to us by phone, please call +44 20 7969 1459.

 

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