Our contact details
Name: Darren Maw
Address: First Floor, Southgate Two, 321 Wilmslow Road, Cheadle, Cheshire SK8 3PW Phone Number: 03300 539347
Last Revised: 2 February 2020
Previous Version: 21 May 2020
This policy sets out what personal data we (10 to 3 Digital Limited) may collect and hold about you, why we do it, how we use it and how we retain it.
For the purposes of the Data Protection Act 2018, we act as both a Controller and a Processor, depending on the nature of the data that we hold and how we use it.
For instance, we act as a Controller in relation to data that we collect and process in relation to customers and suppliers, where we decide how to use this data in the conduct of our relationships with these individuals.
We act as a Processor in relation to data that we collect from clients where this is used to manage certain aspects of their subscriptions and licences. For instance, where a customer assigns each of its licences to an individual we hold some data in relation to those individuals to manage that.
The types of personal information we collect
We collect and process the following information:
- Personal identifiers, contacts and characteristics – for example, name and contact details, email address
- Organisation information – for example the name and details of an organisation to which you are associated, and your relationship with it
- Account information – for example, your username and password
- Billing and payment information – for all customers, whether you arrange payment for our services direct with us, or purchase and pay for any licences through our website
- Device and browser information – for example, information relating to your network, connection, device and browser identifiers Usage data – for example, information about how you use our website, products and services
- Marketing and Communications Data – includes your preferences in receiving marketing from us and your communication preferences.
- Social media and online data information – for example, your username and other information in online profiles and posts if you engage with us on social media
How we collect the personal information
Most of the personal information we process is provided to us directly by you, for instance if you:
- Purchase a licence to use some of our products
- Contact us by phone, email, social media or online message submission
- Apply for a job or position with us
In addition, we may collect information from other organisations, for instance:
- The organisation to which you are associated might provide us with some details about you in order for you to access our products under your organisation’s licence, for example your name and position within the organisation
- We have a sister business called Vista Employer Services Limited, which may from time to time share selected information with us
We also automatically collect information about you if you:
- Search for or visit our website and/or products
- Access, use or download content from us
- Open emails, or click in links contained in emails, or advertisements from us
How we store the personal information
All information you provide to us is stored on secure servers. All reasonable and appropriate technical and organisational measures are taken to prevent unauthorised or unlawful processing of personal data and against accidental loss, destruction or damage to personal data.
We will ensure that:
- Only authorised people will be able to access, alter, disclose or destroy personal data
- Those people only act within the scope of their authority
- If personal data is accidentally lost, altered or destroyed, it can be recovered to prevent any damage or distress to the individuals concerned
- As and when appropriate, we will conduct information risk assessments to ensure data is protected to a reasonable and appropriate standard for the nature of the data held
The lawful basis for collecting and using the personal information
Under the General Data Protection Regulations (GDPR), the lawful bases we rely on for processing this information are:
- We need to process your personal data so that we can perform our contractual obligations to you
- We have obtained your consent for marketing activities. Please see below for more information on marketing We need to process your personal data in order to comply with our legal and regulatory obligations
- The use of your personal data is necessary for our legitimate interests, for example to:
- allow us to manage and administer the operation of our business effectively and efficiently maintain compliance with internal policies and procedures
- monitor the use of our copyrighted materials
- establish, exercise or defend our legal rights or for the purpose of legal proceedings enable quick and easy access to information on our products, content and services
How we use the personal information
We use the information that we hold in connection with our services and business purposes, for example to:
- Provide, analyse and administer our services and products
- Conduct internal research and development for new content, products, and services, and to improve, test, and enhance the features and functions of our current services
- Process transactions related to our Services and administer accounts or profiles related to you or your organisation Personalise and make recommendations related to our services and other offerings
- Contact and communicate with you in connection with our services or other notifications, programs, events, or updates that you may have registered for
- Send you offers, advertising, and marketing materials, including to provide personalised advertising to you Conduct and communicate with you regarding recruiting and human resources administration
- Comply with your instructions or to fulfil other, specified purposes for which you have given your consent
- Detect and prevent fraud and abuse to ensure the security and protection of all customers and others, as well as to identify and authenticate your access to our services or to identify and authenticate you before we provide you with certain information
We may share this information with other organisations in certain circumstances, for example:
- Where we have a legal obligation to do so
- In order to protect the rights, property or safety of 10 to 3 Digital Limited, its staff and customers. This might include sharing information with the Police, regulatory bodies or legal advisors
- In order to enforce our terms and conditions and legal rights
- Where we need to liaise with our insurers, for instance about a claim or the terms of an insurance policy
From time to time we would like to contact you about other products, services and information that may be of interest to you. We will seek your consent before doing so. You have the right to withdraw your consent for marketing contact at any time. Should you wish to withdraw your consent, we include an unsubscribe option at the bottom of all our emails.
You can prevent the setting of cookies by adjusting the settings on your browser (see your browser Help for how to do this). Be aware that disabling cookies will affect the functionality of our and many other websites that you visit. Disabling cookies will usually result in also disabling certain functionality and features of our website.
Our website uses Google Analytics which is one of the most widespread and trusted analytics solutions on the web for helping us to understand how you use the site and ways that we can improve your experience. We also use Ontraport, which tracks activity on our website. These cookies may track things such as how long you spend on the site and the pages that you visit so we can improve our products, service and website.
Links to other websites
How long we keep the personal information
We will hold your personal information on our systems for as long as is necessary to:
- Fulfil the purposes described in this policy
- Comply with legal obligations – for example, finance, taxation or money laundering
- Meet the timelines determined or recommended by regulators, professional bodies, or associations Fulfil any specific requirement or agreement set out in any relevant contract you hold with us
Your data protection rights
Under data protection law, you have rights including:
- Your right of access – You have the right to ask us for copies of your personal information
- Your right to rectification – You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete
- Your right to erasure – You have the right to ask us to erase your personal information in certain circumstances
- Your right to restriction of processing – You have the right to ask us to restrict the processing of your personal information in certain circumstances
- Your right to object to processing – You have the right to object to the processing of your personal information in certain circumstances
- Your right to data portability – You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances
You can find out a lot more information in relation to these rights by contacting or visiting the website of the Information Commission’s Office (the ICO). See the information set out below for contact and website details.
You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you. Please contact us using the details set out at the top of this policy if you wish to make a request.
How to complain
If you have any concerns about our use of your personal information, you can make a complaint to us. Please see the information at the beginning of this policy for how to contact us.
You can also complain to the ICO if you are unhappy with how we have used your data. The ICO’s address is:
Information Commissioner’s Office
Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk