Privacy Policy

PRIVACY POLICY

Website Privacy Notice

 

This Privacy Notice explains how we use the personal information that Savvney collects or generates both in relation to the Savvney Website (www.savvney.com) and Savvney Products.

The list below sets out what is covered in this Privacy Notice and you can click on the headings below to go to a specific section.

 

1.     BACKGROUND

2.     THE PRODUCTS AND SERVICES WE PROVIDE

3.     THE TYPES OF PERSONAL DATA WE COLLECT

4.     HOW WE USE YOUR INFORMATION

5.     DISCLOSURE OF YOUR INFORMATION TO THIRD PARTIES

6.     INTERNATIONAL TRANSFERS OF PERSONAL DATA

7.     HOW WE SAFEGUARD YOUR INFORMATION

8.     HOW LONG WE KEEP YOUR PERSONAL DATA

9.     YOUR RIGHTS

10.  COOKIES

11.  DESIGNATED REPRESENTATIVE

12.  QUESTIONS AND CONCERNS

 


 

1.             BACKGROUND

1.1          Savvney C.I.C. with its registered office at 40 Occam Road, Surrey Research Park, Guildford, Surrey, England, GU2 7YG and with company number 08577066, and other companies in the Savvney group collect and use certain Personal Data. Savvney is responsible for ensuring that it uses that Personal Data in compliance with data protection laws, including (but not limited to) the General Data Protection Regulation (EU) 2016/679 and any other national, implementing or supplementing Data Protection Legislation including but not limited to the Data Protection Act 2018.

1.2          At Savvney we respect the privacy of our clients and we are committed to keeping all your Personal Data secure. This Privacy Notice governs the handling of Personal Data by Savvney in the course of carrying on commercial activities.

1.3          We use the following definitions in this Privacy Notice:

Cookie

means a small text file that includes a small quantity of information sent to the browser of Users, by a web server, and stored on the hard disk drive of a computer for purposes of archiving, collecting navigation data for statistical analysis purposes, and offering Users services related to their interests or location.

Personal Data

means any data which relates to a living individual who can be identified from that data or from that data and other information which is in the possession of, or is likely to come into the possession of, Savvney (or its representatives or service providers). In addition to factual information, it includes any expression of opinion about an individual and any indication of the intentions of Savvney or any other person in respect of an individual.

Privacy Notice

means this website privacy notice.

 

 

Savvney Products

means the training courses, materials and content available on and via the Savvney Website.

Savvney Website

means the Savvney website at www.savvney.com including all content and materials making up that website plus the Savvney Products.

 

 

 

 

Savvney, we or us

means Savvney C.I.C..

User(s) or You

means the visitors and/or users of the Savvney Website.


 

2.             THE PRODUCTS AND SERVICES WE PROVIDE

2.1          This Privacy Notice concerns the following information that we collect about you:

 

(A)           Information we receive through the Savvney Website; and

(B)           Information we receive through the offering and provision of the Savvney Products.

3.             THE TYPES OF PERSONAL DATA WE COLLECT

3.1           Many of the Savvney Products require us to obtain Personal Data about you in order to provide the Savvney Products  to you. Users may be unable to access the Savvney Website if such Personal Data is not provided. In relation to the Savvney Website and the Savvney Products, we will collect and process the following Personal Data about you:

      Information that you provide to Savvney. This includes information about you that you provide to us. The nature of the requests you make or Savvney Products you are interested in will determine the kind of Personal Data we might ask for, though such information may include (by way of a non-exhaustive list):

 

-       basic Personal Data (such as first name; family name; title; profession; position in the company; company name; email address; phone number; address; city; postcode; country; date of birth; gender);

-       any information that you choose to share on the Savvney Website or our social media channels which may be considered Personal Data; and

-       any financial information you share when making payments through the Savvney Website or otherwise.

 

      Information that we collect or generate about you. This includes (by way of non-exhaustive list):

-       any information regarding the Savvney Products purchased and/or accessed via the Savvney Website, and our interactions with you;

-       a file with your contact history to be used for enquiry purposes so that we may ensure that you are satisfied with the Savvney Products which we have provided to you; and

-       through our security services, traffic and security reports that include information on the internet usage of Users (e.g. what websites were visited by each User, IP address, any documents downloaded, security incidents, prevention measures taken by the gateway, the dates, times and frequency of visits to the Savvney Website, etc.).

 

      Information we obtain from other sources. This includes the Personal Data provided to us by third-party service providers, agencies or other publicly available sources where applicable. This includes Personal Data provided by (by way of non-exhaustive list):

 

-       www.TWiCECampaign.org; and

-       local councils / local authorities.

 

      Cookies

-       When you visit the Savvney Website, Cookies are used to collect technical information about your use of the Savvney Website and/or Savvney Products, and how you use them.

-       For more information on the Cookies used by Savvney please see Section ‎10 of this Privacy Notice.

 

 

4.             HOW WE USE YOUR INFORMATION

4.1          Your Personal Data may be stored and processed by us in the following ways and for the following purposes:

      for ongoing review and improvement of the information provided on the Savvney Website to ensure it is user friendly and to prevent any potential disruptions or cyber attacks;

      to allow you to use and access the functionality provided by the Savvney Products;

      to assess your request to buy access to any Savvney Products, where applicable;

      to set up customers to use the Savvney Products;

      to conduct analysis required to detect malicious code or data and understand how this may affect our IT system;

      for statistical monitoring and analysis of current attacks on devices and systems and for the on-going adaptation of the solutions provided to secure devices and systems against current attacks;

      to understand feedback on the Savvney Products and to help provide more information on the use of those products quickly and easily;

      to communicate with you in order to provide you with services or information about Savvney and the Savvney Products;

      for in-depth threat analysis;

      to understand your needs and interests;

      for the management and administration of our business;

      in order to comply with and in order to assess compliance with applicable laws, rules and regulations, and internal policies and procedures;

      for the administration and maintenance of databases storing Personal Data;

      internal record keeping; and/or

      transmission by email of marketing materials that may be of interest to you.

 

4.2          However we use Personal Data, we make sure that the usage complies with law applicable to us, and the law allows us and requires us to use Personal Data for a variety of reasons. These include:

      we need to do so in order to perform contractual obligations with our customers and third-party providers;

      we have obtained your consent;

      we have legal and regulatory obligations that we have to discharge;

      we may need to do so in order to establish, exercise or defend our legal rights or for the purpose of legal proceedings;

      the use of your Personal Data as described is necessary for our legitimate business interests, such as:

-       allowing us to effectively and efficiently manage and administer the operation of our business;

-       maintaining compliance with internal policies and procedures;

-       monitoring the use of our copyrighted materials; and

-       enabling quick and easy access to information on the Savvney Products.

 

4.3          We will take steps to ensure that the Personal Data is accessed only by employees of Savvney that have a need to do so for the purposes described in this Privacy Notice.

5.             DISCLOSURE OF YOUR INFORMATION TO THIRD PARTIES

5.1          We may share your Personal Data within the Savvney group of companies for the purposes described above. We will take steps to ensure that access to Personal Data is restricted to Savvney employees who have a legitimate interest in the purposes described in this Privacy Notice.

5.2          We may also share your Personal Data outside of the Savvney group for the following purposes:

      with our business partners. Personal Data will only be transferred to a business partner who is contractually obliged to comply with appropriate data protection obligations and the relevant privacy and confidentiality legislation;

      with third party agents and contractors for the purposes of providing services to us (for example, Savvney's accountants, professional advisors, IT and communications providers and debt collectors). These third parties will be subject to appropriate data protection obligations and they will only use your Personal Data as described in this Privacy Notice;

      to the extent required by law, for example if we are under a duty to disclose your Personal Data in order to comply with any legal obligation (including, without limitation, in order to comply with tax reporting requirements and disclosures to regulators), or to establish, exercise or defend our legal rights;

      if we sell our business or assets, in which case we may need to disclose your Personal Data to the prospective buyer for due diligence purposes; and

      if we are acquired by a third party, in which case the Personal Data held by us about you will be disclosed to the third party buyer.

6.             INTERNATIONAL TRANSFERS OF PERSONAL DATA

6.1          Where we transfer your Personal Data to another country outside the European Economic Area ("EEA"), we will ensure that it is protected and transferred in a manner consistent with legal requirements. In relation to data being transferred outside the EEA, for example, this may be done in one of the following ways:

      the country that we send the data to might be approved by the European Commission as offering an adequate level of protection for Personal Data;

      the recipient might have signed up to a contract based on "model contractual clauses" approved by the European Commission, obliging them to protect your Personal Data;

      the recipient may have adhered to binding corporate rules (only for intragroup transfers); or

      in other circumstances the law applicable to us may permit us to otherwise transfer your Personal Data outside Europe.

6.2          You can obtain more details of the protection given to your Personal Data when it is transferred outside the EEA (including a copy of the “model contractual clauses” which we have entered into with recipients of your Personal Data) by contacting us as described in Section ‎12 below.

7.             HOW WE SAFEGUARD YOUR INFORMATION

7.1          We have extensive controls in place to maintain the security of our information and information systems. Client files are protected with safeguards according to the sensitivity of the relevant information. Appropriate controls (such as restricted access) are placed on our computer systems. Physical access to areas where Personal Data is gathered, processed or stored is limited to authorised employees.

7.2          As a condition of employment, Savvney employees are required to follow all applicable laws and regulations, including in relation to data protection law. Access to sensitive Personal Data is limited to those employees who need access to it to perform their roles. Unauthorised use or disclosure of confidential client information by a Savvney employee is prohibited and may result in disciplinary measures.

7.3          When you contact a Savvney employee about your usage or other details about you that Savvney has, you may be asked for some Personal Data. This type of safeguard is designed to ensure that only you, or someone authorised by you, has access to such data.

8.             HOW LONG WE KEEP YOUR PERSONAL DATA

8.1          How long we will hold your Personal Data for will vary and will be determined by the following cumulative criteria:

      the purpose for which we are using it – Savvney will need to keep your Personal Data for as long as is necessary for that purpose; and

      legal obligations – laws or regulation may set a minimum period for which Savvney has to keep your Personal Data.

9.             YOUR RIGHTS

9.1          In all the above cases in which we collect, use or store your Personal Data, you may have the following rights which you can exercise free of charge. These rights include:

      the right to obtain information regarding the processing of your Personal Data and access to the Personal Data which we hold about you;

      the right to withdraw your consent to the processing of your Personal Data at any time. Please note, however, that we may still be entitled to process your Personal Data if we have another legitimate reason for doing so. For example, we may need to retain Personal Data to comply with a legal obligation;

      in some circumstances, the right to receive some Personal Data in a structured, commonly used and machine-readable format and/or request that we transmit those data to a third party where this is technically feasible. Please note that this right only applies to Personal Data which you have provided directly to Savvney;

      the right to request that we rectify your Personal Data if it is inaccurate or incomplete;

      the right to request that we erase your Personal Data in certain circumstances. Please note that there may be circumstances where you ask us to erase your Personal Data, but we are legally entitled to retain it;

      the right to object to, or request that we restrict, our processing of your Personal Data in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your Personal Data but we are legally entitled to refuse that request; and

      the right to lodge a complaint with the relevant data protection regulator if you think that any of your rights have been infringed by us.

9.2          You can exercise your rights by contacting us using the details listed in Section ‎12 below.

9.3          Further information about your rights may be obtained by contacting the supervisory data protection authority located in your jurisdiction. This is the Information Commissioner's Office (ICO). The ICO's contact details can be found on their website at ico.org.uk.

10.             COOKIES

10.1     This section on Cookies and the consent that you gave for the use of Cookies apply specifically to each use of Savvney Website www.savvney.com. You gave your consent to the use of Cookies in the cookie banner as described in the Cookie banner and this section.

Savvney tries to keep the information on the Cookies up-to-date but insists on the fact that the information is always a snapshot. Due to the constant innovation of the website, the non-static character of the internet and the third parties involved in the use of Cookies, it is possible that all Cookies and information are not available here.

            To the extent that we collect Personal Data with the help of Cookies, we will process them in accordance with this Privacy Notice.

10.2       Types of Cookies and purposes

            Cookies used on the Savvney Website are used to record information necessary for the proper provision and functioning of the Savvney Website and the Savvney Products, audience measurement, use monitoring and security.

            Cookies are placed by Savvney and, if applicable, its business partners, third party agents and contractors (without Savvney being held responsible for the placement of Cookies by its partners, third party agents and contractors).

            Each time a User is identified on the Savvney Website, a Cookie is placed allowing to identify the computer or hardware used and the User navigating the Savvney Website. This Cookie allows services to be provided seamlessly and therefore without re-identification. This Cookie is invalidated when the browser is closed or after a period of inactivity on the Savvney Website.

10.3          Analytical/performance Cookies

These Cookies are used to analyse how Users use the Savvney Website and ascertain the most popular Savvney Products.

These are used to recognise you when you return to the Savvney Website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

10.4          Functional Cookies

Used to analyse traffic patterns.

10.5          You can choose to enable or disable Cookies in your internet browser. By default, most internet browsers accept Cookies, but this can be changed. Further details can be found from the help section in your internet browser.

10.6          You can choose to delete Cookies at any time. However, you may lose any information that enables you to access the Savvney Website more quickly and efficiently, including, but not limited to personalisation settings.

10.7          It is recommended that you ensure that your internet browser is up to date and that you consult the help and guidance provided by the developer of your internet browser, if you are unsure about adjusting your privacy settings.

            DESIGNATED REPRESENTATIVE

10.8          Savvney's registered office may be contacted using the following contact information

Address:                      40 Occam Road, Surrey Research Park, Guildford, Surrey, England, GU2 7YG

            Email Address:           hello@savvney.com

 

10.9          Savvney's designated representative in the UK may be contacted using the following contact information:

Address:                      40 Occam Road, Surrey Research Park, Guildford, Surrey, England, GU2 7YG

            Email Address:           hello@savvney.com

 

11.             QUESTIONS AND CONCERNS

11.1          For further information regarding the processing of your Personal Data by Savvney, this Privacy Notice, questions relating to consent, or in order to exercise the rights mentioned above, please contact our data protection officer using the following contact details:

Address:                      40 Occam Road, Surrey Research Park, Guildford, Surrey, England, GU2 7YG

            Email Address:           hello@savvney.com

 

We are usually able to resolve privacy questions or concerns promptly and effectively. If you are not satisfied with the response you receive from us, you may escalate concerns to the applicable privacy regulator in your jurisdiction. Upon request, we will provide you with the contact information for that regulator.