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
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:
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Cookie |
means a small text file that |
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Personal |
means any data which relates |
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Privacy |
means this website privacy |
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Savvney |
means the training courses, |
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Savvney |
means the Savvney website at www.savvney.com including all content and |
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Savvney, |
means Savvney C.I.C.. |
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User(s) |
means the visitors and/or |
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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.
9.1
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.
10.1 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.
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
11.1
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.