This Privacy Policy tells you about the information we collect from you. In collecting this information, we are acting as a data controller and, by law, we are required to provide you with information about us, about why and how we use your data, and about the rights you have over your data.

Who are we?

We are Locogen Limited. Our address is Mitchell House, 5 Mitchell Street, Edinburgh, EH6 7BD. You can contact us by post at the above address, by email at info@locogen.com or by telephone on 0131 555 4745.

We are not required to have a data protection officer, so any enquiries about our use of your personal data should be addressed to the contact details above.

What information do we collect?

Personal data that we collect in relation to you (but is not limited to):

  1. Identity Data includes first name, last name, title and date of birth.
  2. Contact Data includes residential address, email address and telephone numbers.
  3. Financial Data includes bank account details.
  4. Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.

How do we collect your personal data?

We use different methods to collect data from and about you including (but not limited to):

When you contact us by telephone or e-mail

If you contact us (by telephone or email) we will collect your personal data and process it in accordance with the legal basis for processing your personal data outlined later in the policy. This may include discussing matters with you in relation to an enquiry about our services or a contract that we may enter into with you.

When you submit an enquiry via our website

If you submit an enquiry via our website, we collect your personal data and use this information to respond to your query, including providing you with any requested information about our products and services. We may also email you several times after your enquiry in order to follow up on your interest and ensure that we have answered it to your satisfaction. Your enquiry is stored and processed as an email which is hosted by Microsoft within the European Economic Area (EEA). It will also be logged on our CRM system on a cloud server based in Frankfurt, Germany.

Cookies

When you use our website to browse our products and services and view the information we make available, a number of cookies are used by us to allow the website to function, to collect useful information about visitors and to help to make your user experience better. A cookie is a text-only string of information that a website transfers to the cookie file of the browser on your computer's hard disk so that the website can remember who you are. A cookie will typically contain the name of the domain from which the cookie has come, the "lifetime" of the cookie, and a value, usually a randomly generated unique number.

You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

Cookie Table

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.

When you submit a CV for a vacancy listed on our website

If you submit your CV for a job vacancy listed on our website, we will collect your personal data to process your application which will include but is not limited to the following activities:

  • assess your suitability for the vacant position based on your skills and experiences;
  • contact you to invite you for interview; and
  • contact you if your application has been unsuccessful.

Your personal data will be stored on our company server and retained as outlined later in this Policy.

How we will use your information

We will only process your personal data if we have a legal basis for doing so, as outlined in this Policy or as notified to you at the time we collect your personal data, and for the purposes for which it was collected for, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you prior to commencing that processing and we will explain the legal basis which allows us to do this. Please note that we may process your personal data without your knowledge or consent, where this is required or permitted by law.

Lawful basis for processing

We are not allowed to process your personal data unless we have a legal basis for doing so.

There are four main legal bases that we rely on when it comes to processing someone’s personal data. These are:

(1) “Legitimate interest” – this is where we need to process your personal data, for example, if we need to contact you because you have raised a general query with us or where we are in contact with you about this or similar issues. We may also have a legitimate interest to contact you about services that may be of interest to you as part of our marketing campaigns.

(2) “Necessary for performing a contract” – this is where if we are in a contract with you (or about to enter into a contract with you and you have requested certain pre-contract details) and we need to use your personal details to complete this contract – for example, we might need to use your e-mail address to communicate with you, which would count as processing your personal data.

(3) “Consent” – this is where we set out specific circumstances where we want to process your personal data and request your consent for this. We will make sure that your consent is explicit. We will usually ask you to tick a box (or similar) to confirm that you have provided your consent. For example, unless we have a legitimate interest to contact you about our services that we would like to market to you, then we would obtain your consent to market to you in the alternative.

(4) “Compliance with a legal obligation” – this is where we might need to process your personal data in order to comply with a common law or statutory obligation, such as disclosures for compliance with HMRC requirements. We will only process your personal data for this reason if it is necessary and we would not otherwise be able to comply with that legal obligation without such processing.

Sharing your information

We will not sell, distribute or lease your personal data to third parties unless we have your consent or are required by law to do so. We currently do not transfer or share your personal data outside the European Economic Area (EEA)

Automated decision making

We do not use the information you provide to make any automated decisions that might affect you.

Retention periods

We cannot definitively set out how long we will retain all personal data in this Policy – this is a general notice that deals with different personal data collected for a variety of reasons. We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Your rights as a data subject

By law, you can ask us what information we hold about you, and you can ask us to correct it if it is inaccurate. If we have asked for your consent to process your personal data, you may withdraw that consent at any time.

If we are processing your personal data for reasons of consent or to fulfil a contract, you can ask us to give you a copy of the information in a machine-readable format so that you can transfer it to another provider.

If we are processing your personal data for reasons of consent or legitimate interest, you can request that your data be erased.

You have the right to ask us to stop using your information for a period of time if you believe we are not doing so lawfully.

Finally, in some circumstances you can ask us not to reach decisions affecting you using automated processing or profiling.

To submit a request regarding your personal data by email, post or telephone, please use the contact information provided above in the Who Are We section of this policy.

Your right to complain

If you have a complaint about our use of your information, we would prefer you to contact us directly in the first instance so that we can address your complaint. However, you can also contact the Information Commissioner’s Office via their website at www.ico.org.uk/concerns or write to them at:

Information Commissioner's Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Updates to this privacy policy

We regularly review and, if appropriate, update this privacy policy from time to time, and as our services and use of personal data evolves. If we want to make use of your personal data in a way that we haven’t previously identified, we will contact you to provide information about this and, if necessary, to ask for your consent.

We will update the version number and date of this document each time it is changed.

Version: 1.0

Date: May 2018