Policy version: 28 June 2022
It also explains your rights in relation to your personal data and how to contact us or the relevant regulator in the event you have a complaint. Our collection, storage, use and sharing of your personal data is regulated by law, including under the UK General Data Protection Regulation (UK GDPR).
Where we are the controller of personal data obtained via the Services, we are the organisation legally responsible for deciding how and for what purposes it is used and we do so in accordance with this policy.
2. What this policy applies to
The Services may link to or rely on other apps, websites, APIs or services owned and operated by us or by certain trusted third parties to enable us to provide you with Services. These other apps, websites, APIs or services may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to these other apps, websites or services, please consult their privacy policies as appropriate. For more information see the section ‘Who we share your personal data with’ below.
This policy does not in any part relate to the personal data regarded as “prospect data” you or your organisation upload to the platform, or the personal data you add to the platform when you are setting up and creating new platform users. As regards that data you or your organisation will be the data controllers, Pipelyft being a data processor acting on your behalf .As such Pipelyft has to comply with such regulation as enforced in the Data Protection Act 2018 regarding the duties of a data processor concerning the processing and security of the data it processes. Any third parties or sub-contractors we use to enable us to provide you with Services are acting as data processors on our behalf. Our relationship with them is contractually defined and includes sections on legislative compliancy around the processing of data .
3. Personal data we collect about you
The personal data we collect about you depends on the particular activities carried out through the Services. We will collect and use the following personal data about you:
|Data Category||In More Detail|
Identify and account data you input into the Services
Registration is mandatory in order to use the Services
|Data collected when you use specific functions in the Services||Data you store online with us using the Services including your usage history or preferences (while such data may not always be personal data as defined at law in all cases we will assume it is and treat it in accordance with this policy as if it were)|
|Other data the Services collects automatically when you use it|
If you do not provide the personal data we ask for where it is required, it may prevent us from providing services and/or the Services to you.
We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below.
4. Sensitive Data
Sensitive personal data (also known as special category data) means information related to personal data revealing racial or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; genetic data; biometric data (where used for identification purposes); data concerning health; data concerning a person’s sex life; and data concerning a person’s sexual orientation.
Please note that we do not knowingly or intentionally collect sensitive personal data or information about criminal convictions from individuals and that you should not submit sensitive data to us.
If, however you do submit sensitive data to us, such as if you make this sensitive data available to other users of the Services (such as by publishing it through any forum feature we may make available from time to time) we will assume that you have purposefully made any such sensitive data manifestly public.
5. How your personal data is collected
We collect personal data from you directly when you sign up to the Services, contact us directly or reach out to us via social media, make submissions via the Services when a forum element is available, or indirectly, such as your activity while using the Services.
6. How and why we use your personal data
Under data protection law, we can only use your personal data if we have a proper reason, e.g.:
- where you have given consent
- to comply with our legal and regulatory obligations
- for the performance of a contract with you or to take steps at your request before entering into a contract, or
- for our legitimate interests or those of a third party
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You can obtain details of this assessment by contacting us (see ‘How to contact us’ below).
The table below explains what we use your personal data for and why.
|What we use your personal data for||Our reasons|
|Create and manage your account with us||To perform our contract with you or to take steps at your request before entering into a contract|
|Providing services and/or the functionalities of the Services to you|
Depending on the circumstances:
|To enforce legal rights or defend or undertake legal proceedings|
Depending on the circumstances:
|Communications with you not related to marketing, including about changes to our terms or policies or changes to the Services or platform or other important notices|
Depending on the circumstances:
|Protect the security of systems and data||To comply with our legal and regulatory obligations we may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests or those of a third party, i.e., to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us|
|Operational reasons, such as improving efficiency, training, and quality control or to provide support to you||For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service to you|
|Statistical analysis to help us manage our business, e.g., in relation to our performance, customer base, app and functionalities and offerings or other efficiency measures||For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service to you and improve and develop our app|
|Updating and enhancing user records|
Depending on the circumstances:
Depending on the circumstances:
|To comply with our legal and regulatory obligations|
To share your personal data with members of our group and third parties in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency.
In such cases information will be anonymised where possible and only shared where necessary
Depending on the circumstances:
See ‘Who we share your personal data with’ for further information on the steps we will take to protect your personal data where we need to share it with others.
We use email marketing to inform you of our services such as promotions.
We will always ask you for your consent before sending you marketing communications, except where you have explicitly opted-in to receiving email marketing from us in the past or except where you were given the option to opt-out of email marketing when you initially signed up for your account with us and you did not do so.
You will have the right to opt out of receiving marketing communications at any time by:
- contacting us at [insert contact details for marketing opt-out]
- using the ‘unsubscribe’ link included in all marketing emails you may received from us
We will always treat your personal data with the utmost respect and never sell or share it with other organisations for marketing purposes.
For more information on your right to object at any time to your personal data being used for marketing purposes, see ‘Your rights’ below.
8. Who we share your personal data with
We share personal data with service providers we use to help us run our business or provide the services or functionalities in the Services, including developers and cloud storage providers. We exert no control over their Privacy Policies.
We only allow service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers to ensure they can only use your personal data to provide services to us and to you.
We or the third parties mentioned above may occasionally also need to share your personal data with:
- external auditors, e.g. in relation to the audit of our accounts and our company —the recipient of the information will be bound by confidentiality obligations
- professional advisors (such as lawyers and other advisors)—the recipient of the information will be bound by confidentiality obligations
- law enforcement agencies, courts or tribunals and regulatory bodies to comply with legal and regulatory obligations
- other parties in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised but this may not always be possible, however, the recipient of the information will be bound by confidentiality obligations
If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).
We will not knowingly share your personal data with any other third party than those mentioned.
9. How long your personal data will be kept
Your personal data is deleted from active data when you close your account but is retained in our backups for 12 months following cancellation of your subscription. If you have cancelled your subscription with us, we will delete your records immediately following any restoration from our backup files. Certain details including financial records and other information that may be required in the event of pursuit or defence of legal claims is retained for a period up to 6 years to comply with any accounting or legal obligations which we have..
Following the end of the of the aforementioned retention period, we will delete or anonymise your personal data.
10. Transferring your personal data out of the UK
We have servers located in the UK, the EU, Switzerland, North America and the Asia-Pacific Region. At this point in time, we do not transfer your personal data outside of the geographic location of your chosen servers (Chosen Jurisdiction), as selected by you during creation of your user account on the platform. If your chosen jurisdiction is in a different jurisdiction to your own (Home Jurisdiction) then you consent to your information being transferred to your Chosen Jurisdiction and you acknowledge and accept that protection and privacy of your personal data will be subject to the applicable laws of your Chosen Jurisdiction and may not offer the same level of protection as that available in your Home Jurisdiction.
Under UK data protection laws, we can only transfer your personal data to a country outside the UK where: the UK government has decided the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy regulation’) further to Article 45 of the UK GDPR; there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you; or a specific exception applies under relevant data protection law. Accordingly, if we were to start transferring your personal data from the UK to:
- The EEA: we would rely on the adequacy finding granted by the UK to the EU under the Withdrawal Agreement to do; for any transfers from the EU to the UK, we would rely on the adequacy regulation granted to the UK under the Adequacy Decision.
- Any country located outside the UK/EEA: we would rely an appropriate safeguards under the UK GDPR, such as by signing an international data transfer agreement.
In the event we could not or choose not to continue to rely on either of those mechanisms at any time we would not transfer your personal data outside the UK unless we could do so on the basis of an alternative mechanism or exception provided by UK data protection law.
11. Your rights
You generally have the following rights, which you can usually exercise free of charge. For more information regarding these rights, please visit the ICO website here.
|Access to a copy of your personal data||The right to be provided with a copy of your personal data.|
|Correction (also known as rectification)||The right to require us to correct any mistakes in your personal data.|
|Erasure (also known as the right to be forgotten)||The right to require us to delete your personal data—in certain situations.|
|Restriction of use||The right to require us to restrict use of your personal data in certain circumstances, e.g. if you contest the accuracy of the data.|
|Data portability||The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations.|
|To object to use|
The right to object:
· at any time to your personal data being used for direct marketing (including profiling)
· in certain other situations to our continued use of your personal data, e.g. where we use you personal data for our legitimate interests.
|Not to be subject to decisions without human involvement|
The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you
We do not make any such decisions based on data collected by the Services.
For further information on each of those rights, including the circumstances in which they do and do not apply, please contact us (see ‘How to contact us’ below). You may also find it helpful to refer to the guidance from the UK’s Information Commissioner on your rights under the UK GDPR.
If you would like to exercise any of those rights, please complete a request form—available on our website at [insert link] or email , call or write to us—see below: ‘How to contact us’. When contacting us please:
- provide enough information to identify yourself (e.g., your full name and username) and any additional identity information we may reasonably request from you, and
- let us know which right(s) you want to exercise and the information to which your request relates
12. Keeping your personal data secure
We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
13. How to complain
Please contact us if you have any queries or concerns about our use of your information (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.
You also have the right to lodge a complaint with the Information Commissioner.
The Information Commissioner can be contacted at https://ico.org.uk/make-a-complaint or telephone: 0303 123 1113.
15. How to contact us
- Pipelyft Ltd, Suite 19, Paulton House, BRISTOL, BS39 7SX
- (+44) 01761 418494