Scribestar General Site Data Ownership, Protection and Privacy
The following paragraphs form part of, and are incorporated into, the Scribestar General Site Terms and Conditions of Use Version 4 Issued 18 April 2018. Historic versions can be obtained by contacting us. Scribestar respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit the Scribestar General Site (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you. It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
DATA PROTECTION AND PRIVACY
Scribestar is a data controller for the purposes of any personal data that you provide to us on or ancillary to, the Scribestar General Site. Scribestar will hold and process that personal data in accordance with Data Protection Legislation. Scribestar stores all personal data on servers located in the UK, but you hereby agree that Scribestar may export that personal data to within the European Economic Area or outside of the European Economic Area, if it does so in accordance with Data Protection Legislation and your consent to Scribestar exporting both within and outside of the European Economic Area, is hereby expressly given by you.
Under certain circumstances, you have rights under the Data Protection Legislation in relation to your personal data. Subject Access Requests You are entitled to apply for a copy of the information we hold about you (for which we may charge a small administration fee). This is called a data subject access request. Erasure In certain circumstances having provided that personal data, you may request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. Processing Objections You may also object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. Withdrawing Consent If you no longer wish that Scribestar contact you, then you can contact Scribestar at the address below, to withdraw your consent to our processing of your personal data and such withdrawal will be made as soon as possible following Scribestar being told by you. Scribestar reserves the right to validate such a request before implementing it. Such a request will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. If your contact with Scribestar is made under a Customer Contract or as a user appointed from the operation of that contract, your contact with Scribestar arises as a result of the use by the Scribestar Customer of the Scribestar Services which are provided as from the Scribestar Services Site. In order to stop contact under those arrangements, you must also contact the relevant Scribestar Customer organization. If you have any questions about this, please contact us at the address below. Correcting Inaccurate information You also have the right to have any inaccurate information about you corrected. We want to make sure that your information is accurate and up to date. You may ask us to correct or remove any information that you think is no longer up to date. Please contact us using the contact details below if you would like any corrections made to your information. Transfer Requests You may request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. We may require further information from you in order to verify your identity before disclosing any personal information to you under a data subject access request, any withdrawal of consent, any objection to processing, any request to restrict processing and any request to transfer your personal data. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. Complaints You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Our full contact details are:
Attention: Chief Executive Officer (Scribestar’s Nominated Data Protection Officer)
Email address: email@example.com
Postal address:45 Beech Street,
London, EC2Y 8AD,
Telephone: 0800 045 3075
All email messages sent to and from Scribestar may be monitored to ensure compliance with our internal policies and to protect our business.
INFORMATION WE MAY COLLECT FROM YOU
For the purposes of these Terms, and the Data Protection Legislation, personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). Scribestar may collect and process personal data about you which includes information you provide when you register to use the Scribestar General Site including any associated services or information or materials or feedback or otherwise arising as from your visit, access or use of our Scribestar General Site and/or the provision of Other Services to you. The information you give us may include your name, address, e-mail address and phone number, and other information you chose to input to the Scribestar General Site, which for the purposes of Data Protection legislation may be regarded as personal data and you hereby expressly authorise us to process that personal data in accordance with these Terms. We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice. We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. With regard to each of your visits to the Scribestar General Site we may also automatically collect technical information, including the Internet Protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform and information about your visit, including the full URL clickstream to, through and from our Scribestar General Site (including date and time); services you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number or other means used to call or otherwise contact our customer service. Where you have provided personal data by completing registration and application forms on the Scribestar General Site, it is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us. Where we need to collect personal data by law, or you fail to provide data when requested, we may not be able to provide you with goods or services. In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through: (a) Direct interactions. You may give us your identity and contact data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- apply for our products or services;
- create an account on the Scribestar General Site;
- subscribe to our service or publications;
- request marketing to be sent to you;
- enter a competition, promotion or survey; or
- give us some feedback.
- analytics providers such as Google based outside the EU;
- advertising networks based inside or outside the EU; and
- search information providers such as Thomson Reuters based inside or outside the EU.
Contact, financial and transaction data from providers of technical, services such as Dealogic based inside or outside the EU. Identity and contact data from publicly available sources such as company/firm web sites, Companies House and the Electoral Register based inside the EU.
6 HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data where it is necessary for our legitimate interests* (or those of a third party) and your interests and fundamental rights do not override those interests and where we need to comply with a legal or regulatory obligation. In particular, we may use your personal information to:
- conduct administrative or operational processes within our business;
- process and respond to requests, enquiries or complaints received by you;
- to provide products and services requested by you;
- to identify products and services you may be interested in;
- to communicate with you about our products and services;
- to invite you to events;
- to monitor and analyze our business;
- to form a view of you as an individual and to identify, develop or improve our services and/or products that may be of interest to you and to carry out market research;
- to send you marketing information.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data. We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. We may have to share your personal data with service providers acting as processors based in the EEA who provide IT and system administration services, such as, for example, helpdesk services, where it is necessary for our legitimate interests. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law. *Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
USE OF YOUR DATA FOR MARKETING PURPOSES
We may ask whether you wish to receive marketing from us and this will be presented to you as an option on the relevant application form or page on the Scribestar General Site where necessary. We will not send you marketing if you ask us not to. If you have agreed to receive marketing but then later change your mind and no longer wish to receive marketing, please let us know so we can remove you from our distribution lists. You can contact us via our contact details noted in section 3.
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
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.
THIRD PARTY LINKS
The Scribestar General Site may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
YOUR ACCOUNT AND PASSWORD
If you are asked to register on the Scribestar General Site and choose to do so, then you confirm that you have the full authority to do so and that all information that you give is true, accurate, current and complete in all respects and, for so long as you are a Visitor to the Scribestar General Site, you shall maintain and promptly update such information to keep it true, accurate, current and complete. If you are provided with a user identification code, password or any other piece of information as part of Scribestar’s security procedures, you must treat such information as confidential. You must not disclose it to any third party and it is for your personal use only. Scribestar will not be liable for any loss that you may incur, or may create, as a result of someone else’s use of your password or account, either with or without your knowledge or assent. You may not use any other user’s account at any time or for any reason. You are solely responsible for the content of any data and information which you share with the Scribestar General Site and for the purposes of all Data Protection Legislation, you hereby give your express consent to Scribestar being able to use such data for the purposes intended by the Scribestar General Site, including but not limited to contacting you for the purpose of advising you about the Scribestar Services and the progress of Scribestar and if agreed with us, the provision of Other Services to you. Scribestar has the right to disable any user identification code or password, whether chosen by you or allocated by Scribestar, at any time, if in our reasonable opinion you have failed to comply with any of the provisions of these Terms or otherwise.
FURTHER COMMUNICATIONS FROM SCRIBESTAR
The Scribestar General Site may result in certain communications from Scribestar being made to a Visitor, such as service announcements, administrative messages, newsletters and other offers or marketing activity. You understand that these communications shall be considered part of using the Scribestar General Site. As part of our policy to provide you total privacy, we also provide you the option of opting out from receiving these communications from us as described above.
All data supplied by Scribestar on the Scribestar General Site is owned by and/or licensed to Scribestar. Any data that you input onto the Scribestar General Site is provided by you and may be used by Scribestar on a perpetual royalty-free licence basis for use anywhere in the world and upon any medium. None of the foregoing shall grant rights to personal data to Scribestar, where such rights would be in breach of Data Protection Legislation.
VISITOR GENERATED CONTENT
You shall be solely responsible for any content that you display on the Scribestar General Site and the consequences of its transmission or publication. Any content made public will be publicly accessible through the internet and may be crawled and indexed by search engines. You are responsible for ensuring that you do not accidentally make any private and/or confidential content publicly available, including personal data. You agree not to use, copy, reproduce, distribute, transmit, broadcast, display, sell, license or otherwise exploit any third party owned content without the applicable licence rights and permissions to do so and you shall indemnify Scribestar in full in the event that in any of your use of the Scribestar General Site, you infringe the rights of others, including under Data Protection Legislation or other privacy rights. Scribestar will have the right to block access to or remove such content made available by you, with or without reason.
Scribestar will maintain commercially reasonable administrative, physical and technical safeguards to protect the security, confidentiality and integrity of any personal data (in accordance with Data Protection Legislation) and for all other information that you provide to Scribestar which has not been published by you on the Scribestar General Site and is not otherwise in the public domain and which any reasonable person would regard as confidential information of yours. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. Information sent through the internet is subject to the security standards on the internet generally but we shall use all reasonable endeavours to ensure that, for Scribestar systems, reasonable security measures have been implemented. Although we will do our best to protect your personal data, we cannot guarantee the security of your personal data when being transmitted to our site: any transmission from you to us is at your own risk. Once we have received your personal data, we will use strict procedures and security features in accordance with Data Protection Legislation, to try to prevent unauthorised access. If Scribestar becomes aware of any security breach in respect of your personal data, Scribestar will comply with its obligations under Data Protection Legislation. Scribestar records and documents its processes for the collection and storage of personal data in compliance with Data Protection Legislation. We will notify you and any applicable regulator of a breach where we are legally required to do so.