Privacy notice

Last update: 5 June 2018

This Privacy Notice of Ciphr Limited forms part of the terms and conditions for use of this site. Please read the Privacy Notice carefully. By using this site, you will be deemed to have accepted these terms of use. If you do not accept the terms of this Privacy Notice, please do not use this site.

You can contact Ciphr’s data protection officer by emailing dpo@ciphr.com, by calling 01628 814 000 or by post to DPO, Ciphr Ltd, 3rd Floor, 33 Blagrave Street, Reading, RG1 1PW

Please select your option, for further assistance mail us privacy@ciphr.com.

We want you to feel secure when visiting our site and are committed to maintaining your privacy when doing so. This Privacy Notice outlines how we may obtain and use any personal data about you and the ways in which we protect and treat such information that we collect when you are on our site or when you use our services. This privacy notice also applies to any personally identifiable information about you that our business partners may share with us. This notice does not apply to the practices of companies that we do not own or control or to people that we do not employ or manage.

Most of the personal information we process is provided to us directly by you for one of the following reasons:

• You have made an enquiry to us.
• You have made an information request to us.
• You wish to attend, or have attended, an event or webinar.
• You subscribe to our e-newsletter or updates.
• You have applied for a job with us. We will process your details in line with our job applicant privacy notice which is available from privacy@ciphr.com
• You have requested further information such as a product demonstration or brochure.
• You have requested access to a resource such as a white paper, video or case study.
• You are representing your organisation.
• You have corresponded with us by post, phone, email or other means.
• You respond to surveys we are conducting or competitions we are running.

We also receive personal information indirectly, in the following scenarios:

• An employee of ours gives your contact details as an emergency contact or a referee.
• Your details are passed to us by a supplier (for example an event organiser) or partner company, where you have requested your details be passed to us.
• We may collect personally identifiable information about you or your organisation from publicly available data sources including, but not limited to Companies House, company websites, social networks and news articles.
• We may collect identity and contact data from data brokers or aggregators.

The personal information we collect will depend on the nature of the service we are providing, and the purpose for which it is collected. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our website, products and services.
  Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• 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.
• Where we need to comply with a legal or regulatory obligation.
• Where you have provided your consent to us to use your personal data in a certain way such as direct marketing by email.
• We have set out below, a description of the most common ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data on more than one lawful ground depending on the specific purpose for which we are using your data.

We may also process your personal data without your knowledge or consent, in compliance with this notice, where this is required or permitted by law.

Purpose/Activity: To register you as a new customer.

Type of data:

Identity
Contact
Profile
Usage
Marketing and communications
Technical

Lawful basis for processing including the basis of legitimate interest:

Performance of a contract with you.

Purpose/Activity: To enable you to partake in a prize draw, competition or complete a survey.

Type of data:

Identity
Contact
Profile
Usage
Marketing and communications

Lawful basis for processing including the basis of legitimate interest:

Performance of a contract with you.

Necessary for our legitimate interests (to study how customers and potential customers might use our products/services, to develop them and grow our business).

Purpose/Activity: To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).

Type of data:

Identity
Contact
Technical

Lawful basis for processing including the basis of legitimate interest:

Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
Necessary to comply with a legal obligation

Purpose/Activity: To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.

Type of data:

Identity
Contact
Profile
Usage
Marketing and Communications
Technical

Lawful basis for processing including basis of legitimate interest:

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

Purpose/Activity: To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

Type of data:

Technical
Usage

Lawful basis for processing including the basis of legitimate interest:

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

Purpose/Activity: To promote Ciphr or our partners’ brands, goods and services, events or news that may be of interest to you

Type of data:

Identity
Contact
Technical
Usage
Profile

Lawful basis for processing including the basis of legitimate interest:

Necessary for our legitimate interests (to develop our products/services, our brand and to grow our business)

You can opt out of receiving email communication from the Ciphr by clicking the unsubscribe button at the bottom of any marketing email. Alternatively you can call 01628 814242 or email privacy@ciphr.com. It may take up to 21 days for the changes to come into effect.

Ciphr Limited is registered under the data protection laws in the United Kingdom and takes all reasonable care to prevent any unauthorised access to your personal data. Other than as set out below we will not pass your personally identifiable information to anyone outside Ciphr Limited. We will only send personally identifiable information about you to other companies or individuals:

where we have your consent for the disclosure or
in order to share your information to provide a product or service you have requested or
in order to send the information to companies or individuals who work on behalf of Ciphr Limited or any subsidiary in connection with the provision of a product or service to you (unless we tell you differently. These companies or individuals will be instructed to not use the personally identifiable information we provide to them beyond what is necessary to assist us in this purpose)
where we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets

The legal grounds for processing your personal data are as follows:

It is necessary for the performance of a contract to which you are a party, or to take steps prior to entering into a contract with you. The agreement between you and Ciphr, which is outlined in our Terms and Conditions, sets out the terms of the contract and the services we will provide.
It is necessary for the purposes of our legitimate interests, except where our interests are overridden by the interests, rights or freedoms of affected individuals (such as you). To determine this we shall consider a number of factors, such as what you were told at the time you provided your data, what your expectations are about the processing of the data, the nature of the data, and the impact of the processing on you.
It is necessary in order to comply with mandatory legal obligations to which we are subject under EU or UK law.

Ciphr Limited is committed to protecting the security of your personal information. We use a variety of security technologies, policies and procedures to help protect your personal information from unauthorised access, use or disclosure. For example, we store the personal information you provide in computer servers with limited access that are located in controlled facilities. When we transmit sensitive information over the internet, we protect it through the use of encryption, such as the Transport Layer Security (TLS) protocol. TLS is an industry standard to ensure internet messages are not intercepted. However, older browsers cannot use TLS and you will need to use Microsoft Internet Explorer browsers, version 11 or later or suitable alternatives.

When someone visits the site, a cookie is placed on the customer’s machine (if the customer accepts cookies) or is read if the customer has visited the site previously. One use of cookies is to assist in the collection of the site visitation statistics. We also use cookies to collect information on which newsletter, page and site links are clicked by customers. This information is used to ensure we are sending information customers want to read.

Web beacons, also known as clear gif technology, or action tags, may be used to assist in delivering the cookie on our site. This technology tells us how many visitors clicked on key elements (such as links or graphics) on a web page. We do not use this technology to access your personally identifiable information, it is a tool we use to compile aggregated statistics about our web site usage. We may share aggregated site statistics with partner companies but do not allow other companies to place clear gifs on our sites.

If you choose to not have your browser accept cookies from our web site, you will be able to view the text on the screens, however you will not experience a personalised visit, nor will you be able to subscribe to the service offerings on the site.

You can view a list of cookies used on our site here

Third party internet sites that you can link to through the Ciphr Limited site are not covered by this Privacy Notice, so please be careful when you enter any personal information online. Ciphr Limited accepts no responsibility or liability for these sites.

Ciphr Limited will occasionally update this privacy notice. When we do, we will also revise the “last updated” date at the top of the privacy notice. For material changes to this notice, Ciphr Limited will notify you by placing prominent notice on the web site.

This website uses remarketing services to advertise on third party websites. It could mean that we advertise to previous website visitors. This could be in the form of an advertisement on a search engine’s results page or as a display advert on a third party website within the ad network’s inventory. Third-party retargeting services use cookies to serve ads based on someone’s past visits to the Ciphr website. Of course, any data collected will be used in accordance with our own privacy notice and the ad network’s privacy notice.

You can usually opt out of receiving targeted ads served by us or on our behalf by clicking on the blue icon that typically appears in the corner of the ads we serve. Please note that, if you delete your cookies or upgrade your browser after having opted out, you will need to opt out again.

You can also opt out of cookie based advertising entirely by updating your browser’s cookie settings or permanently using a browser plugin

The retargeting services we may use are:

• Adroll. You can view their privacy notice here and opt out of receiving ads from the Adroll network here
• Bing. You can view their privacy notice here and opt out of receiving ads from the Bing network here
• Facebook. You can view their privacy notice here. You can view instructions of how to influence the ads that Facebook displays to you here
• Google. You can view their privacy notice here and opt out of seeing personalised ads from Google here
• Instagram. You can view their privacy notice here and instructions of how to opt out of receiving certain ads from the Instagram network here
• Linkedin. You can view their privacy notice here and manage your advertising preferences with Linkedin here
• Quora. You can view their privacy notice here
• Reddit. You can view their privacy notice here and opt out of receiving ads from the Reddit network here
• Taboola. You can view their privacy notice here and opt out of receiving ads from the Taboola network here
• Twitter. You can view their privacy notice here and update your personalisation preferences here

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

Right of Access
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. Note, however, that we may be unable to supply certain pieces of information that you have requested, if it is subject to legal privilege or relates to management planning. This will be notified to you, if applicable, at the time of your request.

You can submit a subject access request to Ciphr by emailing privacy@ciphr.com or by calling 01628 814 000.

To assist us in processing your request, you will need to provide the following information:

• Full name
• Telephone number
• Email address
• Information sought (Please describe, in as much detail as possible, the information you wish to have access to and if appropriate, any dates relevant to the information sought.)

Right to Rectification
Under the GDPR you are entitled to have personal data that we hold on you rectified if it is inaccurate or incomplete. If you are aware of inaccurate information held about you by Ciphr email privacy@ciphr.com

Right to Erasure
Request erasure of your personal data. This enables you to ask us to delete personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete 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 or as soon as possible thereafter. We may also anonymise rather than delete your data.

You will be asked for the following information to assist us in processing your request:

• Full name
• Telephone number
• Email address

To request that your personal data is erased by Ciphr email privacy@ciphr.com

Right to Object
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.

If you would like to exercise this right, please email Ciphr at privacy@ciphr.com or call us on 01628 814 000. Please provide your full name, telephone number, and email address.

Right to Restrict Processing
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

If you would like to exercise this right, please email Ciphr at privacy@ciphr.com or call us on 01628 814 000. Please provide your full name, telephone number, and email address.

Right to Data Portability
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.

If you would like to exercise this right, please email Ciphr at privacy@ciphr.com or call us on 01628 814 000. Please provide your full name, telephone number, and email address.

Rights Related to Automated Decision Making
The GDPR has provisions on:

automated individual decision-making (making a decision solely by automated means without any human involvement); and
profiling (automated processing of personal data to evaluate certain things about an individual). Profiling can be part of an automated decision-making process.
Ciphr may use automated decision-making to help target our marketing activity. This could include what products or blog posts we promote on our website to a particular visitor based on past browsing behaviour or what emails we send a contact in our marketing database depending on the actions they have taken with previous email campaigns. To object to Ciphr using your data for these purposes please email privacy@ciphr.com

Additionally, some of Ciphr’s products enable our customers to create automated decision-making rules such as screening questions during the recruitment process. Our customers are able to publish the relevant details to comply with the GDPR.

Right to Withdraw Consent
Withdraw consent at any time where we are relying on consent to process your personal data. However, this 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 you would like to opt out from receiving marketing messages from us, please select the Unsubscribe link at the bottom of every message.

What we will need from you

We will need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time Limit to Respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.