This is an important notice regarding your privacy and the way in which Exclaimer Ltd (referred to as “we”, “our” or “us” in this policy) collects and makes use of your personal data. We want to be open and transparent with you, and therefore encourage you to contact us if you have any questions about this policy or the ways in which we use your personal data.
This policy applies to our job applicants, business contacts and customers generally. We take our privacy responsibilities seriously and are committed to protecting and respecting your privacy.
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
All data processed by us is securely managed according to the standards of our ISO/IEC 27001:2013 Certification.
Important information and who we are
Data Controller
Exclaimer Limited is a company registered in England, UK under company number 04938619 and we have our registered office and our main trading address at 3rd Floor, 250 Fowler Avenue, Farnborough, Hampshire, GU14 7JP, United Kingdom.
Exclaimer Limited is registered with the UK Information Commissioner’s Office (ICO) with registration number ZA111523.
We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.
Contact Details
Our full details are:
Full name of data controller legal entity: Exclaimer Limited
FAO Data Protection Officer
Email address: dpo@exclaimer.com
Postal address: 3rd Floor, 250 Fowler Avenue, Farnborough, Hampshire, GU14 7JP, United Kingdom
Telephone number: + 44 (0) 1252 531422
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 consider that the ICO would also be the lead supervisory authority for Exclaimer since the UK is the place of the majority of our operations. For data protection issues in other countries, you have the right to complain at any time to the supervisory authority for that country.
We would always prefer that you come to us to help address any concerns of a privacy nature however before you go to the ICO or other applicable supervisory authority, so please contact us in the first instance.
1. What information do we hold about you?
We may collect, store and use personal data about you (referred to throughout this privacy policy as personal information):
Applicants
Personal contact details such as your name, title, address, telephone number, date of birth and e-mail address;
Recruitment information (including personal information such as your passport or visa information, CV or cover letter which is sent to us as part of the application process);
Information provided to us by our recruitment agencies in relation to your application for employment with us;
Any personal information we receive as a result of background or other checks;
Health or disability information where allowed by law and necessary for us to comply with our legal, health and safety of employees obligations.
Equality and diversity information, this may include data concerning: your ethnicity, gender, age, sexual orientation and religious beliefs. You have the right to not provide this information, in which case we will note to statutory bodies that you have elected not to provide this information where relevant.
Employees of our clients and suppliers
Contact details such as your name, business address, business telephone number and e-mail address.
Information you provide or we collect during our interactions with you or your employer.
If you use a personal credit or debit card to pay for our services, payment information such as credit/debit card number, expiration date, security code and name as it appears on the card and address the card is registered to.
Individual customers
Personal contact details such as your name, address, telephone number and e-mail address.
If you use a personal credit or debit card to pay for our services, payment information such as credit/debit card number, expiration date, security code and name as it appears on the card and address the card is registered to.
Generally
If you visit our offices, images and videos are recorded by the CCTV system in operation.
Information gathered when you visit our offices via our visitor sign-in system, including name, car registration number and who you work for.
Any personal information you provide to us during your interactions with us.
Any personal information about you provided to us during our interactions with you or your employer or a third party.
Where you or someone else provides us with access to an e-mail, any personal data contained in that e-mail.
Information provided to us by third party service providers we work with, for example, payment service or analytics providers.
Information about how you use our website, products and services
Any personal information you provide to us via our website, for example, by using the “Contact us” page on our website or if you have consented to marketing, details about your preferences in receiving marketing communications from us.
Any publicly available information such as at Companies House or the internet.
Information gathered by cookies used on our website. Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse and also allows us to improve the way our website works. For detailed information on the cookies we use and the purposes for which we use them, please refer to our Cookie Policy.
2. How will we use your personal information and what is the legal ground we rely on for doing so?
We will only use your personal information when the law allows us to. When we use your personal information, we must have a legal ground for doing so. The following are (among others) the legal grounds by which we can use your personal information:
Where you have provided us with your consent for us to do so;
Where we need to perform the contract we have entered into with you or to take steps to enter into a contract with you (contractual necessity);
Where we need to comply with a legal obligation to which we are subject;
Where it is in pursuit of our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
More specifically, we will use your personal information in the following circumstances:
Applicants
To evaluate and progress your application for employment with us – to perform the contract with you or to take steps to enter into a contract with you, and in pursuit of our legitimate interests to verify your suitability for our vacancies.
To keep a record of your application for employment with us – in pursuit of our legitimate interests in the event we wish to offer to place you in another role within our organization.
To carry out right to work checks – to comply with legal obligations to which we are subject and in pursuit of our legitimate interest to verify your details.
We do not envisage taking any decisions about you based solely on automated processing (i.e. without human involvement), which have a legal or similarly significant effect on you.
Employees of our clients and suppliers
Your contact details – in pursuit of our legitimate interests (to facilitate business between your organization and ours).
Your contact details to provide you with further information on our products and services. This may include technical information and/or marketing information – in pursuit of our legitimate interests (keeping you informed about our products, services and business updates).
Dealing with your enquiry made via our website – in pursuit of our legitimate interests to ensure your enquiry is dealt with promptly and efficiently.
To manage your customer account – in pursuit of our legitimate interests (to facilitate business between your organization and ours).
To provide your organization with our services – in pursuit of our legitimate interests (to facilitate business between your organization and ours).
To improve our services and products made available to you and to improve the user experience - in pursuit of our legitimate interests (to improve your user experience and provide you with better services and products).
Individual customers
Your contact details – to perform our contract with you or to take steps to enter into a contract with you or in pursuit of our legitimate interests (to facilitate business between you, your organization or a third party and us).
Dealing with your enquiry made via our website – in pursuit of our legitimate interests to ensure your enquiry is dealt with promptly and efficiently.
Your contact details to provide you with further information on our products and services. This may include technical information – to perform the contract with you or to take steps to enter into a contract with you. This may also include marketing information – where you have provided us with your consent for us to do so.
To provide you with our services – to perform our contract with you or to take steps to enter into a contract with you or in pursuit of our legitimate interests (to facilitate business between you, your organization or a third party and us).
As an Exclaimer customer or partner (including free trials), you agree to allow Exclaimer to use your data by virtue of agreeing to our Terms & Conditions. This allows Exclaimer to process your data and to contact you in relation to the services we offer and with additional marketing material.
To improve our services and products made available to you and to improve the user experience - in pursuit of our legitimate interests (to improve your user experience and provide you with better services and products).
Generally
To ensure our premises are kept secure – in pursuit of our legitimate interests (site security and evidence).
Health and safety purposes – to comply with a legal obligation.
To provide our e-mail signature services to you, your organization or a third party – to perform our contract with you or to take steps to enter into a contract with you or in pursuit of our legitimate interests (to facilitate business between you, your organization or a third party and us).
To administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes – in pursuit of our legitimate interests (to better understand how people interact with our website and solve any issues it may have).
To improve our website to ensure that content is presented in the most effective manner for you and your computer – in pursuit of our legitimate interests (to improve our content and your or other third parties’ experience of our services).
To improve our services or solve technical issues – in pursuit of our legitimate interests (to improve our content and your or other third parties’ experience of our services).
To transfer to third party service providers – in pursuit of our legitimate interests (in outsourcing for effectiveness and efficiency).
To contact you if we wish to use your information for a purpose not set out in this policy – to comply with a legal obligation.
Developing and improving our website and services: we process your personal information to analyze trends and to track your usages of and interactions with our website and services to the extent necessary for our legitimate interest in developing and improving our websites and services and providing our users with more relevant content and services offerings or where we seek your consent.
Assessing and improving user experience: we process data usage, which in some cases may be associated with your personal information, to analyze trends and assess and improve the overall user experience to the extent it is necessary for our legitimate interest in developing and improving our websites and services and providing our users with more relevant content and services offerings or where we seek your consent.
3. What happens if there is a change of purpose?
We will only use your personal information 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 we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
4. Which type of third parties might we share your personal information with?
We require third parties to respect the security of your personal information and to treat it in accordance with the law. For example, where we instruct third party service providers, we carry out due diligence on those providers to ensure they treat your personal information as seriously as we do and we require them to adhere to the same laws and standards as we treat your personal information.
We may share your personal information with the following types of third parties:
Recruitment partners assisting us with employment related matters, for example, recruitment agencies and job boards.
Professional advisers such as lawyers, accountants and business analysts.
Providers which assist us with marketing by, for example, helping us send our marketing mailshots or assisting us with marketing campaigns.
Providers which assist us in solving your enquiries, for example, by facilitating a live chat with one of our team.
Providers who assist us in our disaster recovery procedures, for example, back up datacenters.
Provides which help us collate and organize information effectively and securely.
Providers which help us with delivery solutions.
Third party software hosting companies which provide us with software solutions such as our customer relationship management system.
Providers which host our servers in their datacenters.
Providers assisting us with payment and fraud prevention solutions.
Accreditation and certificate boards such as auditors who check our systems for our International Organization for Standardization compliance.
Our overseas subsidiaries or sister companies.
5. Data retention
How long will you use my personal information for?
We will only retain your personal information for as long as necessary to fulfill the purposes we collected it for.
We assess the appropriate retention period for different information based on the size, volume, nature, and sensitivity of that information, the potential risk of harm to you from unauthorized use or disclosure of that information, the purposes for which we are using that information, applicable legal requirements for holding that information, and whether we can achieve those purpose(s) through other means.
Applicants
Where you are successful in your application for employment with us, we will provide further information during the course of your employment as to how we use your information.
Where you are unsuccessful, we will keep your personal information for 6 months to allow us to establish, exercise or defend legal claims; and for our legitimate interests – to enable us to reconsider your application and (if appropriate) contact you, if the position you applied for becomes available again.
Employees of our clients and suppliers
Where we have collected your personal information during the course of your and our organizations doing business, we will keep your personal information for as long as this business continues, or for as long as we have a commercial interest in holding your personal information, for example, with a view to doing business in the future. Other than retention for tax or legal reasons, your personal information will not be retained longer than 6 months after our contract with your employer terminates.
Where you have provided us with your personal information in connection with requesting a report through our website, we will keep this information for no more than 6 months.
Where you have provided us with your bank account details in connection with paying us for our services to you, we will keep this information for 1 year.
Where you use our website and one of our cookies is activated, that cookie will operate for the duration set out in our Cookie Policy.
Individual customers
Where we have collected your personal information during the course of you and us doing business, we will keep your personal information for as long as this business continues, or for as long as we have a commercial interest in holding your personal information, for example, with a view to doing business in the future. Other than retention for tax or legal reasons, your personal information will not be retained longer than 6 months after our contract with you terminates.
If you have consented to receiving marketing information, we will keep your personal information for as long as we still have your consent.
Where you have provided us with your bank account details in connection with paying us for our services to you, we will keep this information for 1 year.
Where you have provided us with your personal information in connection with requesting a report through our website, we will keep this information for 6 months.
Where you use our website and one of our cookies is activated, that cookie will operate for the duration set out in our Cookie Policy.
Generally
Any data collected through our visitor sign-in system is stored for 30 days.
Where we have collected your personal information during the course of you and us doing business, we will keep your personal information for as long as this business continues, or for as long as we have a commercial interest in holding your personal information, for example, with a view to doing business in the future. Other than retention for tax or legal reasons, your personal information will not be retained longer than 6 months after our contract with you terminates.
Any videos or images captured by our CCTV system are stored for 30 days only.
6. Where we store your personal information
Electronic versions of your personal information are stored on our servers within the UK.
The server which we use to provide our services to you depends on the location that you or your organization chooses. For example, if you or your organization elects for our services to be provided within Europe, then the server used to provide our service to you or your organization will be based within Europe.
Where we use third party service providers to assist us, your personal information may also be stored in accordance with their practices and procedures. We require third parties to respect your personal information and to treat it in accordance with the law.
7. Rights of access, correction, erasure and restriction
Your rights in connection with your personal information
Under certain circumstances, by law you have the right to:
Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of your personal information and to check we are lawfully processing it.
Request correction of your personal information. This enables you to have any incomplete or inaccurate personal information corrected.
Request the erasure of your personal information. This enables you to ask us to delete or suppress personal information where there is no good reason for us continuing to process it. In some cases, we will need to retain limited information to ensure the data subject’s request is respected in future. You also have the right to ask us to stop processing personal information where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground.
Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of your personal information where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground.
Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of your personal information, for example, if you want us to establish its accuracy or the reason for processing it.
Request the transfer of your personal information to another party.
Right to object to the processing of your personal data for marketing purposes. You may also object when the processing is based on the public interest or other legitimate interests, unless we have compelling legitimate grounds to continue with the processing.
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal information, or request that we transfer a copy of your personal information to another party, please send an email to dpo@exclaimer.com. We will do our utmost to respond to your request without delay or within 30 days maximum as stipulated by law. We will be obligated to confirm your identity before any Data Subject Access request is completed.
8. No fee usually required
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
9. What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to another person who has no right to receive it.
10. Right to withdraw consent
In the limited circumstances where you may have provided your consent to the collecting, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact our Data Protection officer in writing using the contact details set out at the beginning of this privacy policy.
Where we are providing you with marketing information, you can also change your marketing preferences by using the unsubscribe button at the bottom of our marketing e-mails to you.
Once we have received notification that you have withdrawn your consent, we will no longer process your personal information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so.
11. What happens if you fail to provide personal information?
If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you (such as providing you with our products or services), we may not be able to employ you or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of visitors to our offices).
12. Right to complain
You have a right to make a complaint if you wish to do so. The organization with oversight of our processing is the Information Commissioner’s Office, which can be contacted in writing at Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, by telephone (0303 123 1113) or by e-mail (casework@ico.org.uk).
13. Changes to this privacy policy
We may change, modify, add or remove portions of this privacy policy at any time, and any changes will become effective immediately.
Any changes we make to our privacy policy will be posted on this page and, where appropriate, notified to you.