Important information and who we are
The data we collect about you
How is your personal data collected
How we use your personal data
Your legal rights
1. IMPORTANT INFORMATION AND WHO WE ARE
Private individuals and individuals within our customer organisations.
Prospective customers – private individuals and individuals within prospective customer organisations.
All of which we collectively refer to as “you”:
When you enquire about our services and products.
When we are provided with your details by others.
When you are a customer or prospective customer.
When we deal with suppliers, or other business contacts such as referrers.
When you visit our website, including any data you may provide through this website.
Our services, and our website, are not intended for children and we do not knowingly collect data relating to children
When we communicate with you about our products or services, or you become a customer of Seed Developments Ltd, we will let you know which entity will be the controller for your data when we first communicate with you.
There may be scenarios where we will act as a data processor and when doing so will comply with European Data Protection Legislation.
Seed Developments Ltd is responsible for this website and is the controller for any personal data collected via this website.
Our full details are:
Full name of legal entity: Seed Developments Ltd
Name and title of DPO: Andrew Gould – CEO – Risk & Compliance
Email address: firstname.lastname@example.org
Postal address: Unit A, Huntworth Way, North Petherton, Bridgwater, Somerset, TA6 6FA, United Kingdom
Telephone number: 01278 661112
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.
This version was last updated on 24 October 2018.
It is important that the personal data we hold is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
2. THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where it is not possible to identify the individual (anonymous data).
We may collect, use, store and transfer different kinds of personal data which we have grouped together as follows:
Identity Data includes: name(s), last name, title.
Contact Data includes billing address, delivery address, email address and telephone numbers, and the content of your communications (except where it falls within advice data below).
Advice Data includes personal data that you provide to us, or which we collect, in connection with our services, such as; our communications with you or about you, our advice where it relates to you or any individual referred to in our advice, information about your claim, dealings with third parties about you, your personal or business circumstances or history. If you are not our customer, we will also process your personal data as set out in section 4 below.
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/or services you have purchased from us.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We may also receive personal data as part of a membership or shared event to which you have subscribed or attended.
PERSONAL DATA COLLECTED VIA OUR WEBSITE
On our website you can make information requests, apply for jobs, subscribe to marketing or support materials, or register yourself to receive information and updates.
We may collect and process the following data about you:
information you provide to us on these pages, which may include name, address, telephone, e-mail address, user ids and passwords, billing information, information and contact preferences
if you contact us, we may keep a record of that correspondence
information about your computer, including where available your IP address, operating system and browser type.
You can browse our website without disclosing your personal data.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
1. Direct interactions. You may give us your Identity, Contact, Advice and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
Discuss our products and/or services with us, whether as a prospective customer
Deal with us as part of our services;
Engage us to provide services;
Subscribe to our newsletters or publications;
Request marketing to be sent to you;
Complete a survey;
Make a complaint; or
Give us some feedback.
2. Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
Advice Data, for example where we are dealing with other parties or organisation as part of your advice.
Marketing and Communications Data. We may on occasion use professional social media sites, such as LinkedIn, to contact you via that platform or share your content.
Technical Data from the following parties:
analytics providers such as Google based outside the EU and A1 Webstats; and
search information providers based inside the EU
Identity and Contact Data from data brokers or aggregators such as Creditsafe, GB Group and Accuity based inside the EU.
Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.
4. 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 in the following circumstances:
Where we are entering into or have entered into a contract for the supply of products and/or services 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.
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email. You have the right to withdraw consent to marketing at any time by using the "unsubscribe" link in our emails or by contacting us.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
We may use your Identity, Contact, Technical, Usage and Marketing and Communications Data to send you updates (by email, telephone or post) about us or legal developments that might be of interest to you and/or information about our services.
Where consent is needed (for example to send you electronic communications), we will ask for this consent separately and clearly.
We will always ensure that your personal data is treated with respect and we will never sell or share it with other organisations for marketing purposes.
We may ask you to confirm or update your marketing preferences over time, such as when you instruct us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.
Our website does not automatically store or capture personal data other than logging your IP address and other technical IT information. This information is retained after you have logged off for up to three months. We do not link information automatically logged by other means with personal data about specific individuals but we may link the automatically logged information with business information for business intelligence purposes.
The cookies used on this website help us to improve our website and to deliver a better and more responsive service.
CHANGE OF PURPOSE
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.
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.
You can ask us to stop sending you marketing messages at any time by following the unsubscribe links on any marketing message sent to you or by contacting us at any time.
5. DATA SECURITY
We have put in place appropriate technical and organisational measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. 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.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We do not give visitors to our website the option of using a secure transmission method to send us their personal data, unless otherwise indicated. Accordingly, your attention is drawn to the fact that any information carried over the Internet is not secure; information can be intercepted, lost, redirected, changed and read by other people. If you need to send us Personal Data securely then please contact us.
However, Seed Developments Ltd acknowledges your trust and is committed to protecting the information you provide to us. To prevent unauthorised access, maintain accuracy, and ensure proper use of information, we have employed physical, electronic, and managerial processes to safeguard and secure the information we collect online.
We use leading technologies and encryption software to safeguard your data and set strict security standards to prevent any unauthorised access to it.
The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA who work for one of our suppliers. Such staff maybe engaged in, among other things, the processing of your payment details.
6. DATA RETENTION
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.
By law we must keep basic information about our clients (including Contact, Identity, Financial and Transaction Data) for six years after our business relationship ends for tax purposes.
Regulation 40 of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 requires that we retain records and information obtained to complete due diligence for a period of five years after the end of our business relationship.
We are also required under our contract with you to keep Advice Data so that we, and our professional indemnity insurers, may to refer to it if you bring a claim against us. We will therefore retain such information for six years from the date of the closure of your matter.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
7. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
1. Request access to your personal data
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.
2. Request correction of your personal data
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us
3. Request erasure of your personal data
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
4. Object to processing of your personal data
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
5. Request restriction of processing your personal data
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.
6. Request transfer of your personal data
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
7. 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 wish to exercise any of the rights set out above, please contact us
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 several requests. In this case, we will notify you and keep you updated.
This policy will be reviewed at least annually by the Seed Development’s Data Protection Officer.
Date of last review: 24/10/2018
Approved by: Andrew Gould – Data Protection Officer