Introduction and purpose

Satori Risk Limited Company Number 13097279, Registered address 10 4th Floor, Dominion Street, London, England, EC2M 2EF (collectively referred to as “we”, “us” or “our” in this policy) are committed to safeguarding the privacy of website visitors.

This policy explains how we will collect and process personal information through your use of this website, which includes any data you may provide when you purchase a product or service, or otherwise provide any data to us.

We seek your consent to our use of cookies in accordance with the terms of this privacy and cookie policy when you first visit our website.

It is important that you read this privacy and cookie policy, together. This privacy and cookie policy supplements the other notices and is not intended to override them.

This website is not intended for those under the age of 18, and we do not knowingly collect data relating to children.

Controller and third party links

We are the controller and responsible for your personal data.

For questions about this privacy policy (including any requests to exercise your legal rights) please contact us by either:

post at Building 220 Wharfedale Rd, Winnersh, Wokingham RG41 5TP; or

email at info@satoririsk.com quoting Privacy Policy Question

Your right to make a complaint at any time to the Information Commissioner’s Office (ICO) is described below, the UK supervisory authority for data protection issues (www.ico.org.uk). We would appreciate the chance to deal with your concerns before you approach the ICO, please contact us in the first instance.

This website 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, you should read the privacy policy of every website you visit.

Personal data and collection

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 or anonymised data.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped in the following Data sets:

Identity includes first, maiden, last name, username or similar identifier, marital status, title, date of birth and gender.

Contact includes billing address, delivery address, email address and telephone numbers.

Financial includes bank sort code, account and payment card details.

Transaction payments details, to and from you and other details of products and services you have purchased.

Technical includes internet protocol (IP) address, 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 includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.

Usage includes information about how you use our website, products and services, including traffic data.

Marketing and Communications Data refers to your preferences in receiving marketing from us and our third parties and your communication preferences.

Special Categories of Personal Data 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). We do not collect any information about criminal convictions and offences.

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel a product or service you have with us; however we will notify you if this is the case at the time.

Personal data collection methods

We use different methods to collect data from and about you including through:

Direct interaction. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide if you:

apply for our products or services | create an account on our website | subscribe to our service or publications | request marketing to be sent to you | give us your business card | enter a competition, promotion, or survey |give us some feedback.

Automated technologies or interactions. By interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.

Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:

Technical Data from the following parties:

  • analytics providers such as Google based inside OR outside the EU;

  • advertising networks based inside OR outside the EU; and

  • search information providers based inside OR outside the EU.

  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services based inside OR outside the EU.

  • Identity and Contact Data from data brokers or aggregators based inside OR outside the EU.:

  • Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside OR outside the EU;

Use of 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 ways:

In performing the contract we are about to enter into or have entered into with you.

Necessary for our legitimate interests and your interests and fundamental rights do not override those interests, this includes those of a third party.

Complying with a legal or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your personal data other than:

  • (a) if you are not our existing customer or represent a corporate business, and you have given us your business card; or

  • (b) 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.

The below describes the 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.

PURPOSE/ACTIVITY

TYPE OF DATA

LAWFUL BASIS FOR PROCESSING INCLUDING BASIS OF LEGITIMATE INTEREST

Registering a customer, administering an account and manage the relationship with you

(a) Identity

(b) Contact

(a) Performance of a contract with you

(b) To administer your account and manage the relationship with you

Representative of a business / organisation, to manage the relationship with that business or to discharge our contractual obligations

(a) Identity

(b) Contact

(c) Transaction

(a) Manage our relationship with the business you represent, and to discharge our contractual obligations to the business who referred your business to us)

(b) To manage their relationship with us

To process and deliver your order including:

(a) Managing communications

(b) Managing payments etc.

(c) Preventing and detecting fraud

(d) Collecting and recovering money owed to us and enforcing our legal rights

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Usage

(f) Marketing and Communications

(a) Performance of a contract with you

(b) Legal obligation by providing accurate billing information

(c) Prevention and detection of fraud

Recovering debts due to us or otherwise enforcing our legal rights

To manage the relationship with you:

(a) Notification re changes to our terms or privacy and cookie policy

(b) Requesting reviews or take a survey

(c) Enquiries and complaints

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

(e) Financial

(f) Transaction

(g) Usage

(a) Performance of a contract with you

(b) Compliance with a legal obligations (providing accurate billing information and handling complaints)

(c) Keeping records updated and to study how customers use our products/services

Promotion or completion of a survey

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(a) Contract performance reviews

(b) To review how customers use our products/services, to develop them and grow our business

Administration and protection of the business and website including resolving issues, data analysis, testing, system maintenance, support, reporting and hosting of data

(a) Identity

(b) Contact

(c) Technical

(a) 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)

(b) Compliance with a legal obligation

To deliver relevant website content and advertisements , and measure effectiveness

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

Research how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy

Ude of data analytics to improve the website, products/services, marketing, customer relationships and experiences

(a) Technical

(b) Usage

Use of analytics to assess the visitor volume, posts, page views, reviews and followers in order to optimise future marketing campaigns

Provide recommendations about goods or services that may be of interest to you

(a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

To develop our products/services and grow our business

Marketing – So that we can offer choices to you we have established the following personal data control mechanisms:

Promotional offers – we may use your Identity, Contact, Technical, Usage and Profile Data to decide what we think you may want, need or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (marketing). You will receive marketing communications from us if you have requested information from us or purchased goods or services, provided us with your details, in all noted cases, you have not opted out of receiving that marketing.

Prospective clients – if you are not an existing customer or represent a corporate business and you have given us your business card because you are happy to hear from us, we may use your Identity and Contact Data to form a view on what we think you may want or need, or what may be of interest to you.

Third-party marketing – we will obtain your express opt-in consent before we share your personal data with any other company for marketing purposes;

Opting out – you can request that we or third parties to stop sending marketing material and communications at any time by contacting us. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

We will only use your personal data for the purposes for which we collected it, with the exception being that if 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.

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.

Disclosing personal data

We may be required to share your personal data with other parties set out below for the purposes set out in above:

Marketing services providers based in the United Kingdom who provide direct marketing services to us.

Payment services providers based in the United Kingdom who provide payment services to us.

Businesses who referred your business to us.

Professional advisers acting as processors including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.

HM Revenue & Customs, regulators and other authorities based in the United Kingdom.

Third parties such as companies we may be acquired by, transfer, or merge parts of our business or our assets. Also, we may seek to acquire other businesses or merge with them. If a change happens to our business, the new owners may use your personal data in the same way as set out in this privacy and cookie policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. Third-party service providers are prohibited from using your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Transfer of data internationally

Information that we collect may be stored and processed in and transferred between any of the countries in which we operate in order to enable us to use the information in accordance with this privacy and cookie policy.

Whenever we transfer your personal data out of the EEA, we ensure a commensurate degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will only transfer your personal data to countries that have been deemed to provide an sufficient levels of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries

If we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. See European Commission: EU-US Privacy Shield

You expressly agree to the transfers of personal information described in this paragraph 7.

Personal information that you publish on our website or submit for publication on our website may be available, via the internet, around the world. We cannot prevent the use or misuse of such information by others.

Securing personal data

We have put in place appropriate security 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.

You acknowledge that the transmission of information over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.

You are responsible for keeping the password you use for accessing our website confidential; aside from when you log into our web portal on the website we will not ask you for your password.

Retention of personal information

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, which includes:

Legal

Accounting

Reporting requirements

To decide the right retention period for personal data, we assess several factors including the amount, sensitivity, criticality and nature, of the personal data, the potential risk from unauthorised use or disclosure of personal data, why we process your personal data and if we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances we may anonymise your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Updating information

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.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data, details contained in this policy

Request access to your personal data”.

Request correction of your personal data”.

Request erasure of your personal data”.

Object to processing of your personal data”.

Request restriction of processing your personal data”.

Request transfer of your personal data”.

Right to withdraw consent”.

If you wish to exercise any of the rights set out above, contact us by email at info@satoririsk.com quoting My Legal Rights Question with details of your request or by writing to us at Satori Risk, Building 220 Wharfedale Rd, Winnersh, Wokingham RG41 5TP.

You will not usually have to pay a fee to access your personal data, or to exercise any of the other rights). However, we may charge a fee if your request is unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances;

We may request information from you to allow us to 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 unauthorized person. We may also contact you to ask you for further information in relation to your request to speed up our response; and we attempt to respond to all legitimate requests within one month. If for any reason it takes longer than one month, we will notify you of this.

About cookies

The website uses cookies to identify you from other users. A cookie is a small file of letters and numbers, if you agree we will store on your browser or the hard drive of your computer. Cookies contain information that is transferred to your computer’s hard drive. This helps us to provide you with a satisfactory experience when you browse our website, furthermore it allows us to improve our site. By continuing to browse the site, you are agreeing to our use of cookies.

Cookies may be either “persistent” cookies or “session” cookies:

A persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date

A session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

Cookies can be used by web servers to identify and track users as they navigate different pages on a website and identify users returning to a website.

We use session and persistent cookies on the website. If you want to block cookies, this is done by activating the setting on your browser that allows you to refuse the setting of all or some cookies.

However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.

We use the following cookies:

Strictly necessary cookies – these are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing service;

Analytics/performance cookies – they allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily;

Functionality cookies – these are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region);

Targeting cookies – these cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

Analytics cookies: We use Google Analytics to analyse the use of our website. Our analytics service provider generates statistical and other information about website use by means of cookies. The analytics cookies used by our website have the following names: [_ga, _gat, __utma, __utmt, __utmb, __utmc, __utmz and __utmv]. The information generated relating to our website is used to create reports about the use of our website. Our analytics service provider’s privacy policy is available at: https://policies.google.com/privacy?hl=en

Third party cookies: Our website may use third party cookies. A common example is an embedded YouTube video. Details of the other third-party cookies used by our website are set out below:

To review our Cookie Policy click here

Amendments

We may update this policy from time to time by publishing a new version on our website.

This version was last updated on [Add date of publish here] and historic versions can be obtained by emailing us at info@satoririsk.com.

You should check this page occasionally to ensure you are happy with any changes to this policy.

We may notify you of changes to this policy by email or through the private messaging system on our website.

Glossary

Lawful Basis

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

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.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Your Legal Rights

You have the right to:

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.

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.

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.

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.

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.

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.

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.

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