1. Who are we?
Full name of legal entity: Special iApps C.I.C. (CRN: 07585386)
Email address: firstname.lastname@example.org
Postal address: Portland House, Belmont Business Park, Belmont, Durham, United Kingdom, DH1 1TW
Telephone number: +44 (0) 191 389 6638
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.
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 by contacting email@example.com.
3. Third-party links
4. 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 the identity has been removed (anonymous data).
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 and last name, work role and organisation where you work (where relevant);
- Contact Data includes address, email address and telephone numbers;
- Technical Data includes internet protocol (IP) address, browser type, device type and language settings; and
- Usage Data is limited to information about registration (required in order to download free resources) and, only to the extent necessary, to enforce product licensing.
We may also collect, use and share anonymous aggregated data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific feature of the Site.
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. If any communication you send to us includes details of any health or medical condition or any special needs of any person we will not process that information other than to answer any specific query from you and emails will be retained in line with our retention policy.
5. If you fail to provide personal data
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 (for example, to provide you with digital content). 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.
6. How is your personal data collected
We use different methods to collect data from and about you including through:
6.1 Direct interactions. You may give us your Identity, Contact and Profile Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when:
6.1.1 you visit our Site;
6.1.2 you sign up to a free trial or subscribe to an App; or
6.1.3 you subscribe to our mailing list;
6.1.4 you register to download add-on resources;
6.1.5 you report a problem with an App or Site;
6.1.6 you request promo codes for an App;
6.1.7. we meet you at a conference, exhibition or workshop;
6.1.8 you contact us using our Contact Us section of the Site.
7. Reasons why we use your personal data and our lawful bases for processing
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 you have consented before the processing.
- Where we need to perform a contract we are about to enter or have entered 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.
We have set out below, in a table format, the ways we use your personal data, and what our legal justification is for doing so. We have also identified what our legitimate interests are when appropriate.
Type of Data
Lawful basis for processing
To register you for a free trial period
To register you as a new App user where one of our Apps is installed from an App store (such as Google Play, the App Store or the Amazon App Store), and you choose to register this App
Performance of a contract
To install an App and register you as a new App user where you install an App from our Site
Performance of a contract
To manage our relationship with you including notifying you of changes to an App or any Services
Performance of a contract with you
Necessary for our legitimate interests (to keep records updated and to analyse how customers use our products / Services)
Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions)
To communicate with you by email, if required or requested
Performance of a contract with you
To administrate any training workshops that you have signed up for, including contacting delegates who will attend the training
Performance of a contract with you
Legitimate interests (to ensure that our training is properly administrated)
To use data analytics to improve our Site and customer experience
Necessary for our legitimate interests (to deliver and improve our services)
To inform you of new products and/or services
To improve our training and customer experience through the use of questionnaires
Legitimate interests (to analyse and improve our performance and training)
8. Third-party marketing
We do not share your personal data with any third party for marketing purposes.
10. Disclosures of your personal data
We share your personal data with the parties set out below:
10.1 With our mailing list and product registrations platform provider, MailChimp (based outside the EEA).
10.2 With our customer relationship management provider, Salesforce.com (based outside the EEA).
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use 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.
11. International transfers
Some of our third parties may process our personal data outside of the European Economic Area (EEA) such as email providers. We review the data protection terms of these suppliers to ensure that your personal data will only be transferred outside of the EEA, if sufficient appropriate safeguards are in place.
12. Data Security
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 will notify you and any applicable regulator of a breach where we are legally required to do so.
13. Data Retention
We will only retain your personal data for as long as necessary to fulfil the purposes we collect 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.
Details of retention periods for different aspects of your personal data are set out below:
Type of Data
Length of time
Website and email queries and corresponding contact details
Information contained within any communications you send to us
Email Addresses, postal addresses, names, phone details and any other information provided to us as part of the sign-up process
7 years after the end of your subscription to any of our Apps (or 7 years from the end of any free trial period, where you do not then subscribe to the relevant App)
14. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. 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:
- If you want us to establish the data's accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- 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.
- 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.
16. Contact us