This policy together with our General Working Terms and Conditions provides information on how Interactive Data Technology Limited (also referred to in this notice as “IDT, we”, “us“ or our”) takes the privacy of its clients’ data very seriously. It sets out the basis on which any data we collect from you, that you provide to us, or that we collect from other sources about you, will be processed by us when you access our website, purchase products or services from us or via us, or make enquiries or otherwise communicate with us.
This policy was last updated May 2018
1. Who are we?
Interactive Data Technology Limited is a company registered in England and Wales with company number 03407803.
We are registered with the Information Commissioner’s Office, registration number: ZA370164
2. Responsibility for personal data
Our role as a processor:
In particular, if you have selected the relevant remote support service option, IDT will have remote access to your computer systems and the information which you store there. We may use such remote access without requesting further permission from you.
Our role as a Controller:
We also process some personal data as a Controller for certain purposes. Which means that we are primarily responsible for it and make decisions about how that personal data is used. This relates to how you use our service at a technical level, and for our own statistical analysis to help improve the service and where we use your contact details for marketing purposes. For example, we may collect information about your browser and computer operating system to allow us to provide an efficient browsing experience. We have set out how we process this type of personal data in more detail below.
3. Contact Details
We have appointed a Data Protection Compliance Officer who is responsible for overseeing questions in relation to this policy. If you have any questions about this policy, including any requests to exercise your legal rights, please contact us using the details set out below.
Our full details are: Interactive Data Technology Limited. Registered office: 56 Bostocks Lane, Derby DE72 3SX. Registered number 03407803. (England and Wales).
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.
5. What information does IDT collect
- Technical Data, including the Internet protocol (IP) address used to connect your computer to the internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website or for us to access your systems and any remote access codes.
- Identity Data includes: first name, last name, title and your login information.
- Contact Data includes billing address, delivery address, email address and telephone numbers, and the content of your communications such as information you give to us about you or your personnel, when requesting our products and services (including third party products), or if you or one of your personnel, speak to or communicate with one of our representatives and when you report a problem with our products and services.
- You can opt out of Google Analytics cookies – click here to opt-out.
- Financial Data includes bank account and payment details.
- Transaction Data includes details about payments to and from you and other details of products and 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.
6. Information IDT receives from other sources:
Outsourced Service Providers – to make our services efficient and robust, we outsource certain services such as the hosting services etc, and we may receive information about you from them.
We may collect or buy information from third parties about you. For example, if you purchase a third-party product or service, that third party may provide us with information it holds on you in order for us to provide support services to you, or facilitate your purchase or renewal of such services.
7. Sensitive Personal Data / Special Categories of Personal Data.
Unless we make it clear otherwise, our policy is not to ask for any sensitive personal data (also known as special categories of personal data and criminal offence data) from you (that is information about you, or your personnel’s) racial or ethnic origin, political opinions, religious beliefs, trade union activities, physical or mental health, sexual life, or details of criminal offences. We, and our outsourced service providers may, however, require certain sensitive personal data to provide our services to you, or to deal with your enquiries. For example, if you ask us to create an online account with a large service provider on your behalf, to comply with their anti-terrorism policies, it might be necessary to ask you to disclose any relevant background information that they require. In most cases we will do this as your processor and will not collect or process such data as a controller.
If you choose to provide this sensitive personal data to us as part of a particular service (where such information has been requested and the reasons for that discussed with you) or for any other reason, we will explain why we need that information and how we process it at the time you provide that information to us.
- Information about other people. If you provide information to us about any person other than yourself, such as your personnel, your clients or your suppliers, you must ensure that they understand how their information will be used and that they have given their permission for you to disclose it to us and for you to allow us, and our outsourced service providers to use it.
- Information from Clients 18 and Under. If you are aged 18 or under, you must obtain your parent or guardian’s permission beforehand to use our site, our telephone service, and to place orders and whenever you provide personal information to us. Users without this consent are not allowed to provide us with personal information.
You will find that it is not compulsory to provide us with any additional information we request which is not necessary or reasonable in order to provide you with the services you have requested.
8. How is your personal data used?
Where IDT acts as a processor:
The personal data that we collect and store relating to you is primarily used to enable us to provide our products and services to you, which we do as a processor under our contract with you and your organisation. In particular, as part of our services we will use personal data you provide to us
- To carry out our obligations arising from any contractual arrangements entered into between you and us, and to provide you with the information, products and services that you request from us.
- If you have selected the relevant service option, we may access your stored information strictly only for the purposes of providing you the services or products which you have requested.
- To notify you of changes to our services.
- To facilitate in our capacity as a reseller your purchase of certain third-party products and services (such as our Hosted Solutions e.g. Online Backup and Microsoft Office 365).
- We may combine the information you give to us with information which we collect about you and information which we collect from third parties about you. We may use this information and the combined information we collect about you for the purposes set out above. For example, if you purchase a third-party product or service, that third party may provide us with information it holds on you in order for us to provide support services to you or facilitate your renewal of such services.
We retain your data which we use to provide our services to you for such period as we have agreed with you.
Where IDT acts as a controller:
Where we process your personal data as a controller (meaning we use it for our own purposes) we will only use your personal data when the law allows us to. Most commonly, we will use your personal data as a controller in the following circumstances
- Where you have given us your consent.
- 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.
Please see the table below to find out more about the types of lawful basis that we will rely on to process your personal data as a controller.
If you have given us your consent for us to process your personal data, you have the right to withdraw consent by contacting us.
We have set out below a description of all 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.
Note that we may process your personal data for more than one legal basis depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest||Retention period (see further below)|
|To process and deliver our services:|
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(c) Provide support and services
|(a) Necessary for our legitimate interests (to recover debts due to us)|
(b) Maintain SLA’s.
|For the duration of our contract with you, and all amounts have been paid, plus 3 years|
|To manage our relationship with you which will include:|
(b) Asking you to leave a review or take a survey
(c) Marketing and Communications
|To administer and protect our business and our site and our services (including troubleshooting, data analysis, testing, system maintenance)||(a) Identity|
|(a) 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)||For the duration of our contract with you, and all amounts have been paid, plus 3 years|
|To use data analytics to improve our site, and our services, customer relationships and experiences||(a) Technical|
|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)||For the duration of our contract with you, and all amounts have been paid, plus 3 years|
|To make suggestions and recommendations to you about our services that may be of interest to you||(a) Identity|
(b) Necessary for our legitimate interests (to develop and our products and grow our business.)
|For the duration of our contract with you, and all amounts have been paid, plus 3 years|
|To keep information in compliance with our legal obligations.||(a) Legal||(a) [Legal obligation]||For the duration of our contract with you, and all amounts have been paid, plus the amount of time required by the Legal Obligation|
- If you have elected to receive it, we may send you our regular newsletter and we may contact you by electronic means (e.g. by e-mail or SMS/ text or push messages to your smartphone) with information about goods and services of ours which are similar to those which you have purchased or negotiated with us about previously. If you have agreed that we may do so, we may also use your personal data to contact you by electronic means with information about other products and services of ours;
Where consent is needed (for example to send you electronic communications) we will ask for this consent separately and clearly.
We will always ensure your personal data 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.
Opting out of marketing
You may make a request to us at any time via letter or email to: firstname.lastname@example.org to be removed from any marketing databases or future marketing communication, in which case we will immediately perform the task and confirm back to you.
Change of purpose
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
10. Disclosure of your Information
We may have to share your personal data with the parties set out below
- If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of service and other agreements; or to protect the rights, property, or safety of IDT, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of managing our credit risk, fraud protection and the protection of minors. If we are requested by the police or any other regulatory or government authority investigating suspected illegal activities to provide your personal information, we may be obliged to do so.
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.
The data that we collect from you is processed by staff who work either for us, or for one of our outsourced service providers. Such individuals or organisations may be engaged in, among other things, the fulfilment of your services, the processing of your payment details and the provision of support services. We take reasonable steps to ensure that our staff and suppliers protect your information and are aware of their information security obligations. For example, each of our staff members sign a confidentiality agreement to govern and limit disclosure of client sensitive information to any third parties, and all staff are provided with guidance on how to deal with personal information.
We are not responsible for the privacy practices of any external websites to which we have created links.
We do not sell, rent or trade your personal information to third parties for marketing purposes. We may, however, pass your primary contact details (email address and phone number) to a trusted third party who you have asked us to provide your details to.
Where your personal information is disclosed to any of our outsourced service providers for these purposes, they will only have access to the information needed to perform their functions, and our contractual arrangements with them do not permit them to use your personal information for their own purposes. We also take reasonable steps to help ensure that they will keep the information secure and confidential and that they will process it in compliance with applicable data protection legislation.
11. Storing Your 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. Any personal data that is provided to us is stored on our secure servers and/or those of the service provider hosting our site on our behalf.
Please note that given the nature of the internet, data transmitted over the internet or by email is not completely secure from unauthorised access or misuse.
A summary of the security measures is provided below
- Prevent unauthorised persons from gaining access to data processing systems in which personal data are processed.
- Prevent persons entitled to use a data processing system from accessing personal data beyond their needs and authorisations.
- Ensure that personal data in the course of electronic transmission during transport cannot be read, copied, modified or removed without authorisation.
- Ensure that access logs are in place to establish whether, and by whom, the personal data was entered into, modified on or removed from a data processing system.
- Ensure that in the case where processing is carried out by a Data Processor, the data can be processed only in accordance with the instructions of the Data Controller.
- Ensure that personal data is protected against undesired destruction or loss.
- Ensure that personal data collected for different purposes can and is processed separately.
- Ensure that personal data is not kept longer than necessary.
- Ensure that personal data is stored on our secure servers and key information such as usernames, passwords, encryption keys etc are themselves encrypted.
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 will retain your information only for as long as it is necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements. As referenced above.
Please note that the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk
12. Your rights
Under certain circumstances, and depending on our relationship with you as a controller or processor, you have rights under data protection laws in relation 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 held about you.
- Request correction of your personal data that is held about you. This enables you to have any incomplete or inaccurate data held about you corrected, however the accuracy of the new data you provide may need to be verified.
- Request erasure of your personal data. You can ask for your personal data to be deleted or removed 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. 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 your personal data. This enables you to ask that processing of your personal data to be suspended in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where use of the data is unlawful but you do not want it to be erased; (c) where you need the data to be held even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to the use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request transfer of your personal data to you or to a third party. You can ask to be provided with, or that a third party you have chosen is provided with, 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.
- Right to withdraw consent 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.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
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 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. 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.
Cookies are files, often including unique identifiers, that are sent by web servers to web browsers, and which may then be sent back to the server each time the browser requests a page from the server.
Cookies can be used by web servers to identify and track users as they navigate different pages on a website and to identify users returning to a website.
Cookies may be either “persistent” cookies or “session” cookies. A persistent cookie consists of a text file sent by a web server to a web browser, which will be stored by the 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 on this website
We may use the information we obtain from your use of our cookies for the following purposes:
(1) to track visitors as they navigate our website
(2) to improve the website’s usability
(3) to analyse the use of our website
(4) in the administration of this website
Most browsers allow you to refuse to accept cookies. For example:
(1) in Internet Explorer you can refuse all cookies by clicking “Tools”, “Internet Options”, “Privacy”, and selecting “Block all cookies” using the sliding selector;
(2) in Firefox you can block all cookies by clicking “Tools”, “Options”, and un-checking “Accept cookies from sites” in the “Privacy” box
You can also delete cookies already stored on your computer:
(1) in Internet Explorer, you must manually delete cookie files;
(2) in Firefox, you can delete cookies by, first ensuring that cookies are to be deleted when you “clear private data” (this setting can be changed by clicking “Tools”, “Options” and “Settings” in the “Private Data” box) and then clicking “Clear private data” in the “Tools” menu.
Obviously, doing this may have a negative impact on the usability of many websites.
If you have any queries in relation to this policy or the processing of your personal data by us, please contact us using the following contact details:
F.A.O Data Protection Compliance Officer
Interactive Data Technology Limited.
Meadow View House
56 Bostocks Lane,
DE72 3SX. Registered number 03407803. (England and Wales).
+44 115 968 4949