Privacy & Terms

Proxymity and data privacy

PROXYMITY WEBSITE PRIVACY POLICY

This policy

This is Proxymity Limited’s (“Proxymity” or “we/us/our“) privacy policy that explains who we are, why and how we process your personal information (also referred to here as personal data) and your rights and how to contact us if you need to.

 

Our contact details are set out at the end of this policy. We are the controller in relation to the personal data processed in accordance with this policy (except where this policy explains otherwise).

 

This policy sets out:

 

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

Information we collect about you

This is information about you that you give to us by:

  • filling in forms on our websites, being proxymity.io, (or other forms that we ask you to complete);
  • giving us a business card (or similar); or
  • corresponding with us by telephone, post, email or otherwise.

It may include, for example, your name, address, email address and telephone number, information about your business relationship with Proxymity, and information about your professional role, background and interests.

Information that our website and other systems collect about you:

  • If you visit our website it will automatically collect some information about you and your visit, including the internet protocol (IP) address used to connect your device to the internet and some other information such as your browser type and version and the pages on our site that you visit.
  • If you exchange emails, telephone conversations or other electronic communications with our employees and other staff members, our information technology systems will record details of those conversations, sometimes including their content.

 

Information we collect from you or from a third party

We may process your personal data that we have either obtained from you, or obtained from somewhere else. Personal data which is not collected directly from you may be collected if we have a business relationship with the organisation that you represent, your colleagues or other business contacts may give us information about you such as your contact details or details of your role in the relationship.

Personal data relating to you that we process may include:

 

  • Your name.
  • Who you work for, and your job function or department.
  • Your address, phone number, email address or other contact details (these details may relate to your work or to you personally, depending on the nature of our relationship with you or the company that you work for).
  • Information about you that you give us by communicating with us by phone, by e-mail, via our website, via social media or otherwise. It includes information you give us or that we obtain when you use our website, obtain or subscribe to our goods or services, supply us with goods or services, enquire about a product, place an order, enter a competition, promotion or survey, or contact us to report a problem, or do any of these things on behalf of the person that you work for.
  • Information relating to transactions with us involving you or the company you work for (for example, details of goods or services that we have supplied to, or obtained from, you or the person you work for).
  • Other information relating to you which it is necessary for us to process in order to enter into or perform a contract with the company you work for.
  • Information about events to which you or your colleagues are invited, and your personal information and preferences to the extent that this information is relevant to organising and managing those events (for example, your dietary requirements).
  • Where you have requested information from us, your contact information in order to provide you with any such information, and other other information that you give to us, such as a short bio.

 

 

Information that we obtain from you when you use our Website may include:

  • Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform
  • Information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our website (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number or social media handle used to connect with our customer service team.
  • Location data – we may collect information through our website as to your real time location to provide location services where requested or agreed to by you in order to allow tagging, ][allow check-in and deliver content, advertising or other services that are dependent on knowing where you are. This information may also be collected in combination with an identifier associated with your device to enable us to recognise your mobile browser or device when you return to the website.

Delivery of location services may involve reference to one or more of the following: (a) the coordinates (latitude/longitude) of your location; (b) look-up of your country of location by reference to your IP address against public sources; and/or (c) your Identifier for Advertisers (IFA) code for your Apple device, or the Android ID for your Android device, or a similar device identifier. See our cookie policy for more information on the use of cookies and device identifiers on the site.

 

Cookies and other technologies

 

Our use of cookies and other similar technologies to process personal data is explained in our cookie policy, which you should please read.

 

How we use your information

 

Information you give to us:

We will use this information to:

  • Take steps in order to enter into any contract or carry out our obligations arising from any contract entered into between you or the company you work for and us including:
    • supplying goods and services to you or the company you work for or receiving them from you or the company you work for, as the case may be;
    • administering your company’s account with us;
    • your emails and other communications being occasionally accessed by persons other than the member of staff with whom they are exchanged for ordinary business management purposes (for example, where necessary when a staff member is out of the office;
    • where you have requested information from us, to provide you with any such information;
    • notifying you about changes to our service.
  • Provide you with information about our products or services we feel may interest you or the company you work for, if you have given your consent to receiving marketing material from us at the point we collected your information (where required), where required by law or otherwise in our legitimate interests provided these interests do not override your right to object to such communications. See ‘Our promotional updates and communications’.
  • Ensure in our legitimate interests that:
    • content from our site is presented in the most effective manner for you and for your computer;
    • we protect our business from fraud, money-laundering, breach of confidence, cyber attack, theft of proprietary materials and other financial or business crimes;
    • we comply with our legal and regulatory obligations and bring and defend legal claims;
    • we provide you or the company you work for with the information, products and services you request from us.

Information we collect about you from your use of our website

We will use this information in our legitimate interests, where we have considered these are not overridden by your rights:

  • To administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
  • To keep our site safe and secure.
  • To provide you with the information, products and services that you request from us.
  • For measuring or understanding the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you.
  • To improve our site to ensure that content is presented in the most effective manner for you and for your computer.
  • To allow you to participate in interactive features of our service, when you choose to do so.

Information we receive from other sources

We may combine this information with information you give to us and information we collect about you in our legitimate interests (where we have considered that these are not overridden by your rights). We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).

 

You can see a summary of which data we process for what purposes and the lawful basis for such processing at the bottom of this page.

 

Our promotional updates and communications

Where permitted in our legitimate interest or with your prior consent where required by law, we will use your personal information for marketing analysis and to provide you with promotional update communications about our products or  services.

You can object to further marketing at any time by checking and updating your contact details within your account, or selecting the “unsubscribe” link at the end of all our marketing and promotional update communications to you, or by sending us an email to marketing@Proxymity.io.

 

Who we give your information to

 

We may share your personal data with:

 

  • Any other companies associated with Proxymity, [which means our subsidiaries, our ultimate holding company and its subsidiaries, who support our processing of personal data under this policy. If any of these parties are using your information for direct marketing purposes, we will only transfer the information to them for that purpose with your prior consent.
  • Your colleagues within the organisation that you represent;
  • Appropriate third parties including:

 

  • our business partners, customers, suppliers and sub-contractors for the performance of any contract we enter into or other dealings we have in the normal course of business with you or the person that you work for;

 

  • our auditors, legal advisors and other professional advisors or service providers;

 

  • In relation to information obtained via our website analytics and search engine providers that assist us in the improvement and optimisation of our site and subject to the cookie section of this policy.

 

 

Other disclosures we may make

 

We will disclose your personal information to third parties:

  • In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets subject to the terms of this privacy policy.
  • If Proxymity or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
  • 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 supply terms and other agreements with you or the company you work for; or to protect the rights, property, or safety of Proxymity, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction and to prevent cybercrime.

Where do we store your information?

 

The disclosures referred to above may involve transferring your personal information overseas. If you are dealing with us within the European Economic Area (or the UK, after it has left the European Economic Area), you should be aware that this may include transfers to countries outside the European Economic Area / UK, which do not have similarly strict data privacy laws.  It may also be processed by staff situated outside the EEA who work for us or for one of our suppliers. In those cases, where we transfer personal data to other members of the Proxymity group or our service providers, we will ensure that our arrangements with them are governed by data transfer agreements or mechanisms, designed to ensure that your personal information is protected (including, where appropriate, under an agreement on terms approved for this purpose by the European Commission).

 

  • In order to store it.
  • In order to enable us to provide goods or services to and fulfil our contract with you or the company your work for. This includes order fulfilment, processing of payment details, and the provision of support services.
  • Where we are legally required to do so.
  • In order to facilitate the operation of our group of businesses, where it is in our legitimate interests and we have concluded these are not overridden by your rights.

 

 

How we protect your information

All information you provide to us is stored on our secure servers. Unfortunately, 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. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Our website may, from time to time, contain links to external sites. We are not responsible for the privacy policies or the content of such sites.

 

How long we keep your information

 

We retain personal data for as long as you have an account with us in order to meet our contractual obligations to you and for six years after that to identify any issues and resolve any legal proceedings. We keep personal data for marketing purposes for two years from the date of our last contact with you. We may also retain aggregate information beyond this time for research purposes and to help us develop and improve our services. You cannot be identified from aggregate information retained or used for these purposes.

Your rights

 

You have the right under certain circumstances:

  • to be provided with a copy of your personal data held by us;
  • to request the rectification or erasure of your personal data held by us;
  • to request that we restrict the processing of your personal data (while we verify or investigate your concerns with this information, for example);
  • to object to the further processing of your personal data, including the right to object to marketing (as mentioned in ‘Our promotional updates and communications’ section;
  • to request that your provided personal data be moved to a third party.

 

You may opt out at any time from allowing further access by us to your location data by emailing Marketing@Proxymity.io

 

Your right to withdraw consent:

 

Where the processing of your personal information by us is based on consent, you have the right to withdraw that consent without detriment at any time by contacting us . You can also change your marketing preferences at any time as described in ‘Our promotional updates and communications’ section;

 

How to exercise your rights

 

You can also exercise the rights listed above at any time by contacting us at Marketing@Proxymity.io

 

If your request or concern is not satisfactorily resolved by us, you may approach your local data protection authority, (see http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.html ). The Information Commissioner is the supervisory authority in the UK and can provide further information about your rights and our obligations in relation to your personal data, as well as deal with any complaints that you have about our processing of your personal data.

 

Changes to this policy

Any changes we make to our privacy policy in future will be posted on our website at www.proximity.io/privacy and, in relation to substantive changes, will be notified to you by e-mail. This policy was last updated on 1st May 2020.

 

Contact us

 

Purpose and lawful basis for processing of personal data

 

This table sets out:

 

  • What personal data we process
  • What we use that data for
  • The lawful basis for the processing

 

It forms part of our privacy policy which you should also read.

 

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
Collecting data from you as a prospective client

 

(a) Identity

(b) Contact

 

Performance of a contract with you

 

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

 

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

 

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

 

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

 

(a) Identity

(b) Contact

(c) Technical

 

(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)

(b) Necessary to comply with a legal obligation

 

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

 

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

 

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

 

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

 

(a) Technical

(b) Usage

 

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)

 

To make suggestions and recommendations to you about goods or services that may be of interest to you (a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

Necessary for our legitimate interests (to develop our products/services and grow our business)