Website Privacy Notice
1. Background
1.1.
This notice (Privacy Notice) tells you how we look after your personal data when you visit our website at setyl.com (Website), where you are a prospective customer of our business, or where you are another type of business contact, such as a supplier or service provider.
1.2.
This notice sets out what information we collect about you, what we use it for, and whom we share it with. It also explains your rights under data protection law and what to do if you have any concerns about your personal data.
1.3.
This Privacy Notice covers our role as controller of the personal data described here. Where we process personal data on behalf of our customers as a processor (for example, personal data our customers upload to the Setyl platform), that processing is governed by our agreement with the relevant customer, and that customer’s own privacy notice applies.
1.4.
We may need to update this Privacy Notice from time to time to reflect changes in our practices or legal requirements. Please check it regularly.
2. Who we are and other important information
2.1.
We are SETYL LTD, registered in England and Wales with company number 12677958, with our registered address at St James House, St James Road, London, KT6 4QH, UK (we, us or our).
2.2.
For all visitors to our Website, we are the controller of your information (meaning we decide what information we collect and how it is used).
2.3.
We are registered with the Information Commissioner’s Office (ICO), the UK data protection regulator, under number ZA798244.
3. Contact details
3.1.
If you have any questions about this Privacy Notice or the way we use your information, please contact us:
Email: hello@setyl.com
Post: St James House, St James Road, London, KT6 4QH, UK
4. The information we collect about you
4.1.
Personal data means any information which does (or could be used to) identify a living person. The types of personal data we collect are grouped below.
4.2.
Types of personal data:
Identity Data: your first and last name, or title.
Contact Data: your email address, telephone number and postal address.
Technical Data: IP address, browser type and version, time zone setting and general location, browser plug-in types and versions, and the operating system and platform of the devices you use to access our systems.
Usage Data: information about how you use our systems.
Financial Data: where you provide this via our Website to purchase a product or service.
Location Data: your device location if you log into our systems remotely.
Feedback: information and responses you provide when completing surveys and questionnaires.
Photo and Image Data: profile picture, images, videos and audio.
Profile Data: email address, password, username, chat logs, and audit trail of systems used and documents accessed or downloaded.
Marketing and Communication Data: your preferences in receiving marketing from us and third parties, and your communication preferences.
5. How we use your information
5.1.
We are required to identify a legal basis for collecting and using your personal data. The bases most relevant to us are where we use your personal data to: fulfil our contract with you; comply with a legal obligation; pursue our legitimate interests (our justifiable business aims), where these are not outweighed by your rights and freedoms; or where you have given your consent.
5.2.
The lawful bases we rely on are set out below. If we intend to use your personal data for a new reason not listed here, we will update this Privacy Notice.
5.2.1.
Contract — to administer and perform our contract with you; to process your payment information; and to send you updates about the services you have bought.
5.2.2.
Legal obligation — to record your preferences (e.g. marketing) to comply with data protection law; to send you information required by law; and to retain information to bring or defend legal claims.
5.2.3.
Legitimate interests — to improve and optimise our Website; to monitor and improve security and prevent fraud; to provide our services and ensure the proper functioning of our Website; and to protect and defend our business. Where we rely on legitimate interests, we assess that our use is necessary and does not unfairly infringe your rights and freedoms.
5.2.4.
Consent — where you have consented to provide us with information, to our use or sharing of it, or to receiving marketing from us.
5.3.
Where we need to collect personal data to fulfil a contract with you, failure to provide it may mean we cannot provide the service, and we may have to cancel it.
6. Cookies
6.1.
Our Website uses cookies and similar technologies to enable core functionality, remember your preferences, understand how the Website is used, and support our marketing. You can manage your preferences through the cookie settings on our Website. Where cookies are not strictly necessary, we set them only with your consent. For full details of the cookies we use, see our Cookie Policy at setyl.com/legal.
7. Who we share your information with
7.1.
We share (or may share) your personal data with:
Our personnel: employees and other workers who are bound by confidentiality and data protection obligations.
Our supply chain: organisations that help us provide our services, which only have access to the information they need and are bound by contract to protect it.
Regulatory authorities: such as HM Revenue & Customs.
Our professional advisers: such as our accountants and legal advisers.
Business transfers: a buyer or successor if we sell or reorganise our business, in which case we will require them to protect your personal data.
7.2.
If we are asked to provide personal data in response to a court order or legal request (e.g. from the police), we will seek legal advice before disclosing anything and consider the impact on your rights.
8. Where your information is located and transferred to
8.1.
We store your personal data on servers in the UK and EU region, with appropriate mechanisms in place to ensure any transfer complies with data protection law.
8.2.
We will only transfer information outside the UK or EEA where we have a valid legal mechanism in place to ensure it is protected — for example, by transferring to a country covered by UK adequacy regulations, or by using contracts approved by the ICO (such as the International Data Transfer Agreement).
8.3.
If you access our Website from abroad, your personal data may be stored on servers in the same country as you or your organisation.
9. How we keep your information safe
9.1.
We have implemented security measures to prevent your personal data from being accidentally or unlawfully lost, used or accessed without authorisation. These include:
access controls and user authentication (including multi-factor authentication);
internal IT and network security;
regular testing and review of our security measures;
staff policies and training;
incident and breach reporting processes; and
business continuity and disaster recovery processes.
9.2.
If an incident affects your personal data and we are the controller, we will notify the regulator and keep you informed where required by law. Where we act as processor, we notify the relevant controller and support their response.
9.3.
If you notice any unusual activity on the Website, please contact us at hello@setyl.com.
10. How long we keep your information
10.1.
Where we are the controller, we retain your personal data only for as long as necessary for the purposes we collected it for.
10.2.
To decide how long to keep personal data, we consider its volume, nature and sensitivity, the potential risk of harm from unauthorised use, whether we can achieve our purposes by other means, and any applicable legal requirements.
10.3.
We may keep Identity Data, Contact Data and related correspondence for up to seven years after the end of our contractual relationship with you.
10.4.
If you browse our Website, we keep personal data collected through our analytics tools only for as long as necessary.
10.5.
If you have asked for information or subscribed to our mailing list, we keep your details until you ask us to stop contacting you.
11. Your legal rights
11.1.
You have specific rights in relation to your personal data.
11.2.
We may decline to act on a request where we cannot confirm your identity, or where we consider the request to be manifestly unfounded or excessive; in the latter case we may charge a reasonable fee or refuse the request, and we will explain our decision in writing.
11.3.
We will respond without undue delay and within one month of receiving your request (or confirming your identity, if later). We may extend this by two months for complex or multiple requests, and will let you know if we do.
11.4.
We do not respond directly to requests relating to personal data for which we act as processor; we forward these to the relevant controller and await their instructions.
11.5.
To exercise any of the rights below, contact us at hello@setyl.com.
11.6.
Your rights include:
Access: to be told whether your personal data is being used, and to receive a copy of it and information about how we use it.
Correction: to have inaccurate or incomplete personal data corrected.
Deletion: to have your personal data deleted where there is no good reason for us to keep it.
Restriction: to ask us to temporarily limit how we use your personal data.
Objection: to object to our use of your personal data.
Portability: to receive, or have us send to another organisation, an electronic copy of your personal data.
Complaints: to complain to the ICO (ico.org.uk) or another relevant supervisory authority — though we hope you will contact us first at hello@setyl.com so we can address your concerns.
12. When we send you marketing messages
12.1.
If you have consented to receive marketing from us, you can opt out at any time by contacting hello@setyl.com.
12.2.
We market to prospective and existing business customers (Business-to-Business, or B2B Marketing), and may send marketing to staff via work contact details. If you are a member of staff and do not wish to receive B2B Marketing, please let us know at hello@setyl.com.
12.3.
Opting out of marketing does not affect our processing of your personal data in relation to any order you have with us.
13. Profiling
13.1.
Our processing may include profiling — the automated processing of personal data to assess certain characteristics of an individual — in order to better tailor direct marketing and other communications to your interests. This does not produce legal or similarly significant effects on you. You can object to profiling for marketing purposes at any time by contacting hello@setyl.com.
