Privacy Policy

Effective Date: 05/25/2018

IMPORTANT: PLEASE READ THIS PRIVACY POLICY AS IT APPLIES TO ANY PERSONAL INFORMATION (“REFERRED TO AS “PERSONAL DATA”) YOU PROVIDE US OR WE COLLECT ABOUT YOU, FOR EXAMPLE IF YOU ACCESS THE WEBSITE AT CORDIUM.COM OR ANY OTHER WEBSITE OWNED, OPERATED OR PROVIDED BY COLUMBO TOPCO LIMITED, A LIMITED COMPANY INCORPORATED IN ENGLAND & WALES (REGISTERED NUMBER 09332651) AND/OR ANY OF ITS SUBSIDIARY UNDERTAKINGS (REFERRED TO EITHER AS “CORDIUM,” “WE” OR “US”). WE DO NOT MARKET TO OR ENTER INTO CONTRACTS WITH CHILDREN NOR WE DO COLLECT PERSONAL DATA FROM ANY PERSON UNDER 18 YEARS OF AGE.  PLEASE DO NOT ACCESS OR USE THE WEBSITE OR SERVICES IF YOU ARE UNDER 18 YEARS OF AGE.

This Policy

This policy sets out what personal data we might collect, how we process and protect that data, the lawful grounds for that processing, and your related rights.  Essentially “personal data” means any information relating to an identified or identifiable natural person, namely one who can be identified, directly or indirectly from that information alone or in conjunction with other information.

In most cases, the lawful ground will be that the processing: (i) is necessary for our legitimate interests in carrying out our business, including to maintain, improve and market our products and services], provided those interests are not outweighed by your rights and interests (“Legitimate Interests”), (ii) is necessary to perform a contract with you (“Contract”), or (iii) is necessary to comply with our legal obligations (“Legal Obligation”). Where processing is based on your consent (“Consent”), we will identify the processing purposes and provide you with relevant information to make the processing fair and transparent.

As data protection law and practice are constantly developing, we’ll need to update this policy from time to time, which we’ll do by posting a new policy on the Website that takes effect from the date stated.  It is your responsibility to return to the Website from time to time and check for changes.

  1. Information Collection and Use

We collect or are provided Personal Data in the normal course of business, for example:

  • you may provide us with your details during discussions about buying our products or services,
  • when you visit the Website, we may collect information about your visit such as your IP address and the pages you visited,
  • you may provide us with your details when you ask about our Services (through the Website, by email or otherwise) and we may obtain legally-compliant lists of potential customers for our Services for our marketing purposes.

We may collect the following Personal Data from or about you:

  • contact Information such as name, email address, mailing address, phone number
  • information about your business role, such as job title and company name
  • information about your interests in our services and products

We use this information for our legitimate business interests, including to:

  • respond to enquiries about the Services, to provide the Websites and Services, to provide advice and support. Lawful basis: Legitimate Interests or Contract.
  • analyze and improve the Website, the Services, for example for technical or security purposes and to improve the customer experience. Lawful basis: Legitimate Interests, however where for example applicable law requires your consent to use certain cookies, we will ask for your Consent having provided you with relevant information.
  • market our Services – if we do so, we will provide you with an easy and free way to opt-out of receiving such communications in the future. Lawful basis: Legitimate Interests (or Consent as above).
  • administer and manage delivery of our services and products to you. Lawful basis: Legitimate Interests (or Consent as above).
  • in certain circumstances, to share it with a limited number of third parties as described in this policy, for example for operational requirements and business continuity purposes. Lawful basis: most processing will be based on Legitimate Interests, some processing is based on Contract and, where necessary (as above) some processing may be based on your prior Consent.

When you provide us with personal data about yourself or another person, you are confirming to us that you are authorized to provide us with that information and that any personal data you give us is accurate and up-to-date.

Given the nature of our business, we do not ask for “sensitive” or “special categories of personal data,” such as information about your health, political opinions, racial origins or sexual life and we would ask you not to send any to us.

  1. Information Sharing

We will only share your Personal Data with third parties in the ways set out in this privacy policy. We do not give, sell or rent your Personal Data to third parties for them to market their services to you. Nor do we accept advertising from third parties on the Website.  We may provide your Personal Data to our service providers to help us with our business activities, such as inputting your contact information into our CRM or email marketing system. In all cases we will have a written processor agreement with these companies safeguarding your Personal Data, including that it may only be processed for the purposes of that agreement and on our instructions. We may also disclose your Personal Data:

  • For provision of the Services, and for our own disaster recovery and business continuity purposes, we may store or transmit personal data to or through third party providers, such as with our contractors and advisors to help us operate, secure and analyze our business. Lawful basis: Legitimate Interests or Contract.
  • We may be obliged to disclose your personal data to comply with a law, order or request of a court, government authority, other competent legal or regulatory authority or any applicable code of practice or guideline. We may also be obliged to disclose personal data when we believe in good faith that disclosure is necessary for our legitimate interest such as investigating fraud, to make or defend a legal claim, to protect your safety or the safety of others, or to maintain our compliance or that of our personnel with applicable laws, regulations and/or professional obligations, all in accordance with applicable law. Lawful basis: Legal Obligation.
  • If Cordium is involved in a merger, acquisition, or sale of all or a portion of its assets, we may disclose such Personal Data as is necessary for our legitimate interests in completing that transaction and always provided that appropriate safeguards are in place including limitations and restrictions on use, access and retention. Lawful basis: Legitimate Interests.
  • In other situations, only with your prior consent. Lawful basis: Legitimate Interest and Consent.
  1. Transfers outside the EEA

We share the minimum personal data necessary and we have written contracts in place incorporating relevant wording to safeguard that personal data and comply with applicable laws, and we will only share such data as is necessary for the purpose in question.  Where possible, we keep personal data within the European Economic Area (‘EEA’).  However, in order to carry out the above purposes, we may use third parties and their facilities outside the EEA. In all such cases we will ensure that appropriate security measures are in place to protect your personal data and a valid legal basis for the transfer applies.

  1. Your Rights

You have the right to ask whether Cordium processes your Personal Data and to request a copy, to object to direct marketing and in certain circumstances to have the data rectified or blocked or withdrawn. To request this information, please email privacy@cordium.com. If your personal information changes, or if you no longer desire our services, you may ask to have your Personal Data corrected, amended, removed or deleted by emailing privacy@cordium.com. You have the right to ask us to restrict processing certain of your personal data, to erase your personal data, and to ‘port’ certain of your personal data to you or another provider, provided in each case that we have such data and certain conditions are met. You also have the right to object to direct marketing and, under certain circumstances, to object to our processing of your Personal Data. We will respond to your request within 30 days.

Opt-Out Preferences
If you subscribe to our newsletter(s), we will use your name and email address to send the newsletter to you. You may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in such emails or by contacting us at privacy@cordium.com.

  1. Tracking Technologies / Cookies

Cookies
Cordium and our partners, affiliates or analytics or service providers (such as website developers and SEO specialists) use cookies or similar tracking technologies. These technologies are used in analyzing trends, administering the website, tracking users’ movements around the site, and gathering demographic information about our user base as a whole. You can control the use of cookies at the individual browser level but if you choose to disable cookies, it may limit your use of certain features or functions on our website or service. We may receive reports based on the use of these technologies by these companies on an individual and aggregated basis.

Please review our Cookie Policy which is part of (and incorporated into) this Privacy Policy for more information.

Analytics / Log Files
As is true of most web sites, we gather certain information automatically. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and clickstream data to analyze trends in the aggregate and administer the site. You are not identifiable from any of this data.

Social Media Widgets
Our Web site may include social media features, such as the Facebook “like” button, ‘Share This’ button or interactive mini-programs that run on our Sites. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the Feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our Sites. Your interactions with these features are governed by the privacy policy of the company providing it.

  1. Security

The security of your Personal Data is important to us. We follow industry standards to protect the Personal Data submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. If you have any questions about the security of your Personal Data, you can contact privacy@cordium.com.

  1. Retention

We will retain your information for the longer of the period we are required to do so by law, as is reasonably necessary for the purpose (for example to comply with our legal obligations, resolve disputes, and enforce our agreements), or as needed to provide you services. If you opt-out of communications, we will retain your name and contact details to enable us to respect your request.

  1. Additional Information

Anonymized Data
We may create anonymized data from personal data, and any anonymization would be carried out in accordance with applicable law as well as relevant guidelines from regulators such as the UK Information Commissioner (‘UK ICO’).  Anonymization may, for example, be achieved by aggregating data to the point that no individual can be identified such as aggregating website use statistics to see which web content is working well and which could be improved. Anonymized data does not allow for the identification of any individual person and, as it is no longer personal data, neither data protection laws nor this Privacy Policy would apply to such data.

Links to 3rd Party Sites
Our Sites include links to other web sites whose privacy practices may differ from those of Cordium. If you submit Personal Data to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any such third-party web site you visit. If we resell a service delivered or provided by a third party (‘Third Party Service’), including any software that is delivered or owned by a third party (‘Third Party Software’), it is that third party’s separate privacy policy that will apply to your personal data and your use of the Third Party Service and Third Party Software. Your use of a Third Party Service is not covered by this Privacy Policy. Please therefore review the privacy policy for any Third Party Service and Third Party Software before using it.

Testimonials
With consent from the individual, we display personal testimonials of satisfied customers on our website in addition to other endorsements, including their name. If you wish to update or delete your testimonial, you can contact us at privacy@cordium.com.

Changes To This Policy
We may update this privacy policy to reflect changes to our information practices. If we make any material changes we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on the Web Sites prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

  1. “Do-Not-Track” / California Privacy Notice

The Web Sites do not respond to “Do-Not-Track” signals communicated by your internet browser.

Contact Us

If you’ve any question you can always contact us by email at privacy@cordium.com. You have the right, at all times, to notify a complaint to any regulator such as the UK Information Commissioner, although we would welcome the opportunity to discuss and resolve any complaint with you first.