Privacy Policy.

Last Updated: 2 March 2022



Sumner Data Services Limited respects the privacy of your personal information (defined below) and is committed to protecting it through our compliance with this privacy policy.

Definition: Personal information, means any information about an individual from which that person can be identified. A more detailed definition is available at the UK Information Commissioners Office website here.

This privacy policy provides information on the collection, use, and sharing of your personal information. This includes personal information collected via email.

Overview:

  • Where possible we limit the processing of personal data to that which is required for core business purposes. E.g., email communication with clients and prospective clients.
  • We do not use tracking cookies or pixels. We only use cookies for basic Website functionality.
  • We will never knowingly disclose or sell your personal information.
  • We respect your privacy. We are committed to protecting it through our compliance with this privacy policy.

Please read this policy carefully to understand how we will treat your personal information. This policy may change from time to time, as described below; please check this policy frequently for updates.

This policy describes:


Principles.

Personal information will be:

  • processed lawfully, fairly, and in a manner that is transparent to individuals about what data we collect from them, why we collect it, and how we will use and handle it;
  • collected for specified and legitimate purposes and not further processed in a manner beyond those purposes;
  • adequate, relevant, and limited to what is necessary;
  • accurate and, where necessary, kept up to date;
  • deleted or de-identified when it is no longer needed for the stated purpose; and
  • processed in a manner that ensures appropriate protection of personal information.

The data we collect.

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, last name, username or similar identifier, marital status, title, date of birth and gender.
  • Contact Data includes email address and telephone numbers.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
  • Usage Data includes information about how you use our website and services (Note: we do not currently collect this type of data)
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences. (Note: we do not currently collect this type of data)

We may collect this information: (a) directly from you when you provide it to us; or (b) automatically as you navigate through our Websites. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.

Some of this information is required for us to provide our services to you, and some of this information is captured in log files. Note: we don't ue tracking cookies.

We may also receive information about you from suppliers, those businesses that provide us services (such as service providers, contractors, and consultants), third parties, or other online or offline sources.


How we use your data.

We will only use your personal data when the law allows us to and where there is a legitimate need to do so. We use data that we collect about you or that you provide to us, including any personal information to:

  • to fulfill the purpose for which you provide it, e.g., to respond to emails, provide proposals, and maintain contact with existing clients;
  • provide you with information or services that you request from us and notify you about changes to the service;
  • present our Websites to you;
  • exercise and defend our legal rights and comply with applicable; and
  • fulfill obligations outlined in regulatory requirements such as audits.

How we share your data.

We do not share personal data about our clients, their employees, or our website visitors.

However, we may be required to disclose your personal information to comply with any court order, law, or legal process, including to respond to any government or regulatory request.


How we store and retain your data.

Your personal data may, throughout the course of its processing, be transferred outside of the United Kingdom (UK).

We retain personal information for as long as necessary to provide you with the services that you have requested. We may also retain and use this information for a longer period for the following reasons, as permitted or required by law:

  • to comply with our legal, tax or regulatory obligations (e.g., audit and accounting requirements);
  • to handle disputes; and
  • to exercise or defend claims and enforce our agreements.

We ensure that personal information we dispose of, is de-identified or destroyed in a secure manner.

We may retain de-identified and other non-personal data indefinitely. We de-identify such information such that it is not likely reasonable for someone to re-identify the data.


How we protect your data.

We are committed to ensuring that your information is secure. To prevent unauthorized access or disclosure, we have put in place reasonable physical and electronic controls to secure the information we collect.

We follow generally accepted industry standards to protect information submitted to us, both during transmission and once we receive it. However, no method of transmission over the Internet, or method of electronic storage is 100% secure. Therefore, while we strive to protect your personal information in our possession, we cannot guarantee its absolute security. If you have any questions or concerns regarding the security of our systems, you can email us at the address in the ‘How to contact us’ section.


Your privacy rights.

Applicable law may provide certain rights regarding the use of your personal information.

You have the right to:

  • request information about how your personal data is processed;
  • request a copy of that personal data;
  • request that anything inaccurate in your personal data is corrected immediately;
  • raise an objection about how your personal data is processed; and
  • request that your personal data is erased if there is no longer a justification for it.

Your rights may differ according to your place of residence.


Children’s privacy.

We do not knowingly collect, maintain, or use personal information from children under 13 years of age without appropriate parent or guardian consent, and no aspect of our services or our Websites are directed to children.

If you learn that a child has provided us with personal information in violation of this Privacy Policy, then you may alert us the address found in the ‘How to contact us’ section and we will promptly delete any such information that we have collected.


Changes to our privacy policy.

We keep our privacy policy under regular review, and it is our policy to post any changes we make to this policy on this page.

The date this policy was last revised is identified at the top of the page.


Merger, sale, or other asset transfers.

We may transfer your information to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a business transaction in which we are acquired by or merged with another company, or we sell, liquidate, or transfer all or a portion of our assets. The use of your information following any of these events will be governed by the provisions of this Privacy Policy in effect at the time the applicable information was collected.


Other sites / third-party links.

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We have no control over the privacy provided by websites that are not our own, which might be linked to from our Websites. We reference other websites that you may wish to visit. Please be aware that this policy does not apply beyond this Website.

When you leave our website, we encourage you to read the privacy policy of every website you visit.


Cookies and other automatic data collection technologies.

As you navigate through our websites and use our services, we may use cookies and other automatic data collection technologies.
To learn more, please read ourCookies Policy.


Do not track.

Although your browser or device may include a “Do Not Track” option, this Website currently does not respond to a “Do Not Track” signal from your browser or device.


How to contact us.

If you have any questions about this privacy policy or our privacy practices or if you wish to exercise any of your legal rights regarding your personal data, please contact us at: info@sumnerdata.com or at our registered business address in the footer of this webpage.


Complaints.

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.