Simplelists (We, us, our) are committed to protecting and respecting your privacy.
Scope of policy
- Any software (Software) available on http://www.simplelists.com (Website).
- Any software developed by Simplelists.com.
- Any of the services accessible through the Software (Services) that are available on the Website.
This policy sets out the basis on which any personal data We collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how We will treat it.
The data controller is Simplelists Ltd registered with the Information Commissioner’s Office under number ZB350530.
We have appointed a data privacy manager 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 the data privacy manager using the details set out below.
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.
Information we may collect from you
We may collect and process the following data about you:
- submitted information. Information that you provide about yourself, such as your name and e-mail address. This includes information provided at the time of registering to use the Software or any of the Services, subscribing to any of the Services or requesting further services. This also includes any information you provide by filling in any forms on the Website. We may also ask you for information when you report a problem with the Website.
- additional information.
- if you contact us, We may keep a record of that correspondence including your contact details;
- We may also ask you to complete surveys that We use for research purposes, although you do not have to respond to them;
- details of transactions you carry out through the Website and of the fulfilment of your orders; and
- details of your visits to the Website including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.
- device and computer information. We may collect information about the device or any computer you may use to access the Software, including, where available, the device's or computer's unique identifiers, operating system, browser type and mobile network information as well as the device's telephone number, for the purpose of system administration. We may associate device or computer information with Submitted Information and will treat the combined information as personal data in accordance with this policy for as long as it is combined. We may collect and store personal data on your device or computer using application data caches and browser web storage (including HTML 5) and other technology.
- log information. When you use the Services or view content on the Website, We may automatically collect and store certain information in server logs, including but not limited to internet protocol (IP) addresses, internet service provider (ISP), clickstream data, browser type and language, viewed and exit pages and date or time stamps.
- unique application numbers. When you install or uninstall a Service containing a unique application number or when such a Service searches for automatic updates, that number and information about your installation, for example, the type of operating system, may be sent to us.
- data from third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below: Technical Data from the following parties: analytics providers (such as Google based outside the EU); advertising networks (such as GovNet Communications based inside the EU); and search information providers (such as the UK Government Digital Marketplace based inside the EU).
Where We store your personal data
The data that We collect from you may be transferred to, and stored at, a destination within the United Kingdom. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this policy.
All information you provide to us is stored on our secure servers. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted. Where We have given you (or where you have chosen) a password that enables you to access certain parts of the Website or Services, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
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 the Website or Services; 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.
Uses made of the information
We use information held about you in the following ways:
- To ensure that content from the Website and Services is presented in the most effective manner for you and for your computer.
- To provide you with information, products or services that you request from us or which we feel may interest you (including relevant ones from third-parties), where you have consented to be contacted for such purposes.
- To carry out our obligations arising from any contracts entered into between you and us.
- To notify you about changes to our service.
- 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 obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Note that we may process your personal data for more than one lawful ground 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.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:
Promotional offers from us
We may use your data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you have requested information from us or purchased Software or Services from us and you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of Software or Service purchase or other transactions.
Disclosure of your information
We may disclose your personal information to any member of our group acting as joint controllers or processors, which means our subsidiaries, our ultimate holding company and its subsidiaries and to provide IT and system administration services and undertake leadership reporting.
We may disclose your personal information to third parties:
- In the event that We sell or buy any business or assets, in which case We may disclose your personal data to the prospective seller or buyer of such business or assets.
- If Simplelists.com 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 or regulatory obligation or request. For example, to HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the UK who require reporting of processing activities in certain circumstances.
- In order to:
- protect the rights, property or safety of Simplelists our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
- To service providers acting as processors based in the UK who provide IT and system administration services.
- To professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers (typically based in the UK) who provide consultancy, banking, legal, insurance and accounting services.
How long will you use my personal data?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
By law we have to keep basic information about our customers for six years after they cease being customers for tax and legal purposes.
In some circumstances you can ask us to delete your data: see your rights below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Third party links
The Website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates (including, but not limited to, websites on which the Software or the Services are advertised). If you follow a link to any of these websites, please note that these websites and any services that may be accessible through them have their own privacy policies and that We do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as contact and location data. Please check these policies before you submit any personal data to these websites or use these services.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. If you wish to exercise any of these rights, please contact us.
No fee usually required
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 could 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 within one month. Occasionally it could 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.
Your legal rights
You have the right to:
- 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 we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data 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 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 of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data's accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, 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.
- Withdraw consent at any time 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.
Changes to your data
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.