This privacy notice is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.
1. Important information and who we are
Purpose of this privacy notice
This privacy notice aims to give you information on how Privatise collects and processes your personal data through your use of the websites, including any data you may provide through the websites when you register/enroll via one the sites, request a free trial or demo, place an order, subscribe to our newsletter, or fill out a form.
This privacy notice covers both Privatise.com/privatise and privatise.com websites and subsequent references to “website” or “site” may refer to either one or both of these websites.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
Our full details are:
Full name of legal entity: Privatise LTD
Name or title of data privacy manager: Rafi Ozick
Email address: email@example.com
Postal address: 49 Moshe Dayan Jerusalem Israel.
Changes to the privacy notice and your duty to inform us of changes
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.
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 do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.2. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
Users may visit our site anonymously. We will collect such personal identification information from Users only if they voluntarily submit such information to us. Users can always refuse to supply such personal identification information, except that it may prevent them from engaging in certain site related activities.
There is no statutory requirement for you to provide us with your data. However, if you do not provide your information, we will not be able to provide you with our services.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
- Identity Data includes first name, last name, username or similar identifier and title.
- Contact Data includes billing address, delivery address, email address and telephone numbers.
- Financial Data includes bank account and tokenised payment card details.
- 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.
- Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our website.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.3. How is your personal data collected?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your identity and contact data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- create an account on our website;
- request a free trial account;
- complete a contact us form;
- subscribe to our service or publications;
- subscribe to our newsletter;
- request marketing to be sent to you; or
- give us some feedback.
- Direct communications with you via email or telephone;
- Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
- Technical Data from the following parties:
- analytics providers;
- advertising networks; and
- search information providers.
- Technical Data from the following parties:
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
- Identity and Contact Data from data brokers or aggregators.
- Identity and Contact Data from publicly available sources.
4. How we use your personal data
We will only use the details collected from you:
- For the purposes of your enrolment and the administration of the site;
- To provide you with trial and/or demo accounts;
- To carry out services under our contracts with you;
- To improve customer service;
- To administer and maintain our activities and this website including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data;
- To contact you (including sending information and updates relating to any order, questions or requests) or for the provision of customer services;
- To use data analytics to improve our website, products/services, marketing, user relationships and experiences;
- To make suggestions and recommendations to you about goods or services that may be of interest to you.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending first or third party company, product, or 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.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
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 where more than one ground has been set out in the table below.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|For the purposes of your enrolment and the administration of the site||(a) Identity (b) Contact||Performance of a contract with you|
|To carry out services under our contracts with you||(a) Identity (b) Contact (e) Marketing and Communications||Performance of a contract with you|
|To improve customer service||(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 maintain our activities 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 company, provision of administration and IT services, network security, and to prevent fraud or abuse (b) Necessary to comply with a legal obligation|
|To contact you (including sending information and updates relating to any order, questions or requests) or for the provision of customer services||(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical||Necessary for our legitimate interests (to study how users use our products/services, and to develop them)|
|To use data analytics to improve our website, products/services, marketing, user relationships and experiences||(a) Technical (b) Usage||Necessary for our legitimate interests (to define types of users for our products and services, to keep our website updated and relevant 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)|
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 Identity, Contact, Technical, Usage and Profile 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, subscribed to our newsletter, blog or other communications channel, or if you have requested a free trial, or ordered a product or service, in each case, 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 company outside Privatise group for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time or by clicking the appropriate link in marketing messages where provision of a link is appropriate.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of requesting a free trial or placing an order.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.5. Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
We do not sell, trade, or rent personal identification information collected from Users to others outside our group. We may share generic aggregated demographic information not linked to any personal identification information regarding Users with our business partners, trusted affiliates and advertisers for the purposes outlined above.
If payments are collected then we will use a third party service provider to process your payments and we will share your information with them for that purpose only. We may also use third party service providers to help us operate our business and the site or administer activities on our behalf, such as sending out newsletters or surveys. We may share your information with these third parties for those limited purposes unless you have asked us not to do so at registration or afterwards.
We may disclose personal information obtained from you to third parties:
- In the circumstances set out above.
- In the event that we sell or buy any business or assets, in which case we may disclose personal data obtained from you to the prospective seller or buyer of such business or assets.
- If Privatise.com and/or privatise.com, or substantially all of one or both of their 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.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.6. International transfers
Privatise.com and privatise.com and our customer databases are hosted in the United States. We therefore store and process personal information and content outside the European Economic Area (“EEA“), in the US. This information may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the fulfilment of your trial request, demo, order, the processing of your payment details and the provision of support services. By submitting your personal identification information, you agree to this transfer, storing or processing.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented. In particular, we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
Where we use providers based in the US, we may transfer data to them if they have the standard contractual clauses (SCCs) which have been adopted by the European Commission, as an appropriate safeguard to comply with the GDPR restricted transfer rules.
We may transfer the personal information we collect about you to group offices based in Israel, which is outside the EU. The main purpose of this is among other things, the fulfilment of your trial request, demo, order, the processing of your payment details and the provision of support services, which enables us to perform our contract with you and to meet our legal obligations. There is an adequacy decision by the European Commission in respect of Israel. This means that Israel is deemed to provide an adequate level of protection for your personal information.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.7. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
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 requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: Please contact us for further information.
In some circumstances we may 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.
We will keep your session log data only for the amount of time you specify in the Advanced Settings of your Customer Portal account. By default this is 30 days. This is to enable the generation of customer usage and compliance reports and summaries.
Under some circumstances we may explicitly request your consent to keep your session log data for a longer specific period of time to enable troubleshooting, system maintenance, performance enhancements, and protection against fraud and abuse. In such circumstances we would clearly communicate the request, explaining why, and you would be free to decline the request.
Note however that in some circumstances that could mean we may not be able to diagnose or fix bugs or errors with your use of one of our products or services, and in some circumstanced we may not be able to continue to provide you with one of your products or services.9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data:
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
Please refer to the ICO’s website for more information about these rights. If you wish to exercise any of the rights set out above, 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 may 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 may 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.10. Glossary
Legitimate Interest means the interest of our company in conducting and managing our company and this website to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Internal Third Parties means other entities in Privatise Group acting as joint controllers or processors and who are based in the USA, EU and Israel.
External Third Parties
- Service providers acting as processors based in UK and USA who provide payment processing services.
- Privatise and Privatise.com and privatise.com professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in UK, USA and Israel who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities based in the United Kingdom, United States and Israel who require reporting of processing activities in certain circumstances.
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: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) 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.