Computer Geeks Privacy Policy – External

Computer Geeks Privacy Policy – External

CGeeks Limited (“Computer Geeks”, “we”, “us” or “our”) takes the privacy of its clients’ data very seriously.

This policy (together with our General Working Terms and Conditions https://geeks.co.uk/termsandconditions/ or, our Master Services Agreement or Hosting Services Agreement (as applicable to the products and services we provide to you) as well as any other documents referred to in these) sets out the basis on which any data we collect from you, that you provide to us, or that we collect from other sources about you, will be processed by us when you access our website, purchase products or services from us or via us, or make enquiries or otherwise communicate with us.

A copy of this policy is available to view by visiting https://geeks.co.uk/privacy/ or contact your Computer Geeks representative who can provide you with a copy.

We collect personal data in two broad categories (1) where we process personal data on your behalf (where we act as a processor) under a contract with you or your organisation, and (2) where we use that personal data for our own purposes (where we act as a controller). This policy deals with how we process personal data as a controller.

Responsibility for personal data

Our role as a processor:

Except in limited circumstances, as set out below, Computer Geeks provides its services as a processor on behalf of our clients (rather than a controller) in relation to personal data which we may store or access when delivering our services to you. This means we act on your behalf, and that you are responsible for the personal data which is made available to us, how that personal data is used, when it is updated or deleted, in addition to your own obligations as a controller under the applicable data protection legislation. For example, you must comply with the data protection principles as set out in the EU’s General Data Protection Regulation, which you can find out more about here www.ico.org.uk.  In particular, you must ensure you have provided adequate information to individuals about whom you process personal data (for example, you should have an appropriate privacy policy), established an appropriate lawful basis for that processing, and you must handle that personal data appropriately.

In particular, if you have selected the relevant remote support service option, Computer Geeks will have remote access to your computer systems and the information which you store there. We may use such remote access without requesting further permission from you. For more information on which of our services or products require remote support access see the General Working Terms and Conditions, or your Master Services Agreement.

We do have obligations as a processor under the applicable data protection legislation, which we can provide more information about on request. In particular, our Master Services Agreement sets out how we will act on your behalf as a processor.

Our role as a controller:

We also process some personal data as a controller for certain purposes – which means that we are primarily responsible for it, and make decisions about how that personal data is used. This relates to how you use our service at a technical level, and for our own statistical analysis to help improve the service, and where we use your contact details for marketing purposes. For example, we may collect information about your browser, and computer operating system to allow us to provide an efficient browsing experience. We have set out how we process this type of personal data in more detail below.

It is important that you read this policy together with any other privacy policy 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 policy supplements the other notices and is not intended to override them.

Contact Details

We have appointed a Data Protection Compliance Officer 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 us using the details set out below.

Our full details are CGeeks Limited. Registered office: 7 Thomas Lane, Bristol BS1 6JG. Registered number 06774326 (England and Wales).

 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.

Changes to the privacy policy and your duty to inform us of changes 

This version was last updated on 16 May 2018. Previous versions can be obtained by contacting us.

The data protection law in the UK will change on 25 May 2018. Although this privacy policy sets out most of your rights under the new laws, we may not yet be able to respond to some of your requests (for example, a request for the transfer of your personal data) until May 2018 as we are still working towards getting our systems ready for some of these changes.

It is important that the personal data we hold is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

What information does Computer Geeks collect?

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).

·           Information we collect about you: We may collect, use, store and transfer different kinds of personal data about you or your personnel which we have grouped together as follows:

1                     Technical Data, including the Internet protocol (IP) address used to connect your computer to the internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website or for us to access your systems and any remote access codes.

 

2                     Identity Data includes: first name, last name, title, date of birth and gender, your login information.

 

3                     Contact Data includes billing address, delivery address, email address and telephone numbers, and the content of your communications such as information you give to us about you or your personnel, when requesting our products and services (including third party products), or completing a Master Services Agreement or a Hosting Services Agreement, or if you or one of our representatives complete an enquiry form, enter a promotion or survey, when you, or your personnel, speak to or communicate with one of our representatives, and when you report a problem with our products and services.

 

4                     Usage data, which includes information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs); application logs detailing who has added, edited or amended content and when; methods used to browse away from the page and any phone number used to call our customer service number.

 

5                     Financial Data includes bank account and payment card details.

 

6                     Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.

 

7                     Marketing and Communications Data includes your preferences in receiving marketing from us [and our third parties] and your communication preferences.

·           Information Computer Geeks receives from other sources:

Outsourced Service Providers – to make our services efficient, and robust, we outsource certain services such as the secure storage of passwords, and we may receive information about you from them.

We may collect or buy information from third parties about you. For example, if you purchase a third party product or service, that third party may provide us with information it holds on you in order for us to provide support services to you, or facilitate your purchase or renewal of such services.

  • Information may be available about you publicly, or may be aggregated or anonymised by a third party. For example, we may apply demographic analysis of your postcode such as average household size, business size, average income, and the general location.

In these situations, we will usually have informed you when we collected that data from you that it may be shared internally. Any additional data that we collect about you will be combined with other data collected about you from these various information sources.

Sensitive Personal Data / Special Categories of Personal Data. Unless we make it clear otherwise, our policy is not to ask for any sensitive personal data (also known as special categories of personal data and criminal offence data) from you (that is information about your, or your personnel’s) racial or ethnic origin, political opinions, religious beliefs, trade union activities, physical or mental health, sexual life, or details of criminal offences). We, and our outsourced service providers may, however, require certain sensitive personal data to provide our services to you, or to deal with your enquiries. For example: If you ask us to create an online account with a large service provider on your behalf, to comply with their anti-terrorism policies, it might be necessary to ask you to disclose any relevant background information that they require. In most cases we will do this as your processor, and will not collect or process such data as a controller.

If you choose to provide this sensitive personal data to us as part of a particular service (where such information has been requested and the reasons for that discussed with you) or for any other reason, we will explain why we need that information, and how we process it at the time you provide that information to us.

  • Information about other people. If you provide information to us about any person other than yourself, such as your personnel, your clients, or your suppliers, you must ensure that they understand how their information will be used and that they have given their permission for you to disclose it to us and for you to allow us, and our outsourced service providers, to use it.
  • Information from Clients 18 and Under. If you are aged 18 or under, you must obtain your parent or guardian’s permission beforehand to use our site, our telephone service, and to place orders, and whenever you provide personal information to us. Users without this consent are not allowed to provide us with personal information.

You will find that it is not compulsory to provide us with any additional information we request which is not necessary or reasonable in order to provide you with the services you have requested.

How is your personal data collected?  

We use different methods to collect data from and about you, and your personnel, including through:

1         Direct interactions. You may give us your Identity, Contact, and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

·         Discuss our services with us as a prospective client;

·         subscribe to our newsletters or publications;

·         request marketing to be sent to you;

·         complete a survey;

·         make a complaint; or

·         give us some feedback.

2         Third parties or publicly available sources. We may receive personal data about you or your personnel, from various third parties and public sources as set out below:

·         Marketing and Communications Data.  We may on occasion use professional social media sites, such as LinkedIn, to contact you via that platform or share your content.

·         Technical Data from the following parties:

o    analytics providers such as Google based in USA and

o    search information providers based inside the EU.

 

·         Identity and Contact Data from data brokers or aggregators.

·         Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.

 

How is your personal data used?

Where Computer Geeks acts as a processor:

The personal data that we collect and store relating to you is primarily used to enable us to provide our products and services to you, which we do as a processor under our contract with you and your organisation. In particular, as part of our services we will use personal data you provide to us:

·         To carry out our obligations arising from any contractual arrangements entered into between you and us, and to provide you with the information, products and services that you request from us.

·         If you have selected the relevant service option, we may access your stored information strictly only for the purposes of providing you the services or products which you have requested.

·         To notify you of changes to our services.

·         To facilitate, in our capacity as a reseller, your purchase of certain third party products and services (such as Microsoft Hosted Solutions e.g. Office 365).

·         We may combine the information you give to us with information which we collect about you and information which we collect or buy from third parties about you. We may use this information and the combined information we collect about you for the purposes set out above. For example, if you purchase a third party product or service, that third party may provide us with information it holds on you in order for us to provide support services to you, or facilitate your renewal of such services.

 

We retain your data which we use to provide our services to you for such period as we have agreed with you.

Where Computer Geeks acts as a controller:

Where we process your personal data as a controller (meaning we use it for our own purposes) we will only use your personal data when the law allows us to. Most commonly, we will use your personal data as a controller in the following circumstances:

·         Where you have given us your consent.

·         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 or regulatory obligation.

 

Please see the table below to find out more about the types of lawful basis that we will rely on to process your personal data as a controller.

If you have given us your consent for us to process your personal data, you have the right to withdraw consent by Contacting us.

We have set out below 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 legal basis 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

Retention period (see further below)

To process and deliver our services:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

 

(a) Identity

(b) Contact

(c) Transaction

 

(a) Necessary for our legitimate interests (to recover debts due to us)

 

For the duration of our contract with you, and all amounts have been paid, plus 3 years

To manage our relationship with you which will include:

(a) Notifying you about changes to our contract terms or privacy policy

(b) Asking you to leave a review or take a survey

 

(a) Identity

(b) Contact

(c) Marketing and Communications

 

(a)     Necessary for our legitimate interests (to keep our records updated, to keep our terms and privacy policy updated, and to study how customers use our products/services)

 

For the duration of our contract with you, and all amounts have been paid, plus 3 years

To administer and protect our business and our site and our services (including troubleshooting, data analysis, testing, system maintenance)

 

(a) Identity

(b) Contact

(c) Technical

 

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

For the duration of our contract with you, and all amounts have been paid, plus 3 years

To use data analytics to improve our site, and our services, customer relationships and experiences

 

(a) Technical

(b) Usage

 

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

 

For the duration of our contract with you, and all amounts have been paid, plus 3 years

To make suggestions and recommendations to you about our services that may be of interest to you

 

(a) Identity

(b) Contact

(c) Technical

(d) Usage

 

(a)     Consent

(b)     Necessary for our legitimate interests (to develop and our products and grow our business.)

 

For the duration of our contract with you, and all amounts have been paid, plus 3 years

To keep information in compliance with our legal obligations.

(a) Legal

(a) [Legal obligation]

For the duration of our contract with you, and all amounts have been paid, plus the amount of time required by the Legal Obligation

Marketing

  • If you have elected to receive it, we may send you our regular newsletter, and we may contact you by electronic means (e.g. by e-mail or SMS/ text or push messages to your smartphone) with information about goods and services of ours which are similar to those which you have purchased or negotiated with us about previously. If you have agreed that we may do so, we may also use your personal data to contact you by electronic means with information about other products and services of ours;

Where consent is needed (for example to send you electronic communications), we will ask for this consent separately and clearly.

We will always ensure that your personal data with respect and we will never sell or share it with other organisations for marketing purposes.

We may ask you to confirm or update your marketing preferences over time, such as when you instruct us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.

Opting out of marketing

You can ask us 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.

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.

Disclosure of your Information

We may have to share your personal data with the parties set out below :

  • External third parties in their capacity as our sub-contractors in providing our services to you, including  organisations and the specific third parties listed https://geeks.co.uk/privacy/3rdparty or anyone that you ask us to provide your details to. 
  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy or under your contract with us.
  • If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of service and other agreements; or to protect the rights, property, or safety of Computer Geeks, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of managing our credit risk, fraud protection and the protection of minors. If we are requested by the police or any other regulatory or government authority investigating suspected illegal activities to provide your personal information, we may be obliged to do so.

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.

The data that we collect from you is processed by staff who work either for us, or for one of our outsourced service providers. Such individuals or organisations may be engaged in, among other things, the fulfilment of your services, the processing of your payment details and the provision of support services. We take reasonable steps to ensure that our staff and suppliers protect your information, and are aware of their information security obligations. For example, each of our staff members sign a confidentiality agreement to govern and limit disclosure of client sensitive information to any third parties, and all staff are provided with guidance on how to deal with personal information.

We are not responsible for the privacy practices of any external websites to which we have created links.

We do not sell, rent or trade your personal information to third parties for marketing purposes. We may, however, pass your primary contact details (email address and phone number) to a trusted third party who you have asked us to provide your details to.

Where your personal information is disclosed to any of our outsourced service providers for these purposes, they will only have access to the information needed to perform their functions, and our contractual arrangements with them do not permit them to use your personal information for their own purposes. We also take reasonable steps to help ensure that they will keep the information secure and confidential and that they will process it in compliance with applicable data protection legislation.

We may also use and disclose information in aggregate (so that no individuals are identified) for marketing and strategic development purposes or use and analyse the information we collect so that we can administer, support, improve and develop our business. For example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day.

Storing Your Personal Data

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.  Any personal data that is provided to us is stored on our secure servers and/or those of the service provider hosting our site on our behalf. For more information about our security measures, please see https://geeks.co.uk/privacy/3rdparty.

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.

Where legal requirements have been complied with we may transfer personal data that we collect from you to locations outside of the European Economic Area for processing and storing. Your data may also be processed by staff operating outside the European Economic Area who work for us or for one of our suppliers. For example, such staff may be engaged in the provision of your services, the processing of your payment details and the provision of support services. We will take such steps as reasonably necessary to make sure that your data is treated securely and in agreement with this Privacy Policy.

We will retain your information only for as long as it is necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements as set out in our Data Retention and Data Destruction Policies, and as referred to above. If you have any questions relating to our retention or destruction of your data, please contact us using the details set out in the Contact Us section below.

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 our site; any transmission is at your own risk. Access to information and other rights

Under certain circumstances, and depending on our relationship with you as a controller or processor, you have rights under data protection laws in relation to your personal data:

  • 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 held about you and to check that it is being lawfully processed.
  • Request correction of your personal data that is held about you. This enables you to have any incomplete or inaccurate data held about you corrected, though the accuracy of the new data you provide may need to be verified.
  • Request erasure of your personal data. You can ask for your personal data to be deleted or removed 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. 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 your personal data. This enables you to ask that processing of your personal data to be suspended in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where use of the data is unlawful but you do not want it to be erased; (c) where you need the data to be held even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to the use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request transfer of your personal data to you or to a third party. You can ask to be provided with, or that a third party you have chosen is provided with, 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.
  • Right to withdraw consent 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.

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. 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.

Cookies

We want to be up-front about how our website uses cookies. For more detail on how we use cookies, or for information on how to clear your cookies, please read the sections below.

  • Google Analytics

Google Analytics is a free service provided by Google Inc. which uses cookies to better understand how people use and find our website. This is just general information such as whether you are using a computer or a mobile phone but it is essential in helping us make sure we provide the right information in the right formats on our website. For more information on the cookies created by Google Analytics please read Google’s http://www.google.com/intl/en/privacypolicy.html. You can chose to globally opt out of being tracked on Google Analytics (visit Google’s opt out page: https://tools.google.com/dlpage/gaoptout). This will affect every website you visit, not just ours.

  • Facebook Integration

Our website is connected to our Facebook group. When you are signed into your Facebook account the website will allow you to easily like our page and join our Facebook group. Cookies are required to do this. https://www.facebook.com/policy.php

  • Session Cookies

These are temporary cookies that are used each time you visit to the website. They are not kept after you leave the page, but simply ensure you can do things like complete online forms or use the chat functionality.

  • Clearing Cookies

If you decide to clear the cookies in your web browser, then the following instructions should help you:

  • Google Chrome
  1. Click the “wrench” icon in the top right-hand corner and select “Options.”
  2. In the “Under the Hood” tab, click the “Clear browsing data…” button (make sure that “Delete cookies and other site data” is selected).
  3. Click on “Clear browsing data.”
  4. Exit and relaunch the browser.
    • Internet Explorer
  5. On the Internet Explorer Tools menu, click “Internet Options.”
  6. The Internet Options box should open to the General tab.
  7. On the General tab, in the Browsing History section, click the “Delete…” button.
  8. In the “Delete Browsing History” window that comes up, make sure that “Cookies” are selected.
  9. Click the “Delete” button and restart the browser.
    • Mozilla Firefox
  10. Click “Tools” and select “Clear Recent History.”
  11. Make sure that “Cookies” are selected.
  12. Click on “Clear Now.”
  13. Exit and relaunch browser.

Changes to our privacy policy

We may change this Privacy Policy at any time. If we do, we will display a notice to this effect on the home page of our site for at least 30 days. If you use our services or access our site after we have published such a notice, you will be accepting the new policy. Where appropriate, we may also notify you of the changes to you by email.

Contact Us

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to the Computer Geeks Data Protection Compliance Officer at:

Address:          Data Protection Compliance Officer, CGeeks Limited, 7 Thomas Lane, Bristol BS1 6JG

Email Address:           DPCO@geeks.co.uk

This Privacy Policy was last updated in 16 May 2018