FOR REGISTERED USERS OF OUR TPTracker SOFTWARE

We are the data controller, meaning we are responsible for and control the processing of your personal data as a registered user of our TPTracker software.

10 Information we will collect from you

We will collect, use, store and transfer personal data about you as a customer and registered user of our web-based TPTracker software:

10.1 Information you give us

You will give us information about you by registering as a user of TPTracker software. The information you give us may include your name, company address, e-mail address, phone number and job title.

10.2 Information we collect about you

With regard to your visits to TPTracker, the software will automatically record information about records that you create and changes that you make to data fields within the software.

11 Information about other individuals

TPTracker software which you access under contract from us, is provided for the purpose of storing and analysing data and records relating to your contacts. For these records, TPTracker Ltd acts only as the Data Processor and you are legally the Data Controller.

12 Communications

We may monitor communications with you (such as telephone conversations and emails) for the purpose of quality assurance, training, fraud prevention and compliance. We will keep a record of email communications but will not record any telephone conversations.

13 Uses made of the information

13.1 We use information you give to us to:

13.1.1 Carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;

13.1.2 Provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about;

13.1.3 Notify you about changes to our products and services; and

13.1.4 Ensure that content from TPTracker is presented in the most effective manner for you and for your computer.

13.2 We use information we collect about you to:

13.2.1 Administer our services and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;

13.2.2 Improve our services to ensure that content is presented in the most effective manner for you and for your computer;

13.2.3 Support of our efforts to keep our website safe and secure; and

13.3 Our lawful basis for processing your data is:

13.3.1 The performance of a contract with you;

13.3.2 The necessity for our legitimate interests for running our business, provision of services and network security.

13.4 We may share your personal information with:

13.4.1 Any employee of TPTracker Ltd;

13.4.2 Selected third parties including:

• Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
• Analytics and search engine providers that assist us in the improvement and optimisation of our websites.

13.5 In the event that we sell or buy any business or assets

We may disclose your personal data to the prospective seller or buyer of such business or assets and the personal data held by us about our customers will be one of the transferred assets.

13.6 If we are under a duty to disclose or share your personal data

We may disclose your personal data in order to comply with any legal obligation, or to protect the rights, property, or safety of our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection.

14 Cookies

Our web-based software provided under contract to you does not include any cookies.

15 Where we store your personal data

All our websites and web-based software are hosted within mainland UK. We never transfer data elsewhere.

16 Security

We will always do our best to protect your personal data, though we cannot guarantee the security or integrity of your data transmitted to our website and you acknowledge that any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to prevent unauthorised access and ensure your personal data and the data relating to your contacts which is held in TPTracker cannot be accessed by unauthorised users.

17 Data Retention

17.1 Data files held on individual PCs, laptops or phones

It is TPTracker’s policy not to store any data files containing personal data on any devices other than on the TPTracker server.

17.2 Data files held on the TPTracker server

Each January, any files containing personal data that are more than 12 months old will be deleted. This annual clean-up is scheduled as a recurring event in TPTracker’s diary system and is fully recorded for audit purposes.

17.3 Data files held in TPTracker software

Personal data on contacts held in TPTracker software is owned and controlled by the licensee. The data will remain in TPTracker until the licensee deletes or pseudonymises the data. If the licensee’s licence expires, the TPTracker site will be shut down, which will permanently delete all the data held in the site.

17.4 TPTracker software back-up files

The TPTracker database and all files held in TPTracker are backed up each night. Each backup is retained for one month and then over-written with a newer backup, permanently destroying the older copy.

17.5 Paper documents

It is TPTracker’s policy not to store any documents containing personal data for longer than 3 months. All such documents will be disposed of using a 3rd Party, on-site, secure, data shredding contractor who provides a written record.

18 You have the right to:

18.1 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.

18.2 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.

18.3 Request erasure of your personal data

You can 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.

18.4 Object to processing of your personal data

You can object 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.

18.5 Request restriction of processing of your personal data

You can 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.

18.6 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.

18.7 Withdraw consent at any time

You can do this 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 professional services to you. We will advise you if this is the case at the time you withdraw your consent.

18.8 Complain

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 using the details below.