Techonik Ltd (“Techonik”) takes your privacy and the protection of your personal information very seriously. Any reference to “we”, “us” or “our” in this policy is a reference to Techonik Ltd.
This policy explains what information we gather about you, how we use that information, what we use that information for and who we may share that information with. It also sets out your rights in relation to any information that we may hold about you.
This policy applies to information that we collect about visitors to www.urbanly.com (the “Urbanly Site”).
1. Who we are
Techonik Ltd is the controller and responsible for the Urbanly Site. Techonik Ltd is a company incorporated in Scotland with company number SC628773 with registered office at 272 Bath St, Glasgow, G2 4JR.
2. Third party links
3. The information we collect about you
We use different methods to collect data from and about you including through direct interactions. For example, you may provide us with your personal data by filling in forms or by corresponding with us by post, phone, email or otherwise.
You can browse the Urbanly Site without entering any personal information. However, if you choose to request information about a product or service which is being advertised on the Urbanly Site or any of the products or services we or a Third Party (as defined below) offer, you will be asked to provide us with personal information through a request form. Information we collect may include: your name, email address, telephone number and postcode.
In certain circumstances, to process your request, we may request that you provide us with certain sensitive personal data (as defined in the applicable data protection laws from time to time, and includes: [gender]) in which event we will only collect and process such data where we have obtained your explicit consent.
We endeavour to only collect the minimum amount of information necessary to fulfil your request. However, some of the information that we ask you to provide is mandatory and if you do not provide it, we may not be able to action your request.
4. How we will use the information about you
When you provide your personal information to us, we may use it for any of the purposes described in this policy, including, but not limited to:
(a) where it is necessary for our/your legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
(b) to administer and manage the Urbanly Site, including: to continue to improve the user experience on the Urbanly Site; and to conduct benchmarking and data analytics, for example, determining the usage of the Urbanly Site and sorting and analysing your data for this purpose;
(c) to conduct quality and risk management assessments;
(e) where we need to comply with a legal/regulatory obligation; and/or
(f) any other purposes for which you have provided your personal information to Techonik (including, where you have provided your consent to Techonik using such personal information for the purposes set out in section 4 below).
5. Sharing your data with third parties
When you provide your personal information to us through the form on the Urbanly Site, you are consenting to Techonik sharing such personal information with the parties set out in the Schedule to this policy only for the Purpose (as defined below) (the “Third Party”).
The Third Party will only use your data for contacting you via phone, email, SMS or post from time to time for the purpose of marketing their products and/or services to you that, by providing your personal data on the Urbanly Site, you have expressed an interest (the “Purpose”). You have the right to opt-out of any of the Third Party’s marketing communications and, unless expressly stated otherwise and having obtained the necessary consents from you, the Third Party will only contact you for the Purpose.
6. Cookies and other information-gathering technologies
7. Security of your personal information
We adhere to highly stringent security measures to protect your personal information from misuse, loss or alteration. Only persons who have agreed to protect and keep confidential your personal information in line with this policy and our practices relating to data protection and confidentiality have access to your personal information you provide to us.
We take all appropriate measures to protect personal information; however, as any transfer of data over the internet is not completely secure we cannot guarantee absolutely the security of data transmitted to us over the internet. 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
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, governance 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 of 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, having regard to the applicable legal, regulatory, tax, accounting, governance or other requirements.
In some circumstances you can ask us to delete your data (see section 11 below).
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.
9. Transfer of personal information
When necessary and in very limited circumstances, your personal information may be transferred to and stored outside of the United Kingdom. This includes countries outside of the European Economic Area (“EEA”) which may not have local laws which specifically provide protection for personal information. Where your personal information is collected within the EEA and transferred out of the EEA, it will only be transferred where: the recipient is located in a country which provides an adequate level of protection; and/or, an agreement is in place which includes contractual clauses that are of a standard approved by the European Commission for the purposes of transferring personal information outside of the EEA.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
In accordance with this policy, we may transfer or disclose the personal data we collect to subcontractors and to their third party contractors and their subsidiaries and affiliates. This may be necessary for administrative, security, storage and management purposes and to process the information for the reason it has been submitted on the Urbanly Site and we will, where it is necessary to share your personal information in this way, ensure that there are necessary data protection and confidentiality protections in place with such third party affiliates.
10. Applicable law
The terms of this policy, its subject matter and its formation are governed by Scottish law. You and we both agree that the courts of Scotland will have exclusive jurisdiction.
11. Changes to this policy
We keep this policy under regular review. Every time you wish to use the Urbanly Site, please check these terms to ensure you understand the terms that apply at that time.
12. Your legal rights
Under the EU General Data Protection Regulation, you have a number of rights in respect of your personal data. In summary, these rights are to:
(a) 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.
(b) 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.
(c) 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.
(d) 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.
(e) 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.
(f) 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.
(g) 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.
13. Contact us
We welcome your views about the Urbanly Site and this policy. If you would like to contact us with any queries, comments or with a request concerning your rights under section 11 please send an email to [email protected] or send a letter to 272 Bath St, Glasgow, G2 4JR and we will endeavour to respond to your request in a timely manner.