Administrate Limited whose registered office is at Argyle House, 3 Lady Lawson Street, Edinburgh, EH3 9DR (“we”) are committed to protecting and respecting your privacy. This policy sets out the basis on which any personal data about you 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. For the purpose of the Data Protection Act 1998, the General Data Protection Regulations 2016 and any and all other applicable laws and regulations relating to the processing of personal data and privacy (“the Data Protection Legislation”), we act as the data controller.
1. Information We Collect
- 1.1 We may collect and process the following data about you:
- 1.1.1 information about you that you give us by filling in details on our website located at the domain name www.getadministrate.com (“our Website”) or by corresponding with us by phone, e-mail, Linkedin, social media (including, but not limited to, Facebook, Twitter, Pinterest, Instagram) or otherwise. The information you give us may include your name, address, e-mail address and phone number, gender, date of birth, financial and credit card information and other relevant information;
- 1.1.2 if you contact us, we may keep a record of that correspondence;
- 1.1.3 if you complete surveys that we use for research purposes (although for the avoidance of doubt you do not have to respond to such surveys), the information which you provide in response to that survey;
- 1.1.4 technical information regarding your visits to our Website including, but not limited to, the Internet protocol (IP) address used to connect your computer to the Internet, geographical location, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and
- 1.1.5 information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our Website (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), methods used to browse away from the page, and any phone number used to call us.
- 1.1.6 in cases where we have a reason to believe an organisation may benefit from our services we may send marketing emails to your work address. In these cases the marketing is assessed as legitimate interest as defined by the GDPR and a risk assessment is performed based on the ICO guidance for a 3-stage test.
2 IP addresses and Cookies
- 2.1 We may collect information about your computer, including, where available, your IP address, operating system and browser type, for system administration and Website quality improvements. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual.
3 How we use your personal data
- 3.1 We may use the information which we collect and hold about you in the following ways:
- 3.1.1 to carry out our obligations arising from any contracts entered into between you and us as is necessary for the performance of our contract with you;
- 3.1.2 to provide you with the information and services that you request from us prior to entering into a contract with us;
- 3.1.3 to provide you with information which you request from us as is in our legitimate interest to do so;
- 3.1.4 to answer your enquiries in accordance with our legitimate interests;
- 3.1.5 to maintain our business relationship with you, where you are a user of our Website as a customer in accordance with our legitimate interests;
- 3.1.6 in respect of candidates who have applied to work for Administrate Limited and its subsidiaries, to allow us to process and evaluate your application or CV in respect of any job vacancy with us that you have applied for as a step prior to entering into any contract with you;
- 3.1.7 to notify you about changes to our service as is in our legitimate interests to do so;
- 3.1.8 to provide you with information about other services we offer that are similar to those that you have already been provided with where it is in our legitimate interests to do so. You may unsubscribe at any time from receiving further communications from us for these purposes;
- 3.1.9 to provide you with information about services we feel may interest you, any news or industry updates, upcoming events or other information. You may unsubscribe at any time from receiving further communications from us for these purposes;
- 3.1.10 to ensure that content from our Website is presented in the most effective manner for you and for your computer as is in our legitimate interest;
- 3.1.11 to administer our Website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes so as to allow us to provide you with the best possible service and experience as is in our legitimate interest to do so; and
- 3.1.12 as part of our efforts to keep our Website safe and secure as is in our legitimate interest;
- For the purposes of the above, our ‘legitimate interests’ include the proper administration, monitoring and improvement of our business and the Website, the promotion of our business including direct marketing and the maintenance of the goodwill and reputation of Administrate Limited which includes the provision of excellent customer service and care.
4 Providing your personal data to others
- 4.1 We may share your personal information with:
- 4.1.1 Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, insofar as reasonably necessary for the purposes set out in this policy.
- 4.1.2 Selected third parties including:
- 184.108.40.206 business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you; and
- 220.127.116.11 those who perform functions on our behalf and who also provide services to us such as professional advisors as it is in our legitimate interest to do so.
- 4.1.4 We will disclose your personal information to third parties:
- 18.104.22.168 In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets as part of the sale or purchase process in order to allow such transaction to complete as is in our legitimate interest to do so;
- 22.214.171.124 If Administrate Limited or substantially all of its assets are acquired by a third party or its business merges with another business or company, we may share personal data with the new owners of the business or company or their professional advisers as is in our legitimate interests to do so; and
- 126.96.36.199 If we are under a duty to disclose or share your personal data in order to comply with any legal obligation or to protect the rights, property, or safety of Administrate Limited, our customers or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction as it is in our legitimate interests to do so.
5 Where we store your personal data and international transfers of your data
- 5.2 We and our other group companies have offices and facilities in the U.S.A. and Lebanon. Transfers to the offices in the U.S.A. and Lebanon will be protected by appropriate safeguards. Specifically the use of standard contractual clauses for the transfer of personal data to processors established in third countries under Directive 95/46/EC of the European Parliament and of the Council. All staff are obligated by contract to abide by privacy and security rules laid out by the parent company and are trained on these obligations regularly.
- 5.3 All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
- 5.4 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 Website; 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.
6 Retaining and deleting personal data
- 6.1 We shall ensure that any personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes. We will retain and delete your personal data for the periods set out in our Retention Policy which you can find at www.getadministrate.com/trust
- 6.2 Notwithstanding the above, we may retain your personal data where such retention is necessary for compliance with our legal obligations.
7 Your rights
- 7.1 You have the right to ask us not to process your personal data for marketing purposes. You can exercise your right to prevent such processing by not checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by clicking the unsubscribe link on any marketing communication we send to you by email or by filling this form: Data Subject Access Request
- 7.2 You can exercise the right to request any amendments or rectifications to your personal data by contacting us at Administrate Limited, 3 Lady Lawson Street, Edinburgh EH3 9DR or at the email address [email protected] or by filling this form: Data Subject Access Request if you would like us to delete or erase your data or, in certain circumstances, if you would like us to restrict the manner in which we process your data. Please note in certain circumstances we may not be able to delete or erase your personal data such as where this is still required for the purpose for which it was provided or where we have overriding legitimate interests in retaining your data.
- 7.3 Where you have given us your consent to the specific processing of your personal data please note you have the right to withdraw that consent at any time. Should you wish to withdraw your consent please contact us at the address above.
- 7.3 Our Website may, from time to time, contain links to and from external websites as a service to our visitors. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites. The provision of a link on our Website to an external website should not be taken as an endorsement by us of that external website, its owners or their products/services.
8 Access to information
- 8.1 The Data Protection Legislation gives you the right to access information held about you. Your right of access can be exercised in accordance with the Data Protection Legislation by contacting us at Administrate Limited, 3 Lady Lawson Street, Edinburgh EH3 9DR or at the email address [email protected] or by filling this form: Data Subject Access Request
- 10.1 If you are unhappy with the way in which we have collected or processed your personal data or have any other complaint in relation to our handling of your personal data, you can make a complaint to the Information Commissioner. Further information can be found on the Information Commissioner’s website at www.ico.org.uk or via their helpline on 0303 123 1113.