Introduction

This policy, together with (i) the End User Licence Agreement entered into by you when you downloaded the App, (ii) the my-CI Customer Licence Agreement entered into by the organisation that who has created, allocated or authorised the Active Account required to allow you to access and use the App (referred to as “your organisation”) and (iii) any additional terms of use incorporated by reference into the End User Licence Agreement or my-CI Customer Licence Agreement (together our Terms of Use) applies to your use of:

• the software application developed by GENEO Software Limited known as my-CI (the my-CI App), however it is accessed; 
• our website portal and hosting services to access the my-CI App; and
• any third party tools embedded within the my-CI App, including ReCaptur. 

This policy sets out the basis on which any personal data we collect from you or your organisation, or that you or your organisation provide to us, will be processed by us. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

You can download a pdf version of the policy here: Privacy Policy

Important information and who we are

GENEO Software Limited is the controller and is responsible for your personal data (collectively referred to as "we", "us" or "our" in this policy).

Contact details

Our full details are:

• Full name of legal entity: GENEO Software Limited
• Name or title of data privacy manager: The GENEO Software Privacy Manager 
• Email address: software@geneo.co.uk
• Postal address: Dalton House, 9 Dalton Square Lancaster. LA1 1WD

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.

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

We keep our privacy policy under regular review.

This version was last updated on 19 September 2021. It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you when you next access the my-CI App. The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the my-CI App.

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 our relationship with you.

Third party links

The my-CI App utilises third party links, such as Fresh Desk, as an integrated part of its operation. Please note that these third parties have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as Contact Data. Please check these policies before you submit any personal data via these services.

The data we collect about you

We may collect, use, store and transfer different kinds of personal data about you as follows:

• Identity Data;
• Contact Data;
• Profile Data;
• Usage Data (including activity logs and the system you use to access the my-CI App);
• Location Data (including time zone); and
• Data regarding the business that has nominated you to access the my-CI App.

We explain these categories of data below.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs). Nor do we collect any information about criminal convictions and offences.

How is your personal data collected?

We will collect and process the following data about you:

• Information you give us. This is information you consent to giving us about you when you register to use the my-CI App and when you report a problem with the my-CI App. If you contact us, we will keep a record of that correspondence. This includes Identity Data, Contact Date, Profile Data and data regarding the business that has nominated you to access the my-CI App.
• Information we collect about you. Each time you use the my-CI App we will automatically collect personal data including Usage Data and Location Data. We collect this data using cookies and other similar technologies. Please see our cookie policy HERE for further details.
• Information we receive from your organisation. Your organisation may provide data about you when they authorise or allocate the Active Account required to enable to you to use the my-CI App.
• Information we receive from other sources including third parties and publicly available sources. We will receive personal data about you from various third parties as set out below:

• Device Data and Usage Data from the following parties:

1. Analytics and tag management providers such as Google LLC (based outside the EU); and
2. search information providers (based inside and outside the EU); and
3. Font Awesome (Fonticons, Inc), if you use the my-CI App to access information hosted on our website or within our hosted environment; and

• Unique application numbers. When you want to install or uninstall the my-CI App containing a unique application number or when your device or the my-CI APP searches for automatic updates, that number and information about your installation, for example, the type of operating system, may be sent to us.

Cookies

We use cookies to distinguish you from other users of the my-CI App, the distribution platform where you downloaded the my-CI App (namely Google Play App Store or Apple App Store) or our hosted services and to remember your preferences. This helps us to provide you with a good experience when you use the my-CI App and also allows us to improve the my-CI App. For detailed information on the cookies we use, the purposes for which we use them and how you can exercise your choices regarding our use of your cookies, see our cookie policy HERE.

How we use your personal data

We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:

• Where you have consented before the processing;
• Where we need to perform a contract we are about to enter or have entered with you;
• 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; and
• Where we need to comply with a legal or regulatory obligation.

See the glossary to find out more about the types of lawful basis that we will rely on to process your personal data.

We will only send you direct marketing communications by email or text if we have your consent. You have the right to withdraw that consent at any time by contacting us.

Purposes for which we will use your personal data

Disclosures of your personal data

When you consent to providing us with your personal data, we will also ask you for your consent to share your personal data with the third parties set out below for the purposes set out in the table Purposes for which we will use your personal data:

• Internal Third Parties as set out in the Glossary.
• External Third Parties as set out in the Glossary.
• 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.

International transfers

Many of our external third parties are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.

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:

• 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 certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.]
• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

Data security

All information you provide to us is stored on secure servers. Where we have given you (or where you have chosen) a password that enables you to access certain parts of our Services, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.

We will collect and store personal data on your Device using application data caches and browser web storage (including HTML5).

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.

Data retention

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request by contacting us.

In some circumstances you can ask us to delete your data: see Your legal rights below for further information.

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.

In the event that you do not use the my-CI App for a period of three months then we may treat your Active Account as expired and your personal data may be deleted.

Your legal rights

Under certain circumstances you have the following rights under data protection laws in relation to your personal data.

See page 9 to find out more about these rights:

• [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 or your personal data.]
• [Right to withdraw consent.]

You also have the right to ask us not to continue to process your personal data for marketing purposes.

You can exercise any of these rights at any time by contacting us at Dalton House, 9 Dalton Square Lancaster. LA1 1WD or by email to support@geneo.co.uk.

Glossary

1. Lawful basis

Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.

Legitimate Interest means the interest of our business in conducting and managing our business 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 obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

2. Third parties

3. Internal third parties

Other companies in the GENEO Software Group acting as joint controllers or processors.

4. External third parties

Service providers acting as processors based in countries inside and outside of the EEA who provide IT and system administration services, including the providers of cloud servers utilised in the provision of the Services.

Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.

HM Revenue and Customs, regulators and other authorities acting as processors or joint controllers based in the UK who require reporting of processing activities in certain circumstances.

5. 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 and you will not be able to continue to use the my-CI App. We will advise you if this is the case at the time you withdraw your consent.

Description of categories of personal data

• Identity Data: first name, last name, maiden name, username or similar identifier, marital status, title, date of birth, gender and details of your organisation.
• Contact Data: address, email address and telephone numbers.
• Device Data: includes the type of mobile device you use, a unique device identifier (for example, your Device's IMEI number, the MAC address of the Device's wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use and time zone setting.
• Content Data: includes information stored on your Device, including login information.

• Profile Picture: your profile picture, where one is supply by you or on your behalf.

• Profile Data: includes your username and password, your preferences, feedback and survey responses.
• Usage Data: includes details of your use of the my-CI App and the hosted services to which the my-CI relates or your visits to any of websites including, but not limited to, traffic data and other communication data, whether this is required for our own monitoring purposes or otherwise and the resources that you access.
• Communications Data: includes your communication preferences.