We appreciate the trust you place in us when sharing your personal data. The security of that data is very important to us. In this document, we will explain how we collect, use and protect your personal data.
We will also explain what rights you have with regards to your personal data and how you can exercise those rights.
Cybernet Europe is the data controller. This means that Cybernet Europe determines what data is collected, how this data is going to be used and how this data is protected.
Our registered office address is:
Essex CO2 8LA
If you have questions about how we process personal data, or would like to exercise your data subject rights, please email us at firstname.lastname@example.org.
We collect personal data from you for one or more of the following purposes:
The table in Section 4 below provides more detail about the data that we collect for each of these purposes, the lawful basis for doing so, and the period for which we will retain each type of data.
In addition, and in order to ensure that each visitor to any of our websites can use and navigate the site effectively, we collect the following:
In Section 7 below, we identify your rights in respect of the personal data that we collect and describe how you can exercise those rights.
The table below describes the various forms of personal data we collect and the lawful basis for processing this data. We have processes in place to make sure that only those people in our organisation who need to access your data can do so. A number of data elements are collected for multiple purposes, as the table below shows. Some data may be shared with third parties and, where this happens, this is also identified below.
When we process on the lawful basis of legitimate interest, we apply the following test to determine whether it is appropriate:
The purpose test - is there a legitimate interest behind the processing?
Necessity test - is the processing necessary for that purpose?
Balancing test - is the legitimate interest overridden, or not, by the individual's interests, rights or freedoms?
|Purpose of collection||Information category||Data collected||Purpose for collection||Lawful basis for processing||Data shared with?||Retention period|
|1. To provide you with information||Subject matter information||Name, company name, geographic location, email address, business sector.||To provide appropriate online or email information about products and services that you have requested||Contractual fulfilment||Internally only||
Maximum 8 years from the data the information is collected.
6 months if a marketing email is left unopened.
|To provide further, related, online or email information and ongoing news updates in relation to the identified area of interest.||Legitimate interest||Internally only|
|Telephone number||Follow-up to ensure requested information meets needs and identify further requirements||Legitimate interest||Internally only|
|Personal contact information as provided through website forms or at trade shows or any other means.||General mailing list subscription||Consent||Internally only|
|2. Transactional information||Transaction details||Name, physical address, email address, telephone number, bank account details (for credit accounts), other medium of content delivery||To process purchase transactions for products and services with customers, and to ensure any transaction issues can be dealt with.||Contractual performance||Internally only||
Maximum 8 years from the date of the performance of the contract.
6 months from the data the data subject has input personal information but has not proceeded with a transaction.
8 years for VAT records from the performance of the contract.
|For accounting and taxation purposes||Statutory obligation||Internally and professional advisers|
|Documentation should any contractual legal claim arise||Legitimate Interest||Internally and professional advisers|
|Payment card data||Primary account number (PAN), cardholder name, service code, expiration date||To fulfil purchase requests using payment cards||Contractual performance||Payment card companies, all in line with PCI DSS||Only retained whist authorisation is pending.|
|3. Fulfilment information||Fulfilment data||Name, contact details||Licensing details necessary for allocation and maintenance of a licence purchased for use with software and related products.||Contractual performance||Internally and any third parties whose products or services you may have purchased from us.||Maximum 6 years from the date of the performance of the contract.|
|Name, address(es), email address, contact details||Actual delivery of products or services, in physical or digital form, that you may have purchased from us.||Contractual performance||Internally and any third party logistics or supplier companies with whom we contract in order to fulfil these requirements.|
|4. Security||Security information||Technical information, as described above, plus any other information that may be required for this purpose||To protect our websites and infrastructure from cyber attack or other threats and to report and deal with any illegal acts.||Legitimate interest||Internally, forensic and other organisations with whom we might contract for this purpose.||Relevant statutes of limitation.|
|5. Communications||Contact information||Names, contact details, identification details||To communicate with you about any issue that you raise with us or which follows from an interaction between us.||Legitimate interest||Internally and, as necessary, with professional advisers.||Relevant statutes of limitation.|
Cybernet Europe is a UK-domiciled organisation whose primary offices are in the UK.
Our business is Cyber Essentials certified and all our payment card processing is in compliance with PCI DSS.
We have what we believe are appropriate security controls in place to protect personal data. We do not, however, have any control over what happens between your device and the boundary of our information infrastructure. You should be aware of the many information security risks that exist and take appropriate steps to safeguard your own information. We accept no liability in respect of breaches that occur beyond our sphere of control.
As a data subject whose personal information we hold, you have certain rights. If you wish to exercise any of these rights, please email to email@example.com or use the information supplied in the Contact us section below. In order to process your request, we will ask you to provide two valid forms of identification for verification purposes. Your rights are as follows:
If there are exceptional circumstances that mean we can refuse to provide the information, we will explain them. If requests are frivolous or vexatious, we reserve the right to refuse them. If answering requests is likely to require additional time or occasions unreasonable expense (which you may have to meet), we will inform you.
Alternatively, you can contact us at our UK HQ using the following postal address or telephone numbers:
GDPR Compliance Manager
Essex CO2 8LA
Telephone: +44 (845) 539.1200
Should you wish to discuss a complaint, please feel free to contact us using the details provided above. All complaints will be treated in a confidential manner.
Should you feel unsatisfied with our handling of your data, or about any complaint that you have made to us about our handling of your data, you are entitled to escalate your complaint to a supervisory authority within the European Union. For the United Kingdom, this is the Information Commissioner's Office (ICO), who is also our lead supervisory authority. Its contact information can be found at https://ico.org.uk/global/contact-us.