Digital Catapult (“We”, “Us”) is committed to protecting and respecting your privacy. This Privacy and Cookies Policy (“Policy”), together with any other documents referred to therein, including but not limited to our Terms of Use, sets out the basis on which the personal data collected from you, or that you provide to Us 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 and how we use cookies.
For the purpose of the General Data Protection Regulation (“GDPR”, from the GDPR implementation date) or, until GDPR implementation date, the Data Protection Act 1998, (collectively the “Data Protection Laws”), and in relation to the Digital Supply Chain Hub Platform [or Platform] Digital Catapult (company no. 07964699) shall be the Data Controller together with one of its suppliers (Ethical Fashion Group Limited), and each, severally, not jointly, be the Data Controller for the users on the Platform, and shall each own the data relating thereto.
1.1 YOUR PERSONAL INFORMATION
Information we collect from you
We collect and process some or all of the following types of information from you in the course of your use of our Platform or you involvement in our innovation programmes or similar services:
Information that you provide by filling in forms on the Platform or as part of the registration process for our events, programmes or newsletters. We may also ask you for further information when you contact us via the Platform. This includes any information that you post or upload to the Platform and any information you provide to us when you register on the Platform, participate in online discussion forums, fill out any form or enter competitions and promotions. It also includes information you give us when you contact us with feedback, report a problem with the Platform or communicate with us for any other reason.
Specifically, personal details may include name, email address, address or any information (such as information about your business and interests), your interests, your location, your image, what you are looking for, your job role and experience, your skills, and information about the organisation that you work for.
Information you input when using our Platform, completing our surveys that We use for research purposes, although you do not have to respond to them, forms and using our services. By “personal data”, we mean any information which directly or indirectly identifies you and includes any identifiers such as IP address.
If you contact Us, We may keep a record of that correspondence.
With regard to each of your visits to the Platform we will automatically collect the following information:
Technical information which may include your IP address, operating system and browser type.
Details of your visits to the Platform which may include but not limited to traffic data, location data, weblogs, search data, other communication data, and the resources that you access and download, and the people and organisations that you click on, connect with, message, view, bookmark or share (e.g. articles, resources, video, individual and business profiles and ads (this could include ads on or off the Platform)).
We use log-ins, cookies, device information (as described below) and IP address to identify you and log your use.
Device information. We receive data from your devices and networks, including location data. When you visit or leave our services (including our plugins or cookies or similar technology on the Platforms of others), we receive the URL of both the Platform you came from and the one you go to next. We also get information about your IP address, proxy server, operating system, web browser and add-ons, device identifier and features, and/or ISP or your mobile carrier. If you use our services from a mobile device, that device will send us data about your location. Most devices allow you to prevent location data from being sent to us by setting your preferences and we honour your preferences.
1.2 USES MADE OF YOUR INFORMATION
Lawful basis for processing
We rely on your consent as provided when you enter your details or otherwise sign up to using our services as the lawful basis on which We collect and use your personal data, that includes for the purposes of making the Platform available to you in accordance with our Terms of Use
If We enter into a contract with you, We rely on performance of a contract as the lawful basis on which We collect and use your personal data.
We may also rely on legitimate interests as the lawful basis on which We collect and use your personal data. Our legitimate interests are connecting potential business partners, investors and innovators or connecting similar parties together in line with our mandate to promote the development and early adoption of advanced digital technology.
Purposes of processing
We use information held about you in the following ways:
To provide you with our services, which may include connecting you with relevant business partners, investors, collaborators, innovators or academic institutions;
To ensure that content on the Platform is presented in the most effective manner for you and for the device(s) you use to access and view the Platform;
To provide you with information and details of events that you request from Us or which We feel may interest you.
To carry out our obligations arising from any contracts entered into between you and Us.
To allow you to participate in interactive features of our service, when you choose to do so.
To notify you about changes to our service.
To carry research on and measure our impact and effectiveness of our activities on Your business and the wider sector.
Marketing
In addition to the above uses We may use your information, to notify you about goods or services which may be of interest to you. Where We do this, We will contact you by electronic means (e-mail or SMS) only if you have consented to such communication or where we have a lawful, legitimate interest in doing so. If you do not want Us to use your data in this way please either (i) tick the relevant box situated on the form on which We collect your data (for example, the contact form or registration form); (ii) unsubscribe from our electronic communications using the method indicated in the relevant communication; or (iii) inform Us at any time by contacting Us at the contact details set out below.
1.3 DISCLOSURE OF YOUR INFORMATION
We routinely disclose your personal data to third parties as follows:
We may pass your information to our third party service providers, agents, subcontractors and other associated organisations for the purposes of completing tasks and providing services to you on our behalf (e.g. to host our servers). Due to the nature of our organisation, this may include disclosing your information to programme delivery partners, such as The Department for Digital, Culture, Media and Sports, The Accelerator Network, Inogesis, and Centre for Secure Information Technologies for the purposes of the programme, and to contact you in the future for help with measuring our impact on your business and the wider sector.
We may disclose your personal data to any member of our corporate group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006 (where applicable).
We may also disclose your personal data to third parties:
in the event that We sell or buy any business or assets, in which case We may disclose your personal data to the prospective seller or buyer of such business or assets; or
if We or substantially all of our assets are acquired by a third party, in which case personal data held by Us about our customers will be one of the transferred assets (including a prospective seller or buyer in the event of a sale or purchase of any business or asset of our suppliers that operate the Platform, so that the buyer can continue to operate the Platform);or
if We are under a duty to disclose or share your personal data in order to comply with any legal or statutory or audit obligation, or in order to enforce or apply our Terms and Conditions on the Platform or any other contracts with you; or
to protect Our rights, property, or safety or that of our affiliated entities and our users and any third party We interact with to provide the Platform; or
in relation to other, selected third parties only, only to the extent that you have consented to such selected third parties notifying you about certain goods or services, which may be of interest to you (including selected third parties and other users where you post Material on the Platform (as defined in the Terms of Use of the Platform); or
our selected partners or suppliers where you have chosen to participate in surveys, enter competitions and promotions or activities relating to your use of the Platform and have consented to our sharing your personal data with such partners of suppliers for direct marketing purposes; or
third parties that we engage to provide services for us. Where we provide your personal data to such third parties, they are required to keep your personal data confidential and secure, and must only use your personal data as instructed by us; and
our partners or service providers, including for marketing purposes or where you have chosen to share your information through various features and functionalities provided via the Platform.
In our fight against spam on our Platform, we may use the reCAPTCHA tool when you submit information to us. This helps ensure requests we receive are genuine. Certain information about you and your device may be collected. reCAPTCHA data collection and use is governed by the Google Privacy Policy and our Terms of Use. Please make sure you have reviewed these.
Other than as set out above, and save insofar as is necessary in order for Us to carry out our obligations arising from any contracts entered into between you and Us, We will not share your data with third parties unless We have procured your express consent to do so.
1.4 STORING YOUR PERSONAL DATA
Security
We take appropriate measures to ensure that any personal data is kept secure, including security measures to prevent personal data from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal data to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where We are legally required to do so.
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 the Platform; 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.
The Platform may, from time to time, contain links to and from the Platforms of our partner networks and programmes, advertisers, social media Platforms and affiliates. If you follow a link to any of these Platforms, please note that some of these Platforms may have their own privacy policies and terms of use and that we do not accept any responsibility or liability for these policies and terms of use. Please check these policies before you submit any personal data to these Platforms.
We may transfer your information to any destination within the European Economic Area (“EEA”), where it may also be stored. Your information may be processed by staff within the EEA, who work for us or for one of our suppliers. Such staff may be engaged in, among other things, providing support services. We will implement appropriate administrative, technical and physical safeguards to protect the confidentiality, integrity and availability of your personal data. We will take all steps reasonably necessary to ensure that your personal data is treated securely and in accordance with this Privacy & Cookies Policy.
Where you have chosen a password which enables you to access certain parts of the Platform, you are responsible for keeping this password confidential.
If your personal details change you may update them by contacting Us using the contact details below. If you have any questions about how We use data collected which relates to you, please contact Us by sending a request by email to the contact details below.
We will endeavour to update your personal data within ten (10) working days of any new or updated personal data being provided to Us, in order to ensure that the personal data We hold about you is as accurate and up to date as possible.
How long we keep your personal data
We will hold Your contact details (name, email address, information about your business and other contact details) for five years from the last point of contact, provided that there is no statutory, legal or contractual requirement to retain it for longer. We are required to keep this information for this period of time so we are able to measure and report upon our impact on your business and the wider business sector, which is a contractual requirement of Innovate UK.
Where we store your personal data
The data that We collect from you may be processed by our direct and indirect subsidiaries and/or subcontractors and/or suppliers which may be entities based in countries outside of the EEA for the purposes of providing you with support services in relation to the Platform and may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for Us or for one of our suppliers. Such staff may be engaged in, among other things, the fulfilment of your orders, the processing of your payment details and the provision of support services.
Such countries do not have the same data protection laws as the United Kingdom and EEA. Whilst the European Commission has not given a formal decision that such countries provide an adequate level of data protection similar to those which apply in the United Kingdom and EEA, any transfer of your personal data will be subject to a EU-US Privacy Shield (as permitted under Article 46(5) of the General Data Protection Regulation) that are designed to help safeguard your privacy rights and give you remedies in the unlikely event of a misuse of your personal data.
If you would like further information please contact Us (see ‘Contact’ below). We will not otherwise transfer your personal data outside of the EEA or to any organisation (or subordinate bodies) governed by public international law or which is set up under any agreement between two or more countries.
1.5 YOUR RIGHTS
Under the General Data Protection Regulation you have a number of important rights free of charge. In summary, those include rights to:
access to your personal data and to certain other supplementary information that this Policy is already designed to address
require Us to correct any mistakes in your information which We hold
require the erasure of personal data concerning you in certain situations
receive the personal data concerning you which you have provided to Us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
object at any time to processing of personal data concerning you for direct marketing
object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
object in certain other situations to our continued processing of your personal data
otherwise restrict our processing of your personal data in certain circumstances
claim compensation for damages caused by our breach of any data protection laws.
For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please:
email Us at privacy@digicatapult.org.uk;
let Us have enough information to identify you (name, email address and information as to how you have worked with Us;
let Us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
let Us know the information to which your request relates.
1.6 HOW TO COMPLAIN
We hope that We can resolve any query or concern you raise about our use of your information.
The General Data Protection Regulation also gives you the right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone: 0303 123 1113.
1.7 CHANGES TO OUR PRIVACY POLICY
We reserve the right to modify this Policy at any time. Any changes We may make to our Policy in the future will be notified and made available to you using the Platform. Your continued use of the services and the Platform shall be deemed your acceptance of the varied privacy policy.
1.8 INFORMATION ABOUT OUR USE OF COOKIES AND IP ADDRESSES
We may collect information about your mobile phone, computer or other device from which you access the Platform including where available your IP address, operating system and browser type, for systems administration and to report aggregate information to Innovate UK. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual. We may, however, use such information in conjunction with the data We have about you in order to track your usage of our services.
Our Platform uses cookies to distinguish you from other users of our Platform. This helps Us to provide you with a good experience when you browse our Platform and also allows Us to improve the Platform. By using our Platform you agree to our use of cookies as more specifically set out below.
A cookie is a small file of letters and numbers that We store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.
The cookies We use include:
“Analytical” cookies. They allow Us to recognise and count the number of visitors and to see how visitors move around the Platform when they are using it. This helps Us to improve the way our Platform works, for example, by ensuring that users are finding what they are looking for easily.
“Strictly necessary” cookies. These are cookies that are required for the operation of our Platform. They include, for example, cookies that enable you to log into secure areas of our Platform, use a shopping cart or make use of e-billing services.
“Functionality” cookies. These are used to recognise you when you return to our Platform. This enables Us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
“Targeting” cookies. These cookies record your visit to our Platform, the pages you have visited and the links you have followed to our affiliates Platforms. We will use this information to make our Platform, offers e-mailed to you and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
Please note that third parties affiliates may also use cookies, over which We have no control.
You may block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of the Platform. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies as soon as you visit our Platform.
1.9 CONTACT
All questions, comments and requests regarding this Privacy and Cookies Policy should be sent:
by email at privacy@digicatapult.org.uk;
phoning Us on 020 3882 3557 ; or
by writing to Us at Digital Catapult, Level 9, 101 Euston Road, London, NW1 2RA, marked as a “Data Protection query”.
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