We, Us, Our, Flexciton – refers to Flexciton Limited

Data Protection Legislation – refers to all applicable privacy and data protection laws including (i) the General Data Protection Regulation ((EU) 2016/679), the Data Protection Act 2018 and any further or additional national implementing laws, regulations and secondary legislation in England and Wales relating to the processing of Personal Data and the privacy of electronic communications, as amended, replaced or updated from time to time, including the Privacy and Electronic Communications Directive (2002/58/EC) and the Privacy and Electronic Communications (EC Directive) Regulations 2003 (SI 2003/2426).

Introduction

Welcome to our privacy policy.

Data is a big part of what we do at Flexciton, so we are committed to maintaining the trust and confidence of everyone we work with. We respect your privacy and are committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you.

Purpose of this privacy policy

This privacy policy aims to give you information on how we collect and process your personal data through your use of this website.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Controller

Flexciton is the controller and responsible for your personal data.

If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us using the details set out in the Contact Us section below.

Complaints

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 (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to this Privacy Notice and your duty to inform us of changes

We keep this privacy policy under regular review. This version was last updated in June 2019.

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 your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

Personal Data we receive

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Your identity includes information such as first name, last name, title, date of birth, and other identifiers that you may have provided at some time.
• Your contact information includes information such as billing address, delivery address, email address, telephone numbers and any other information you have given to us for the purpose of communication or meeting.
• Identity data (including your first name, last name, title, company name, date of birth, and other identifiers that you may have provided at some time);
• Contact data (including billing address, delivery address, email address, telephone numbers, social media profiles and any other information you have given to us for the purpose of communication or meeting.);
• Technical Data (including internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website).
• Usage Data (including information about how you use our website, products and services].
• Marketing and Communications data (including your preferences in receiving marketing from us and/or third parties and your communications preferences);

How is your personal data collected?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity and Contact by filling in forms, providing us with your business card or by corresponding with us by post, phone, email or otherwise. This includes the personal data you provide when you:
• express an interest in downloading content from our website;
• request information about Flexciton services;
• attend a Flexciton event;
• accept our contact request on social media websites; or
• give us feedback or contact us.
• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy for further details.
• Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
• Technical Data from the following parties:
• analytics providers, such as Google based outside the EU;
• search information providers, such as Google based outside the EU;
• Identity and Contact Data from data brokers or aggregators such as Market Location, based inside the EU.
• Profile and Contact Data from social media and company websites.
• Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.

How will your data be used?

1. We will only use your data in circumstances where the data protection legislation allows us to. Most commonly, we will use your personal data in the following circumstances:
   
   (a) Where we need to perform a contract, we are about to enter into or have entered into with you;
   
   (b) 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;
   
   (c) Where we need to comply with a legal obligation;
   
   (d) Where we have received your informed and specific consent to do so

We have set out below, in a table format and within the numbered paragraphs thereafter, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Please note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

2. If in the future, we would like to process your personal data for a purpose other than that which it was collected for, we’ll provide you with information about that and request your consent before doing so.

Where your personal data is stored?

Personal data collected either directly or indirectly will be stored and processed in our CRM system (HubSpot).

Marketing and Emails

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and email marketing.

The information provided as a part of either the registration process to our e-newsletter or to download pdf content, we collect your personal data. We do it in order to deliver you the content you’ve requested for or to update you with our products or services as well as receive your feedback.

You will receive marketing communications from us if you have requested information from us or have given your specific and informed consent to receiving that marketing.

We use third-party providers, Webflow and HubSpot, to deliver our marketing communication and newsletter. We gather statistics around email opening and clicks using industry standard technologies to help us monitor and improve our e-newsletter. For more information, please see Webflow’s and HubSpot’s privacy policies.

Opting out                                                                                                          

You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and adjusting your marketing preferences.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us other than in accordance with this privacy notice.

Cookies

You can set your browser to refuse all or some browser cookies or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy].

​What we do not do with your personal data

Flexciton will not provide your personal data, received in accordance with the terms of this privacy notice, to third parties (other than those specified within this privacy notice) without your explicit and informed prior consent.

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

Procedures are in place to deal with any data security breach and we will notify you and any applicable regulator if a data breach has occurred.

Data retention

How long will we use your personal data for?

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 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 with respect to 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, and the applicable legal, regulatory, tax, accounting or other requirements.

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.

Your Rights

Under the data protection legislation, you have a number of rights with regard to your personal data. 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:
• 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.
• 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. We will advise you if this is the case at the time you withdraw your consent.

Amendments

We may update this policy from time to time by publishing a new version on our website. You should check this page occasionally to ensure you are happy with any changes to this policy.

Contact Us

1. We are registered in England under registration number 10184111, and our registered office is at Linen Court, Floor 7, 10 East Road, London, N1 6AD.
2. Our principal place of business is at Linen Court, Floor 7, 10 East Road, London, N1 6AD.
3. If you have any questions about this privacy notice or how we handle your personal information, you can contact us with attention to the Data Protection Officer:
   
   (a) by post to the postal address given above;
   
   (b) using our website contact form; or
   
   (c) by email, using info@flexciton.com

Cookies

We believe in being clear and open about how we collect and use data related to you. In the spirit of transparency, this policy provides detailed information about how and when we use cookies.

What is a cookie?

Cookies are small files which are stored on a user's computer. They and similar technologies enable you to be remembered when using that computer or device to interact with websites and online services and can be used to manage a range of features and content as well as storing searches and presenting personalised content.

Why do we use cookies?

Yes. As described in our Privacy Policy, Our Site uses cookies and similar technologies to distinguish you from other users of Our Site. This helps us to provide you with a good experience when you browse Our Site and also allows us to improve Our Site.  

They are necessary for the performance of a contract with you, or because using them is in our legitimate interests (where we have considered that these are not overridden by your rights), and, in some cases, where required by law, where you have consented to their use. If you have consented to using cookies then you can withdraw this consent at any time by disabling them as described below.

Cookies also help us keep your account safe. By continuing to visit or use our services, you are agreeing to the use of cookies and similar technologies for the purposes we describe in this policy.

How long do they last?

A number of cookies and similar technologies we use last only for the duration of your web session and expire when you close your browser. Others are used to remember you when you return to Our Site and will last for longer. 

What type of cookies do we use?

We use cookies and/or other similar technologies such as tracking GIFs, either alone or in combination with each other to create a unique device ID.

We use the following types of cookies:

• Strictly necessary cookies. These are cookies that are required for the operation of our website and under our terms with you. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
• Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us for our legitimate interests of improving the way our website works, for example, by ensuring that users are finding what they are looking for easily.
• Functionality cookies. These are used to recognise you when you return to our website. This enables us, subject to your choices and preferences, to personalise our content, greet you by name and remember your preferences (for example, your choice of language or region).

Disabling cookies

Most web browsers automatically accept cookies and similar technologies, but if you prefer, you can change your browser to prevent that and your help screen or manual will tell you how to do this. Alternatively, disable the cookies using our pop up when opening our site for the first time. 

The effect of disabling cookies depends on which cookies you disable but, in general, the website may not operate properly if all cookies are switched off.  If you only disable third-party cookies, you will not be prevented from making purchases on Our Site.

To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit wikipedia.org or www.aboutcookies.org.