Last updated: March 2019
Please read this privacy notice (Privacy Notice) carefully as it describes our collection, use, disclosure, retention and protection of your personal information.
This Privacy Notice applies to any website, application or service which references this Privacy Notice. Where you provide us with your personal information in any
of the ways described in section 2 below, you agree that we may collect, store and use it : (a) in order to perform our contractual obligations to you ; (b) based
on our legitimate interests for processing (i.e. for internal administrative purposes, data analytics and benchmarking (see section 3 below for more information),
maintaining automated back-up systems or for the detection or prevention of crime) ; or (c) based on your consent, which you may withdraw at any time, as described in this
Privacy Notice.
Who we are
This Privacy Notice applies to all products, applications and services offered by The Positive8 Limited (a company incorporated in England with company registration
number 04034265 and whose registered office address is 92 Devonport Road, Shepherds Bush, London. W12 8NU, United Kingdom), and its affiliates, but excludes any products
applications or services that have separate privacy notices which do not incorporate this Privacy Notice.
How we collect information To the extent permissible under applicable law, we collect information about you and any other party whose details you provide to us when you:
register to use our websites, applications or services (including free trials); this may include your name (including business name), address, email address and telephone
number. We may also ask you to provide additional information about your business and your preferences;
place an order using our websites, applications or services; this may include your name (including business name), address, contact (including telephone number and email address) and payment details;
complete online forms (including call back requests), take part in surveys, post on our message boards, post any blogs, enter any competitions or prize draws, download
information such as white papers or other publications or participate in any other interactive areas that appear on our website or within our application or service;
interact with us using social media; and
provide your contact details to us when registering to use or accessing any websites, applications or services we make available or when you update those details;
contact us offline, for example by telephone, fax, SMS, email or post.
We will also collect your information where you only partially complete and/or abandon any information inputted into our website and/or other online forms and may use
this information to contact you to remind you to complete any outstanding information and/or for marketing purposes.
We also collect information from your devices (including mobile devices) and applications you or your users use to access and use any of our websites, applications or
services (for example, we may collect the device identification number and type, location information and connection information such as statistics on your page views,
traffic to and from the sites, referral URL, ad data, your IP address, your browsing history and your web log information) and we will ask for your permission before we
do so. We may do this using cookies or similar technologies (as described in section 8 below).
We may enhance personal information we collect from you with information
we obtain from third parties that are entitled to share that information; for example, information from credit agencies, search information providers or public sources (e.g. for customer due diligence purposes), but in each case as permitted by applicable laws.
Providing us with information about others
If you provide us with personal information about someone else, you are responsible for ensuring that you comply with any obligation and consent obligations under
applicable data protection laws in relation to such disclosure. In so far as required by applicable data protection laws, you must ensure that you have provided the required
notices and have obtained the individual’s explicit consent to provide us with the information and that you explain to them how we collect, use, disclose and retain their personal
information or direct them to read our Privacy Notice.
How we use your information
To the extent permissible under applicable law, we use your information to: provide any information and services that you have requested or any applications or services that you have ordered;
compare information for accuracy and to verify it with third parties;
provide, maintain, protect and improve any applications, products, services and information that you have requested from us;
manage and administer your use of applications, products and services you have asked us to provide;
manage our relationship with you (for example, customer services and support activities);
monitor, measure, improve and protect our content, website, applications and services and provide an enhanced, personal, user experience for you;
undertake internal testing of our website, applications, systems and services to test and improve their security, provision and performance, in which case, we would pseudonymise any information used for such purposes, and ensure is it only displayed at aggregated levels which will not be linked back to you or any living individual;
provide you with any information that we are required to send you to comply with our regulatory or legal obligations;
detect, prevent, investigate or remediate, crime, illegal or prohibited activities or to otherwise protect our legal rights (including liaison with regulators and law enforcement agencies for these purposes);
contact you to see if you would like to take part in our customer research (for example, feedback on your use of our applications, products and services);
to monitor, carry out statistical analysis and benchmarking, provided that in such circumstances it is on an aggregated basis which will not be linked back to you or any living individual;
To the extent permitted by applicable law, we retain information about you after the closure of your Positive8 account, if your application for a Positive8 account is declined or if you decide not to proceed. This information will be held and used for as long as permitted for legal, regulatory, fraud prevention and legitimate business purposes. Our website, applications and services may contain technology that enables us to:check specific information from your device or systems directly relevant to your use of the websites, applications or services against our records to make sure the websites, applications or services are being used in accordance with our end-user agreements and to troubleshoot any problems;
obtain information relating to any technical errors or other issues with our website, applications and services;
collect information about how you and users use the functions of the features of our website, applications and services; and
gather statistical information about the operating system and environment from which you access our applications or services.
You can manage your privacy settings within your browser or our applications and services (where applicable).
In addition to the purposes described in this section 3, we may also use information we gather to deliver targeted advertising, marketing (including in-product messaging) or information to you which may be useful, based on your use of the website, applications or services or any other information we have about you (depending on the websites, applications or services, you may able to configure these features to suit your preferences). Sections 5 of this Privacy Notice provides further details on how we will do this.
We may monitor and record our communications with you, including e-mails and phone conversations. Information which we collect may then be used for training purposes, quality assurance, to record details about our website, applications and services you order from us or ask us about, and in order to meet our legal and regulatory obligations generally.
Mobile data
We may obtain information through mobile applications that you or your users install on their mobile devices to access and use our website, applications or services or which you or your users use to provide other services related to that mobile application (for example, to sync information from our application or service with such mobile application). These mobile applications may be our own mobile applications or those belonging to third parties. Where the mobile application belongs to a third party, you must read that third party’s own privacy notice as it will apply to your use of that third party mobile application. We are not responsible for such third party mobile applications and their use of your personal information.
Mobile applications may provide us with information related to a user’s use of that mobile application and use of our applications and services accessed using that mobile application. We may use such information to provide and improve the mobile application or our own application or services. For example, activity undertaken within a mobile application may be logged.
You can configure our mobile application’s privacy settings on your device but this may affect the performance of that mobile application and the way it interacts with our applications and services.
Data analytics and benchmarking
We may use information generated and stored during your use of our services for our legitimate business interests to enable us to give you the best service and/or solutions and the best experience. These purposes include to: deliver advertising, marketing (including in-product messaging) or information to you which may be useful to you, based on your use of services;
carry out research and development to improve our services, products and applications;
develop and provide new and existing functionality and services (including statistical analysis, benchmarking and forecasting services); and
provide you with location based services (for example location relevant content) where we collect geo-location data to provide a relevant experience.
Whenever we use your information for our legitimate interests, we will ensure that your information is processed on a pseudonymised basis and displayed at aggregated levels, which will not be linked back to you or to any living individual. You have the right to object to processing based on our legitimate interests, and if you wish to do so, please contact us at
[email protected] to discuss this further. If you object, this may affect our ability to provide certain services and/or solutions for your benefit.
Changes to this Privacy Notice
We may change this Privacy Notice from time to time. However we will not reduce your rights under this Privacy Notice. We will always update this Privacy Notice on our website, so please try to read it when you visit the website (the ‘last updated’ reference tells you when we last updated this Privacy Notice).
Security and storage of information
We will keep your information secure by taking appropriate technical and organisational measures against its unauthorised or unlawful processing and against its accidental loss, destruction or damage. We will do our best to protect your personal information but we cannot guarantee the security of your information which is transmitted to our website, applications or services or to other website, applications and services via an internet or similar connection. If we have given you (or you have chosen) a password to access certain areas of our websites, applications or services please keep this password safe – we will not share this password with anyone.
If you believe your account has been compromised, please contact us at
[email protected].
Other sites and social media
If you follow a link from our website, application or service to another site or service, this Privacy Notice will no longer apply. We are not responsible for the information handling practices of third party sites or services and we encourage you to read the privacy notices appearing on those sites or services. Our websites, applications or services may enable you to share information with social media sites, or use social media sites to create your account or to connect your social media account. Those social media sites may automatically provide us with access to certain personal information retained by them about you (for example any content you have viewed). You should be able to manage your privacy settings from within your own third party social media account(s) to manage what personal information you enable us to access from that account.
Cookies, Analytics and Traffic Data
Cookies are small text files which are transferred from our websites, applications or services and stored on your device. We use cookies to help us provide you with a personalised service, and to help make our websites, applications and services better for you. Our cookies may be session cookies (temporary cookies that identify and track users within our websites, applications or services which are deleted when you close your browser or leave your session in the application or service) or persistent cookies (cookies which enable our websites, applications or services to “remember” who you are and to remember your preferences within our websites, applications or services and which will stay on your computer or device after you close your browser or leave your session in the application or service). We use the following different types of cookies:
Strictly necessary cookies
These are cookies which are needed for our websites, applications or services to function properly, for example, these cookies allow you to access secure areas of our website or to remember what you have put into your shopping basket.
Performance cookies and analytics technologies
These cookies collect information about how visitors and users use our websites, applications and services, for instance which functionality visitors use most often, and if they get error messages from areas of the websites, applications or services. These cookies don't collect information that identifies a visitor or user. All information these cookies collect is aggregated and therefore anonymous. We only use these cookies to improve how our website, applications and services work.
Functionality cookies
These cookies allow our websites, applications and services to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customise. They may also be used to provide services you have asked for. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites.
Targeting or advertising cookies
These cookies are used to deliver adverts more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. They are usually placed by advertising networks with the website operators’ permission. They remember that you have visited a website and this information is shared with other organisations such as advertisers. Quite often targeting or advertising cookies will be linked to site functionality provided by the other organisation.
Web beacons and parameter tracking
We also use cookies and similar software known as web beacons to count users who have visited our website after clicking through from one of our advertisements on another website or in emails and to collect details of any products or services purchased. These web beacons collect limited information which does not identify particular individuals. It is not possible to refuse the use of web beacons. However, because they are used in conjunction with cookies, you can effectively disable them by setting your browser to restrict or block cookies.
IP Address and traffic data
We keep a record of traffic data which is logged automatically by our servers, such as your Internet Protocol (IP) address, device information, the website that you visited before ours and the website you visit after leaving our site. We also collect some site, application and service statistics such as access rates, page hits and page views. We are not able to identify any individual from traffic data or site statistics.