Privacy Notices

WEBSITE AND SERVICE USER PRIVACY NOTICE

Introduction

Igniyte Limited t/a Yoono respects your privacy and is committed to protecting your Personal Data. This Privacy Notice will tell you about to how we look after your Personal Data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

You can download a pdf version of the policy here: [LINK]. Please also see the Glossary below, which provides further detail on the meaning of some of the terms used in this Privacy Notice.

1. Important information and who we are

  • Purpose of this Privacy Notice This Privacy Notice aims to give you information on how Igniyte Limited t/a Yoono collects and processes your Personal Data through your use of this website and our products and services, including any data you may provide through this website when you:

  • use this website;

  • provide your business contact details as an employee;

  • place an order to use and when you use our products or services from us ;

  • contact us to make a complaint;

  • take part in a competition; or

  • contact us directly for another purpose. 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 Notice together with any other privacy, data protection or fair processing information we may provide on specific occasions when we are collecting or processing Personal Data about you (including when we provide you with our products and services) so that you are fully aware of how and why we are using it. This Privacy Notice supplements other notices and privacy policies and is not intended to override them. You can find our Service Terms here: [LINK]. Controller Igniyte Limited t/a Yoono is the controller and responsible for your Personal Data (collectively referred to as "Yoono", "we", "us" or "our" in this Privacy Notice). If you have any questions about this Privacy Notice, including any requests to exercise your legal rights (as referred to below), please contact us using the details set out below.

Contact details

If you have any questions about this Privacy Notice or our privacy practices, please contact us: Full name of legal entity: Igniyte Limited t/a Yoono Email address: simon@yoono.io Postal address: 1 Aire Street, Leeds LS1 4PR Telephone number: 0203 542 8689 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) if you are concerned in relation to how we collect or process your Personal Data. 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 the Privacy Notice and your duty to inform us of changes

We keep our Privacy Notice under regular review. This version was last updated on 4th December 2020. Historic versions can be obtained by contacting us using the details provided above. 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, applications and social media platforms. 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, plug-ins, applications or social media platforms and are not responsible for their privacy statements. When you leave our website, we encourage you to read the Privacy Notice of every website you visit.

2. The data we collect about you

Personal Data 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:

  • Identity Data includes first name, last name, username or similar identifier and title .

  • Contact Data includes billing address email address and telephone numbers .

  • Financial Data includes Paypal account details and activity .

  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us, including recordings of telephone calls .

  • Technical Data includes internet protocol (IP) address, your login data, 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 and our services .

  • Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses .

  • Usage Data includes information about how you use our website, products and services .

  • Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences .

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your Personal Data but is not considered Personal Data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Privacy Notice. We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide Personal Data

Where we need to collect Personal Data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our products or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

3. 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, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes Personal Data you provide when you:

    • enquire about, or place an order for, our products or services;

    • create an account on our website;

    • subscribe to our services or publications;

    • request marketing to be sent to you;

    • enter a competition, promotion or survey; 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, server logs and other similar technologies. [We may also receive Technical Data about you if you visit other websites employing our cookies.] Please see our cookie policy [LINK] for further details.

4. How we use your Personal Data

We will only use your Personal Data when the law allows us to. Most commonly, we will use your Personal Data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into 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.

  • Where we need to comply with a legal obligation.

Please see the Glossary and Lawful Basis sections of this Privacy Notice below to find out more about the types of lawful basis that we will rely on to process your Personal Data. Generally, we do not rely on consent as a legal basis for processing your Personal Data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us using the details above.

Purposes for which we will use your Personal Data

We have set out below, in a table format, 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 Personal 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.

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To register you as a new customer

(a) Identity

(b) Contact

Performance of a contract with you

To process and deliver your order including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or Privacy Notice

(b) Asking you to leave a review or take a survey

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To enable you to partake in a prize draw, competition or complete a survey

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

For training purposes, to prevent and detect crime (including fraud) and to administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) 

(a) Identity

(b) Contact

(c) Technical

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

(a) Technical

(b) Usage

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

For assessment and analysis and to make suggestions and recommendations to you about products or services that may be of interest to you, and to invite you to attend our events

(a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

(f) Marketing and Communications

Necessary for our legitimate interests (to develop our products/services and grow our business)


 

Marketing

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you have requested information from us or purchased products or services from us and you have not opted out of receiving that marketing.

Third party marketing

Opting out

You can ask us to stop sending you marketing messages at any time by contacting us using the details provided above. Where you opt out of receiving these marketing messages, this will not apply to Personal Data provided to us as a result of a product or service purchase or order, product or service experience or other transactions.

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 [LINK].

Change of purpose

We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures of your Personal Data

We may share your Personal Data with the parties set out below for the purposes set out in the table above: • 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 Notice. We require all third parties to respect the security of your Personal Data and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions.

6. International transfers

We do not transfer your Personal Data outside the European Economic Area (EEA ).

7. 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. We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data retention

How long will you use my 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 in 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. By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes. In some circumstances you can ask us to delete your Personal Data: see the Your Legal Rights section 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.

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation 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 Personal 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. If you wish to exercise any of the rights set out above, please contact us using the details set out above.

No fee usually required

You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. Glossary

LAWFUL BASIS

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 Personal 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.

THIRD PARTIES

Third Parties

• Service providers acting as processors based in [SPECIFIC COUNTRIES] who provide IT and system administration services. • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in [SPECIFIC COUNTRIES] who provide consultancy, banking, legal, insurance and accounting services. • HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

YOONO – THIRD PARTY DATA SUBJECT PRIVACY NOTICE

Introduction

If you post or publish content or information (which may include Personal Data) on any publicly-available website or social media platform (including, without limitation, Twitter, Facebook, Instagram, TikTok, Twitch and WeChat) then Igniyte Limited t/a Yoono may have collected and used (processed) Personal Data which relates to you as part of our products and services. We collect such publicly-available information, analyse and generate insight and reports based on it based upon requests made by customers of our products and services and offer them access to that information. Our products and services can be used by our customers in a number of ways, including for pre-and post-employment screening, investigations and anti-money laundering compliance. Under EU and UK Data Protection Legislation (including the GDPR and Data Protection Act 2018), you have a number of rights in relation to your Personal Data, which we set out below. Whenever we provide access to any information which may contain your Personal Data to our customers, our Service Terms restrict how it can be used and emphasise that any use must comply with relevant Data Protection Legislation. Igniyte Limited t/a Yoono respects your privacy and is committed to protecting your Personal Data. This Privacy Notice will tell you about to how we look after your Personal Data when we collect and process it and tell you about your privacy rights and how the law protects you. You can download a pdf version of the policy here: [LINK]. Please also see the Glossary below, which provides further detail on the meaning of some of the terms used in this Privacy Notice. 1. Important information and who we are

Purpose of this Privacy Notice

This Privacy Notice aims to give you information on how Igniyte Limited t/a Yoono collects and processes your Personal Data through collating content or information which you may have published or posted on any publicly-available website or social media platform.

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 Notice together with any other privacy, data protection or fair processing information 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 it. This Privacy Notice supplements other notices and privacy policies and is not intended to override them. You can find our Service Terms here: [LINK].

Controller

Igniyte Limited t/a Yoono is the controller and responsible for your Personal Data (collectively referred to as "Yoono", "we", "us" or "our" in this Privacy Notice). If you have any questions about this Privacy Notice, including any requests to exercise your legal rights (as referred to below), please contact us using the details set out below.

Contact details

If you have any questions about this Privacy Notice or our privacy practices, please contact us: Full name of legal entity: Igniyte Limited t/a Yoono Email address: admin@yoono.io Postal address: 1 Aire Street, Leeds LS1 4PR Telephone number: 0203 542 8689 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) if you are concerned in relation to how we collect or process your Personal Data. 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 the Privacy Notice and your duty to inform us of changes We keep our Privacy Notice under regular review. This version was last updated on 19th January 2021. Historic versions can be obtained by contacting us using the details provided above. 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, applications and social media platforms. 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, plug-ins, applications or social media platforms and are not responsible for their privacy statements. When you leave our website, we encourage you to read the Privacy Notice of every website you visit.

2. The data we collect about you

“Personal Data” 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 publicly-available Personal Data about you (dependent upon the source of that Personal Data and any restrictions imposed on its availability by the relevant website or social media platform) which we have grouped together as follows: • Identity Data includes first name, last name, username or similar identifier, title, date of birth and gender. • Content Data includes any and all content which you may have posted or published on the relevant website or social media platform by using your Identity Data to access your account; • Audio-Visual Data includes your profile picture or any other images or videos which you may have posted or published on the relevant website or social media platform by using your Identity Data to access your account;; • Employment Data includes your job title and profession; • Demographic Data includes your age, interests, gender and marital status; • Location Data: your geographical location. We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your Personal Data but is not considered Personal Data in law as this data will not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Privacy Notice. We may also use Personal Data about you which we have collected to analyse and infer other Personal Data about you through the provision of our products and services to our customers. Any inference will be made automatically by our proprietary software, based upon specific publicly-available posts and content. We do not aim to specifically collect any Special Categories of Personal Data (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data) about you within publicly-available information posted by you. Nor do we collect any information about criminal convictions and offences. If we do process your Special Category Data when providing our products and services to our customers, then this will be based on our legitimate interest in providing those services.

3. How is your Personal Data collected?

Yoono runs keywords and combinations of keywords provided by our users through an API that scrapes Google search results. It then passes the content it finds in those results through an algorithm to score that content for relevance and checks against our in-house databases to exclude certain results. Scored and checked content then passes through to reports provided to our users where content of interest to them is flagged.

4. How we use your Personal Data We will only use your Personal Data when the law allows us to. Most commonly, we will use your Personal Data in the following circumstances: • 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. • Where we need to comply with a legal obligation.

[We do not use algorithms to make automated decisions about you in violation of any applicable law or Data Protection Legislation or in any way which produces a significant legal effect.]

Please see the Glossary and Lawful Basis sections of this Privacy Notice below to find out more about the types of lawful basis that we will rely on to process your Personal Data. Purposes for which we will use your Personal Data We have set out below, in a table format, 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 Personal 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.

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To provide our products and services to our customers

(a) Identity

(b) Content

(c) Audio-Visual

(d) Employment

(e) Demographic

(f) Location

Necessary for our legitimate interests (to provide our products and services to our customers, to develop them, and to grow our business)

For training purposes, to prevent and detect crime (including fraud) and to administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) 

(a) Identity

(b) Content

(c) Audio-Visual

(d) Employment

(e) Demographic

(f) Location

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation 


 

Change of purpose We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law. 1. Disclosures of your Personal Data We may share your Personal Data with the parties set out below for the purposes set out in the table above: • Our customers, for the purpose of providing our products or services; • 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 Notice. We require all third parties, including our customers through our Service Terms, to respect the security of your Personal Data and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions. 2. International transfers We do not transfer your Personal Data outside the European Economic Area (EEA). 3. 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. We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. 4. Data retention How long will you use my 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 in 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 Personal Data: see the Your Legal Rights section 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. 5. Your legal rights Under certain circumstances, you have rights under data protection laws in relation 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 Personal 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. If you wish to exercise any of the rights set out above, please contact us using the details set out above.