Privacy Policy & Cookies

Introduction

S2 Partnership respects your privacy and is committed to protecting your personal data. S2 Partnership Limited is certified to ISO 27001 for Information Security Management.

This privacy notice will inform you about how we look after your personal data when you visit our websites (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

This privacy policy is designed to provide an overview of the types of information we may collect about you, how we collect and use this information, who we might share it with, the steps we take to keep your data secure and confidential and your rights to your information.

This privacy policy applies to www.s2partnership.co.uk and www.s2riskwise.co.uk.

This privacy notice is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.

  1. [IMPORTANT INFORMATION AND WHO WE ARE]
  2. [THE DATA WE COLLECT ABOUT YOU]
  3. [HOW IS YOUR PERSONAL DATA COLLECTED]
  4. [HOW WE USE YOUR PERSONAL DATA]
  5. [DISCLOSURES OF YOUR PERSONAL DATA]
  6. [INTERNATIONAL TRANSFERS]
  7. [DATA SECURITY]
  8. [DATA RETENTION]
  9. [YOUR LEGAL RIGHTS]
  10. [GLOSSARY]

1.  IMPORTANT INFORMATION AND WHO WE ARE

PURPOSE OF THIS PRIVACY NOTICE

This privacy notice aims to give you information on how S2 Partnership Limited collects and processes your personal data through your use of this website, including any data you may provide through this website when you complete and submit one of our website forms, for example, to sign up to our newsletter, request information or book a product demonstration.

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 notice or fair processing notice 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 notice supplements the other notices and is not intended to override them.

CONTROLLER

S2 Partnership Limited is the controller and responsible for your personal data (collectively referred to as S2 Partnership, “we”, “us” or “our” in this privacy notice).

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO OR data privacy manager using the details set out below.

CONTACT DETAILS

Our full contact details are:

Mail: S2 Partnership Limited, 14-17 Avenue Business Park, Elsworth, Cambridge, CB23 4EY
Email: inforequest@s2partnership.co.uk
Telephone number: +44 (0)1954 267788

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 THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES

This version was last updated on 22nd May 2018 and historic versions can be obtained by contacting us.

The data protection law in the UK changes on 25 May 2018. Although this privacy notice sets out most of your rights under the new laws, we will be reviewing it frequently to accommodate any updates to or interpretations of the new data protection law.

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 notice of every website you visit.

2.  THE DATA WE COLLECT ABOUT YOU

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 follows:

  • Identity Data includes first name, last name, username or similar identifier and title.
  • Contact Data includes billing address, delivery address, email address and telephone numbers.
  • Technical Data includes 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.
  • Profile Data includes your interests and preferences.
  • Usage Data includes information about how you use our website.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
  • And other data that you may provide to us through contact form free text fields.

We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does 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. Nor do we collect any information about criminal convictions and offences.

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 Profile Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
    • request information about our products or services;
    • subscribe to our communications;
    • request marketing information;
    • send an email through the website.
  • Automated technologies or interactions. As you interact with our website, we may 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. Please see the below section on our cookie policy for further details.
  • Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:
  • Technical Data from the following parties:
  • (a)  analytics providers including Google based outside the EU;
  • (b)  website information providers such as Lead Forensics IP tracking technology to identify businesses visiting our websites and the pages they visit. Lead Forensics cannot identify the individual visiting our website, only the company and provides us with information about that company readily available in the public domain.

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 or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your personal data. You have the right to withdraw consent to marketing at any time by Contacting us at marketing@s2partnership.co.uk.

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.

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.

Purpose/Activity

 

Type of data

 

Lawful basis for processing including basis of legitimate interest Transfer to Third Party
To process your enquiry and register you as a customer or potential new customer Identity

Contact

To respond to your request and perform a contract with you (e.g. providing a quotation or information). Data is transferred to a third party Customer Relationship Management (CRM) system and Mailing Communication system.
To communicate with you and to manage our relationship with you which will include:

 

(a) Providing you with timely communications relevant to your role, industry or business
(b) Notifying you about changes to our terms or privacy policy

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

Identity

Contact

Profile

Marketing and Communications

 

(a) Legitimate interest to inform clients and prospects of relevant product, service, industry, legal and company news

(b)Performance of a contract with you and 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 communicate to make suggestions and recommendations to you about goods or services that may be of interest to you (a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

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

 

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) Technical

 

Necessary for our legitimate interests for running our business, provision of administration and IT services, and network security.

 

None
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. None

MARKETING

We strive to provide you with choices regarding certain personal data uses, particularly around marketing. We have established the following personal data control mechanisms:

MARKETING COMMUNICATIONS

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 completed a website form, requested information from us or purchased goods or services from us or if you provided us with your details when you registered for a promotion and, in each case, you have not later opted out of receiving that marketing.

THIRD-PARTY MARKETING

We do not share your personal data with any other third party companies for marketing purposes.

OPTING OUT

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

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.

COOKIES

This website uses cookies – small text files that are held on your computer by websites you visit to help the site provide a better experience, make websites work efficiently and provide anonymised data to website owners about visitor use.

As a rule, cookies are used to make your browsing experience better, and the information we collect does not identify anyone personally.

We use this information to see how visitors use our site, and how we can improve the visitor experience. We will not use this information for any other purpose, or share this information with third parties.

The cookies currently in use whilst you are browsing our website are:

Cookie Name Cookie Category Description Duration
wordpress_ 2 WordPress cookie for a logged in user. session
wordpress_logged_in_ 2 WordPress cookie for a logged in user session
wordpress_test_ 2 WordPress cookie for a logged in user session
wordpress_test_cookie 2 WordPress test cookie session
wp-settings- 1 WordPress also sets a few wp-settings-[UID] cookies. The number on the end is your individual user ID from the users database table. This is used to customize your view of admin interface, and possibly also the main site interface. 1 year
wp-settings-time- 2 WordPress also sets a few wp-settings-{time}-[UID] cookies. The number on the end is your individual user ID from the users database table. This is used to customize your view of admin interface, and possibly also the main site interface. 1 year
PHPSESSID 1 To identify your unique session on the website session
SESS 1 To ensure that you are recognised when you move from page to page within the site and that any information you have entered is remembered. session
__utma 2 This cookie keeps track of the number of times a visitor has been to the site pertaining to the cookie, when their first visit was, and when their last visit occurred. Google Analytics uses the information from this cookie to calculate things like Days and Visits to purchase. permanent
__utmb 2 __utmb is a Google Analytics cookie. It takes a timestamp of the exact moment in time when a visitor enters a site. session
__utmc 2 __utmc takes a timestamp of the exact moment in time when a visitor leaves a site. 30 mins
__utmz 2 Keeps track of where the visitor came from, what search engine you used, what link you clicked on, what keyword you used, and where they were in the world when you accessed a website. This cookie is how Google Analytics knows to whom and to what source / medium / keyword to assign the credit for a Goal Conversion or an Ecommerce Transaction. 6 months

To disable cookies on this site and others, 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.   To specifically opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout.

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 have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

  • External Third Parties as set out in the Glossary.
  • Specific third parties listed in the table in paragraph 4 above.

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

Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data may involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we seek to ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

Please Contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the 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.

S2 Partnership Limited is certified to ISO 27001 for Information Security Management.

8.  DATA RETENTION

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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 requirements.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.

In some circumstances you can ask us to delete your data: see Request erasure below for further information.

In some circumstances we may 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. Please click on the links below to find out more about these rights:

  • Request access to your personal data.
  • Request correction of your personal data.
  • Request erasure of your personal data.
  • Object to processing of your personal data.
  • Request restriction of processing your personal data.
  • Request transfer of your personal data.
  • Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us at inforequest@s2partnership.co.uk.

You will not normally 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 may 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 may 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 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 or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

EXTERNAL THIRD PARTIES

  • Service providers acting as processors as listed in Section 4 who provide IT and system administration services such as email solutions and CRM.
  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers 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.

YOUR LEGAL RIGHTS

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: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) 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.

 

We hope this privacy policy provides all of the information that you need, however if you have any questions, please contact us at inforequest@s2partnership.co.uk.