Updated: October 2021
1.1. Important information and who we are
The individuals from which we may gather and use data can include Users, suppliers, business contacts, employees and/or staff members of our Users, users of our Users’ websites and any other people that the organisation has a relationship with or may need to contact.
1.2. Who is Your Data Controller
SortFlow Limited is your Data Controller and responsible for your Personal Data. You have the right to contact 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.
1.3. Processing Data on Behalf of a Controller and Processors’ responsibility to you
In discharging the responsibilities of the Data Controller, we have Processors who deal with your data on behalf of the Data Controller. Therefore, the responsibilities described below may be assigned to an individual, or may be taken to apply to the organisation as a whole.
The Data Processor has the following responsibilities:
• Ensure that all processing of Personal Data is governed by one of the legal bases laid out in the GDPR (see 2.2 below for more information on those bases).
• Ensure that persons authorised to process Personal Data have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality
• Implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk associated with the processing of Personal Data
• Obtain the prior specific or general written authorisation of the Controller before engaging another Processor
• Assist the Controller in the fulfilment of the Controller’s obligation to respond to requests for exercising the data subject’s rights
• Make available to the Controller all information necessary to demonstrate compliance with the obligations laid down in the GDPR and allow for and contribute to audits, including inspections, conducted by the Controller or another auditor mandated by the Controller
• Maintain a record of all categories of processing activities carried out on behalf of a Controller
• Cooperate, on request, with the supervisory authority in the performance of its tasks
• Ensure that any person acting under the authority of the Processor who has access to Personal Data does not process them except on instructions from the Controller
• Notify the Controller without undue delay after becoming aware of a Personal Data Breach
• Designate a data protection officer where required by the GDPR, publish their details and communicate them to the supervisory authority
• Support the data protection officer in performing their tasks by providing resources necessary to carry out those tasks and access to Personal Data and processing operations, and to maintain his or her expert knowledge
2. Legal Basis for Data Collection
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 set out below. Not all of the following types of data will necessarily be collected from you but this is the full scope of data that we collect:
• Profile/Identity Data: first name and last name.
• Contact Data includes email address.
• Communications Data includes your communication preferences.
• Billing Data and Company Financial Data: bank account/debit/credit card holder information (name/billing address) of whoever purchased something from SortFlow
• Transaction Data includes details about payments from you for products and purchases you have made from SortFlow.
• Technical Data: internet protocol (IP) address, browser type and version, time zone setting and location, operating system and platform, and other technology on the devices you use to access this website.
• Customer Support Data includes feedback and survey responses.
• Usage Data includes information about how you use our website, products and services.
Further, we may use anonymous data collected from SortFlow Limited for site administration, analytics, advertising and promotional purposes, and we may share such information with other entities (such as service providers) for such purposes. We may also aggregate data to enable research or analysis so that we can better understand and serve you and others. Although this aggregated data may be based in part on Personal Data, it does not identify you personally. SortFlow may share this type of anonymous data with others, including service providers, our affiliates, agents and current and prospective business partners.
We may retain your IP address and/or other device-identifying data in order to help us diagnose problems with our servers, to administer SortFlow including personalizing content or links relevant to your geographic area or device-type, to verify that your account is not being used by others, to gather broad anonymous demographic data (such as the number of visitors from a geographic area), to enforce compliance with our Terms and Conditions for our Site and/or Service or otherwise in order to protect our services, Site, Platform, Users, or other third parties.
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.
2.2. The Legal Basis for Collecting That Data
There are a number of justifiable reasons under the GDPR that allow collection and processing of Personal Data. The main avenues we rely on are:
• Consent: Certain situations allow us to collect your Personal Data, such as when you tick a box that confirms you are happy to receive email newsletters from us, or ‘opt in’ to a service.
• Contractual Obligations: We may require certain information from you in order to fulfil our contractual obligations and provide you with the promised service.
• Legal Compliance: We’re required by law to collect and process certain types of data.
• Legitimate Interest: We might need to collect certain information from you to be able to meet our legitimate interests – this covers aspects that can be reasonably expected as part of running our business, that will not have a material impact on your rights, freedom or interests.
3. How is your Personal Data Collected?
3.1. Direct Interactions
You may give us your identity and contact details by filling in forms or by corresponding with us by phone, email or otherwise. This includes Personal Data you provide when you:
• Inquire about or purchase our products or services and go on to use them
• Speak to our support team
• Create an account on our Platform
• Request marketing to be sent to you
• Give us feedback or contact us
3.2. Automated Technologies or Interactions
As you interact with our Site or Platform, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We might collect this Personal Data by using cookies and other similar technologies.
3.3. Third-parties or Publicly Available Sources
We will receive Personal Data about you from various third parties including advertising networks such as LinkedIn and Google.
4. How we use your personal data
4.1. Our Uses
We will only use your Personal Data when the law allows us to. Set out below is a table containing the different types of Personal Data we collect and the lawful basis for processing that data. Please refer to section 2.2 for more information on the lawful basis listed in the table below.
Examples provided in the table below are indicative in nature and the purposes for which we use your data may be broader than described but we will never process your data without a legal basis for doing so and it is for a related purpose. For further inquiries please contact us at firstname.lastname@example.org.
(Y) Type of data
(Z) Lawful basis for processing including basis of legitimate interest
(X) A User requesting and attending a live demo of our products/services or inquiring into our services through a call with members of our sales/support team
(Y) (a) Identity (b) Contact (a) Consent
(Z) Certain company information might be taken at this time, including names of stakeholders. (b) Legitimate Interest We need this information to be able to help assess your needs.
(X) New User account is created
(Y) (a) Identity (a) Legitimate Interest
(Z) We need to know who you are so that we know who to deliver the service to once it has been purchased. It also enables us to provide support to the right individual
(X) User support with specific products
(Y) (a) Identity (b) Usage (a) Consent
(Z) We may need your telephone number or other further contact details if reaching out to you is best achieved via those details (b) Legitimate Interest We will retain records of the transactions you have made with us and what you have used on the Platform so when you come to us with an issue we can quickly identify what your issue relates to and provide you with the most efficient support
(X) To administer and protect our business (the Site and Platform) including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data
(Y) (a) Identity (b) Contact (c) Technical
(Z) (a) Legitimate interests for running our business, provision of administration and IT services, network security (b) Contractual Obligation To be able to comply with all legal obligations surrounding data collection, processing and retention. To use data analytics to improve our website, products/services, marketing, customer relationships and experiences (a) Technical (b) Usage (a) Legitimate interest To define types of customers for our products and services, to keep our Site and Platform updated and relevant, to develop our business
4.2. Content Updates
You might receive new content communications from us if you have an account.
4.3. 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 at email@example.com.
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. Your rights and how you are protected by us
5.1. What Control Do I Have Over SortFlow’s Use Of My Personal Data?
We can delete your account upon request – this will remove your account page from the Platform and our related software. If you would like us to delete/correct personally identifiable data, let us know and we will action your request as soon as practicable.
User account information will be protected by a password for your privacy and security. You need to prevent unauthorized access to your account and personal information by selecting and protecting your password appropriately and limiting access to your computer or device and by signing off after you have finished accessing your account.
You can access information associated with your account by logging into SortFlow.
California Privacy Rights: Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of personal customer information which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to firstname.lastname@example.org
5.2. How Does SortFlow Protect Customer Data?
We are concerned with keeping your data secure and protecting it from inappropriate disclosure. We implement a variety of security measures to ensure the security of your Personal Data on our systems. Any Personal Data collected by us is contained behind secured networks and is only accessible by a limited number of employees who have special access rights to such systems and are bound by obligations of confidentiality. Where sensitive data is collected by us it will be transmitted and protected via a secure protocol and encrypted in our databases to be accessed only as stated above. If and when we use subcontractors to store your data, we will not relinquish control of your Personal Data or expose it to security risks that would not have arisen had the data remained in our possession. However, unfortunately, no transmission of data over the internet is guaranteed to be completely secure. It may be possible for third parties not under the control of SortFlow to intercept or access transmissions or private communications unlawfully. While we strive to protect your Personal Data, we cannot ensure or warrant the security of any Personal Data you transmit to us. Any such transmission is done at your own risk. If you believe that your interaction with us is no longer secure, please contact us.
5.3. How to Request your Data and the Process for Obtaining it
You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, if your request is clearly unfounded, we could refuse to comply with your request.
We may need to request specific information from you to help us confirm your identity and ensure you have the 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.
6. Your data and third parties
6.1. Will We Share Your Data With Third Parties?
We may share non-personal data with third parties to, for example (but not by way of limitation), improve SortFlow and to enable data aggregation.
We may share your Personal Data with subcontractors, (only when necessary and subject to confidentiality obligations to use it only for the purposes for which we disclose it to them and pursuant to our instructions).
We may also share Personal Data with interested parties in the event that SortFlow anticipates a change in control or the acquisition of all or part of our business or assets or with interested parties in connection with the licensing of our technology.
6.2. Third-Party Links
7. How long we will retain your data for?
We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for. We may retain your Personal Data for a longer period than usual in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
8. Age limits for our users
You must not use SortFlow unless you are aged 18 or older. This website and platform are not intended for children and we do not knowingly collect data relating to children.
9. International transfer of data
Your information may be stored and processed in the US or other countries or jurisdictions outside the US where SortFlow has facilities. We are currently storing data in the EU and so, by using SortFlow, you are permitting and consenting to the transfer of information, including personal data, outside of the US.
10. Notification of changes and acceptance of policy
All uses of the word “including” mean “including but not limited to” and the enumerated examples are not intended to in any way limit the term which they serve to illustrate. Any email addresses set out in this policy may be used solely for the purpose for which they are stated to be provided. Unless otherwise required by law, we reserve the right to not respond to emails, even if they relate to a legitimate subject matter for which we have provided an email address. Our staff are not authorised to contract on behalf of SortFlow, waive rights or make representations (whether contractual or otherwise). If anything contained in an email from a SortFlow address contradicts anything in this policy, our terms or any official public announcement on our website, or is inconsistent with or amounts to a waiver of any SortFlow rights, the email content shall be read down to grant precedence to the latter.
• GDPR: The General Data Protection Regulation (EU) 2016/679 (GDPR)
• Users: Any individual who either browses the public website, speaks with our employees and staff members, of uses our Platform as a signed-up user.
• Personal Data: Information relating to an individual who can be directly identified from the information. Personal Data includes factual information as well as expressions of opinion or intentions.
• Data Controller / Controller: The organisation that determines the manner and purposes for which Personal Data is to be processed. In our case, SortFlow Limited.
• Personal Data Breach: Loss, theft or unauthorised access, use or disclosure of Personal Data.
• Aggregated Data: Statistical or demographic data derived from your personal data but not consider personal data in law as the data will not directly or indirectly reveal your identity.