1.1 Equippd Ltd (“we” or “us”) take the privacy of your information very seriously. This policy sets out how we collect, use and store any personal data when interacting with us as a service provider. This includes data that may be collected in person, collected through our website or obtained via other mediums such as by online forms, email exchange, or telephone communication.
1.2 This notice relates to any personal information you provide to us when working with us on projects and includes (but is not limited to): names, physical addresses, email addresses and telephone numbers.
1.3 In this notice “you” refers to any individual whose personal data we hold or process (i.e. to you as a client).
1.4 In general, our services relate to the design, provision and maintenance of technology systems, of which we do not process personal data on a large scale. However we do hold contact information, system information and in some cases account information on behalf of our clients. This policy sets out the basis on which we hold that data.
1.5 This notice is governed by the EU General Data Protection Regulation (the “GDPR”) from 25 May 2018.
2. Legal Basis on which we process personal data
2.1 Personal data we hold about you will be processed because it is necessary in order for us to deliver the services agreed upon under a formal or informal contract between you and us.
3. Personal data we collect
3.1 We may collect and process the following personal data (information that can be uniquely identified with you) about you:
3.1.1 contact information such as names, email addresses, phone numbers, addresses, and job titles and/or specific roles within your organisation
(“Client Contact Information”);
3.1.2 account information such as passwords which are stored in an encrypted format and protected with two factor authentication
3.1.3 system information including public IP addresses, local IP addresses,
equipment usernames and passwords, all of which are stored in an encrypted format and protected with two factor authentication
3.1.4 property information including structural / architectural plans that include address details
provide our services to you without personal data (for example we will need contact information in order to communicate with you). You may withdraw our authority to process your personal data (or request that we restrict our processing) at any time but this may lead to termination of our working relationship due to the inability to continue offering our services. In this case, you agree to pay any outstanding invoices for work that has already been completed.
4. How we process your personal data
4.1. Please see the table below, which sets out the manner in which we will process the different types of personal data we hold:
Purpose / activity Type of data Grounds for data processing
Communicating with the client throughout the duration of a project
Contact info: email addresses, phone number, address
Necessary for ongoing communication and delivery of services
Providing system support or maintenance
Public IP addresses, digital account information
Necessary to supply essential maintenance / support services and keep systems protected
5. Sharing your information
We do not disclose any information you provide to any third parties other than as follows:
5.1.1 if we are under a duty to disclose or share your personal data in order to comply with any legal obligation (for example, if required to do so by a court order or for the purposes of prevention of fraud or other crime);
5.1.2. in order to enforce any terms and conditions or agreements for our services that may apply;
5.1.3. if we are sub-contracting services to a third party we may provide information to that third party in order to provide the relevant services;
party unless you give us express permission to do so. If we do supply your personal information to a third party we will take steps to ensure that your privacy rights are protected and that third party complies with the terms of this notice.
6.1 We will take all reasonable steps to ensure that appropriate technical and organisational measures are carried out in order to safeguard the information we collect from you and protect against unlawful access and accidental loss or damage. These measures may include (as necessary):
Other than as set out above, your personal information will not be shared or disclosed to any other
6.1.4 when necessary, disposing of or deleting your data so it is done so
protecting our servers with software firewalls;
locating our data processing storage facilities in secure locations; encrypting all data stored on our systems with encryption and two
factor authentication securely;
6.1.5 regularly backing up and encrypting all data we hold.
6.3 This notice and our procedures for handling personal data will be reviewed as necessary.
6.4 Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of any data you send to us. Once we have received your information, we will use the strict procedures and security features referred to in this clause to try to prevent unauthorised access.
7. Your privacy rights
7.1 The GDPR gives you the following rights in respect of personal data we hold about you:
The right to be informed
You have a right to know about our personal data protection and data processing activities, details of which are contained in this notice.
The right of access
You can make what is known as a Subject Access Request (“SAR”) to request information about the personal data we hold about you (free of charge, save for reasonable expenses for repeat requests). If you wish to make a SAR please contact us as described below.
The right to correction
Please inform us if information we hold about you is incomplete or inaccurate in any way and we will update our records as soon as possible, but in any event within one month. We will take reasonable steps to communicate the change to any third parties to whom we have passed the same information.
The right to erasure(the ‘right to be forgotten’)
Please notify us if you no longer wish us to hold personal data about you (although in practice it is not possible to provide our services without holding your personal data and we may need to keep your data in some circumstances). Unless we have reasonable grounds to refuse the erasure, on receipt of such a request we will securely delete the personal data in question within one month. The data may continue to exist in certain backup, but we will take steps to ensure that it will not be accessible. We will communicate the erasure to any third parties to whom we have passed the same information.
The right to restrict processing
You can request that we no longer process your personal data in certain ways, whilst not requiring us to delete the same data. However again, some of our Services will not be available if processing is restricted.
The right to data portability
You have right to receive copies of personal data we hold about you in a commonly used and easily storable format (please let us know a format which suits you). You may also request that we transfer your personal data directly to third party (where technically possible).
The right to object
Unless we have overriding legitimate grounds for such processing, you may object to us using your personal data for direct marketing purposes (including profiling) or for research or statistical purposes. Please notify your objection to us and we will gladly cease such processing.
Rights with respect to automated decision- making and profiling
You have a right not to be subject to automated decision-making (including profiling) when those decisions have a legal (or similarly significant effect) on you. You are not entitled to this right when the automated processing is necessary for us to perform our obligations under a contract with you, it is permitted by law, or if you have given your explicit consent.
If we are relying on your consent as the basis on which we are processing your personal data, you have the right to withdraw your consent at any time. Even if you have not expressly given your consent to our processing, you also have the right to object (see above).”
7.2 All SARs and other requests or notifications in respect of your above rights must be sent to us via email to email@example.com
7.3 We will endeavour to comply with such requests as soon as possible but in any event we will comply within one month of receipt (unless a longer period of time to respond is reasonable by virtue of the complexity or number of your requests).
8. Data Breaches
8.1 If personal data we hold about you is subject to a breach or unauthorised disclosure or access, we will report this to the Information Commissioner’s Office (ICO).
8.2 If a breach is likely to result in a risk to your data rights and freedoms, we will notify you as soon as possible.
9. Transferring your information outside Europe
9.1 As part of the services we provide to our clients, your information may be transferred to, processed and stored at, countries or international organisations outside of the EEA.
9.2 Other service providers who we collaborate with may be based outside of the EEA and we may transfer personal data to these locations. For instance we may use your email addresses to sign up for system tools hosted outside of the EEA.
9.3. If you contact us while you are outside the EEA, your information may be transferred outside the EEA in order to communicate with you.
9.4 If we transfer your information outside of the EEA other than in accordance with clauses 9.2 and 9.3 and the third country or international organisation in question has not been deemed by the EU Commission to have adequate data protection laws, we will provide appropriate safeguards and we will be responsible for ensuring your privacy rights continue to be protected as outlined in this notice.
10. Notification of changes to the contents of this notice
We will post details of any changes to our policy on www.equippd.uk to help ensure you are always aware of the information we collect, how we use it, and in what circumstances, if any, we share it with other parties.
11. Contact us
If at any time you would like to contact us with your views about our privacy practices, or with any enquiry or complaint relating to your personal information or
Right to withdraw consent
how it is handled, you can do so by sending an email to the following address: firstname.lastname@example.org
If we are unable to resolve any issues you may have or you would like to make a further complaint, you can contact the Information Commissioner’s Office by visiting http://www.ico.org.uk/ for further assistance.