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Date Published – June 2021

This is the website privacy notice of Trigonal Ltd. In this document, “we”, “our”, or “us” refer to Trigonal Ltd.

We are company number 4758967 registered in the United Kingdom.

Our registered office is at c/o BSG Valentine & Co., Lynton House, 7-12 Tavistock Square, London WC1H 9BQ, United Kingdom.

Introduction

This privacy policy aims to inform you about how we collect and process any information that we collect from you or that you provide to us. It covers information that could identify you (“personal information”) and information that could not. In the context of the law and this notice, “process” means collect, store, transfer, use or otherwise act on information. It tells you about your privacy rights and how the law protects you.

We are committed to protecting your privacy and the confidentiality of your personal information.

We undertake to preserve the confidentiality of all information you provide to us.

Our policy complies with the Data Protection Act 2018 (Act) accordingly incorporating the EU General Data Protection Regulation (GDPR).

Except as set out below, we do not share, or sell, or disclose to a third party, any information collected through our website.

TABLE OF CONTENTS

  1. DATA PROTECTION OFFICER
  2. DATA WE PROCESS
  3. INFORMATION WE PROCESS
  4. COMPLAINTS
  5. COMMUNICATING WITH US
  6. COOKIES
  7. PERSONAL IDENTIFIERS FROM YOUR BROWSING ACTIVITY
  8. INFORMATION FROM THIRD PARTIES
  9. THIRD PARTY ADVERTISING ON OUR WEBSITE
  10. DATA PROCESSED OUTSIDE THE EUROPEAN UNION
  11. ACCESS TO YOUR PERSONAL INFORMATION
  12. REMOVAL OF YOUR INFORMATION
  13. VERIFICATION OF YOUR INFORMATION
  14. ENCRYPTION OF DATA SENT BETWEEN US
  15. RETENTION PERIOD FOR PERSONAL DATA
  16. USE OF SITE BY CHILDREN
  17. COMPLIANCE WITH THE LAW
  18. REVIEW OF THIS PRIVACY POLICY

1. Data Protection Officer

We have appointed a data protection officer (DPO) who is responsible for ensuring that our policy is followed. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact our DPO, Mr. Marius Andresen at marius@trigonal.co.uk

2. Data we process

We may collect, use and store different kinds of personal data about you. We have collated these into groups as follows:

Your identity may include information such as first name, last name, title and other identifiers that you may have provided at some time.

Your contact information includes information such as email address, telephone numbers and any other information you have given to us for the purpose of communication.

Technical data may include your 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.

We may aggregate anonymous data such as statistical or demographic data for any purpose. Anonymous data is data that does not identify you as an individual. Aggregated data may be derived from your personal data but is not considered personal information in law because it does not reveal your identity.

For example, we may aggregate profile data to assess interest in a product or service. However, if we combine or connect aggregated data with your personal information so that it can identify you in any way, we treat the combined data as personal information and it will be used in accordance with this privacy notice.

Special personal information

Special personal information is data 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. We do not collect any special personal information about you.

The bases on which we process information about you

The law requires us to determine under which of six defined bases we process different categories of your personal information and to notify you of the basis for each category.

All the bases are described at: https://www.knowyourprivacyrights.org/legitimate-uses/. If a basis on which we process your personal information is no longer relevant, then we shall immediately stop processing your data. If the basis changes then if required by law, we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information.

3. Information we process

Information we process with your consent

Through certain actions when otherwise there is no contractual relationship between us, such as when you browse our website or ask us to provide you more information about our products and services, you provide your consent to us to process information that may be personal information. Wherever possible, we aim to obtain your explicit consent to process this information, for example, by asking you to agree to our use of cookies.

You may withdraw your consent at any time by instructing our DPO, Mr. Marius Andresen at marius@trigonal.co.uk

Information we process because we have a contractual obligation with you

When you agree to our terms and conditions, a contract is formed between you and us.

To carry out our obligations under that contract we must process the information you give us. Some of this information may be personal information.

We may use it to:

  • verify your identity for security purposes
  • sell products to you
  • provide you with our services
  • provide you with suggestions and advice on products, services and how to obtain the most from using our website

We process this information on the basis there is a contract between us. We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.

Information we process for the purposes of legitimate interests

We may process information on the basis there is a legitimate interest, either to you or to us, of doing so. Where we process your information on this basis, we do after having considered:

  • whether the same objective could be achieved through other means
  • whether processing (or not processing) might cause you harm
  • whether you would expect us to process your data and whether you would, in the round, consider it reasonable to do so

For example, we may process your data on this basis for the purposes of:

  • record-keeping for the proper and necessary administration of our sales enquiry record
  • responding to unsolicited communication from you to which we believe you would expect a response
  • protecting and asserting the legal rights of any party
  • protecting your interests where we believe we have a duty to do so

Information we process because we have a legal obligation

Sometimes, we must process your information to comply with a statutory obligation. For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order. This may include your personal information.

4. Complaints

Complaints regarding content on our website

If you are not happy with our privacy policy or if you have any complaint, please tell us. If you complain about any of the content on our website, we shall investigate your complaint. If we feel it is justified or if we believe the law requires us to do so, we shall remove the content while we investigate. If we think your complaint is vexatious or without any basis, we shall not correspond with you about it. If a dispute is not settled, then we hope you will agree to attempt to resolve it by engaging in good faith with us in a process of mediation or arbitration. If you are in any way dissatisfied about how we process your personal information, you have a right to lodge a complaint with the Information Commissioner’s Office (ICO). This can be done at https://ico.org.uk/make-a-complaint/ We would, however, appreciate the opportunity to talk to you about your concern before you approach the ICO.

5. Communicating with us

When you contact us, whether by telephone, through our website or by e-mail, we collect the data you have given to us, so we are able to reply with the information you require. We record your request and our reply to increase the efficiency of our business. We keep personally identifiable information associated with your messages, such as your name and email address so we can track our communications with you to provide a high-quality service.

6. Cookies

Cookies are small text files that are placed on your computer’s hard drive by your web browser when you visit any website. They allow information gathered on one web page to be stored until it is needed for use on another, allowing a website to provide you with a personalised experience and the website owner with statistics about how you use the website so that it can be improved.

Some cookies may last for a defined period, such as one day or until you close your browser. Others last indefinitely. Your web browser should allow you to delete any you choose. It also should allow you to prevent or limit their use. Our website uses cookies. They are placed by software operated by third parties whose services we use.

When you first visit our website, we ask you whether you wish us to use cookies. If you choose not to accept them, we shall not use them for your visit except to record that you have not consented to their use for any other purpose. If you choose not to use cookies or prevent their use through your browser settings, you will not be able to use all the functionality of our website. We use cookies in the following ways:

  • to track how you use our website
  • to record whether you have seen specific messages we display on our website
  • to keep you signed into our website
  • to record your answers in the contact form on our site while you complete them
  • to record the conversation thread during a live chat with our support team

We provide more information about the cookies we use in our cookie policy.

7. Personal identifiers from your browsing activity

Requests by your web browser to our servers for web pages and other content on our website are recorded. We record information such as your geographical location, your Internet service provider and your IP address. We also record information about the software you are using to browse our website, such as the type of computer or device and the screen resolution. We may use this information in aggregate to assess the popularity of the webpages on our website and how we perform in providing content to you. If combined with other information we know about you from previous visits, the data possibly could be used to identify you personally, even if you are not signed in to our website.

8. Information from third parties

We do not disclose your personal information to any third party or receive any data that is indirectly made up from your personal information from third parties.

9. Third party advertising on our website

We do not allow third party advertising on our website.

10. Data processed outside the European Union

Our website is hosted in the United Kingdom. We may also use outsourced services in countries outside the European Union from time to time in other aspects of our business. Accordingly, data obtained within the UK or any other country could be processed outside the European Union.

11. Access to your personal information

You may request a ‘copy of all and any personally identifiable information that we hold about you, at any time. Please do so by contacting our DPO, Mr. Marius Andresen at marius@trigonal.co.uk

12. Removal of your information

You may request the removal of all and any personally identifiable information that we hold about you, at any time. Please do so by contacting our DPO, Mr. Marius Andresen at marius@trigonal.co.uk

13. Verification of your information

When we receive any request to access, edit or delete personal identifiable information we shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.

14. Encryption of data sent between us

We use Secure Sockets Layer (SSL) certificates to encrypt any data you give us. Whenever information is sent to us, you can check that it is done so using SSL by looking for a closed padlock symbol or other trust mark in your browser’s URL bar or toolbar.

15. Retention period for personal data

Except as otherwise mentioned in this privacy notice, we keep your personal information only for as long as required by us:

  • to provide you with the services you have requested;
  • to comply with other law, including for the period demanded by our tax authorities;
  • to support a claim or defence in court.

16. Use of site by children

We do not sell products or provide services for purchase by children, nor do we market to children. If you are under 18, you may use our website (and/or request further information) only with consent from a parent or guardian

17. Compliance with the law

Our privacy policy has been compiled to comply with the law of every country or legal jurisdiction in which we aim to do business. If you think it fails to satisfy the law of your jurisdiction, please contact us. However, ultimately it is your choice as to whether you wish to use our website.

18. Review of this privacy policy

We may update this privacy notice from time to time, as necessary. The terms that apply to you are those posted here on our website on the day you use our website. We advise you to print a copy for your records. If you have any question regarding our privacy policy, please contact our DPO, Mr. Marius Andresen at marius@trigonal.co.uk