Privacy Policy

This privacy policy sets out how we, Citycom Technologies Limited collect, store and use information about you when you use or interact with our website, www.citycom.co.uk and where we otherwise obtain or collect information about you. This Privacy Policy is effective from 25 May 2018.

Contents

  • Summary
  • Our details
  • How we collect information about you
  • Explaining the legal basis, we rely on
  • Information we collect when you contact us
  • Information collected or obtained from third parties
  • Disclosure and additional uses of your information
  • How long we retain your information
  • How we secure your information
  • Transfers of your information outside the European Economic Area
  • Your rights in relation to your information
  • Your right to object to the processing of your information for certain purposes
  • Sensitive Personal Information
  • Changes to our Privacy Policy

Summary

This section summarises how we obtain, store and use information about you. It is intended to provide a very general overview only. It is not complete in and of itself and it must be read in conjunction with the corresponding full sections of this Privacy Policy.

Data controller: Citycom Technologies Limited

How we collect or obtain information about you:

  • when you provide it to us by contacting us or filling your details in our webforms to get in touch with you.
  • from your use of our website, using cookies
  • When you call our customer service team.
  • occasionally, from third parties.

Explaining the legal basis, we rely on:

The GDPR law on data protection sets out a number of different reasons a company may collect and process your personal data, including:

  • Consent: In specific situations, we can collect and process your data with your consent – e.g. when you access our customer service webform. When collecting your personal data, we’ll always make clear to you which data is necessary in connection with a particular service
  • Contractual obligations: In some instances, we need your personal data to comply with our contractual obligations. For example, if you place an order with us, we need your address details to deliver your order and we also need to pass your details to a courier.
  • Legal compliance: We may be legally bound to collect and process your data. For example, if someone is involved in any criminal activity or fraud affecting Citycom, we need to pass details to law enforcement.
  • Legitimate interest: We require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests. For example, we may use your purchase history and preferences to offer more personalised offers or services.

Information we collect:

Name, contact details, payment information e.g. your credit or debit card details, IP address, information from cookies, information about your computer or device (e.g. device and browser type),information about how you use our website (e.g. which pages you have viewed, the time when you view them and what you clicked on, the geographical location from which you accessed our website (based on your IP address), company name or business name.

We do not knowingly or intentionally collect sensitive personal information from individuals, and you must not submit sensitive personal information to you.  If you inadvertently or intentionally transmit sensitive personal information to us, you will be considered to have explicitly consented to us processing that sensitive personal information under Article 9(2)(a) of the General Data Protection Regulation. We will use and process your sensitive personal information for the purposes of deleting it.

How we use your information:

For administrative and business purposes, particularly to contact you and process your orders, to improve our business and website, to fulfil our contractual obligations, to promote our goods and services, to analyse your use of our website, and in connection with our legal rights and obligations. To comply with our legal obligations, we may send you communications required by law or which are legally necessary e.g. e.g. significant updates to this Privacy Notice, product recall notices and legally required information relating to your orders.

Disclosure of your information to third parties:

At times we need to share your personal data to the extent necessary to run our business with trusted third parties e.g., delivery couriers, mobile service providers, IT companies. We only provide what they need and they cannot use your data for anything other than the purposes that they have your data for. Your data is deleted or rendered anonymous if we stop working with them. Under any circumstance, we will not sell your information to third parties.

How long we retain your information:

We only keep your data for as long as is necessary for the purpose it was collected. After that period, your data is deleted or anonymised and for example, aggregated with other data to be used for business planning and analysis. We will take into account any legal obligations we have any other legal basis we have for retaining your information (e.g. your consent, performance of a contract with you or our legitimate interests as a business) For specific retention periods in relation to certain information which we collect from you, please see the main section below entitled How long we retain your information.

How we secure your information:

The security of your personal data is very important to us and we take a lot of care to handle and store it as best we can and in line with new legislation as we know it is important to you as well as us. We use appropriate technical and organisational measures such as storing your information on secure servers, encrypting transfers of data to or from our servers using Secure Sockets Layer (SSL) technology and only granting access to your information where necessary.  We monitor and check our data security systems for possible vulnerabilities and attacks, and we carry out penetration testing to identify ways to further strengthen security.

Use of cookies and similar technologies:

We use cookies and similar information-gathering technologies on our website including essential, functional, analytical and targeting cookies.. For more information, please visit our cookies policy here: Citycom Cookie Policy

Transfers of your information outside the European Economic Area:

We will only transfer your information outside the European Economic Area if we are required to do so by law. In certain circumstances we may transfer your information outside of the European Economic Area such as the US to fulfil contractual obligations. Where we do so, we will ensure appropriate safeguards are in place

We do not make use of automated decision making and profiling.

Your rights in relation to your information

  • to access your information and to receive information about its use
  • to have your information corrected and/or completed
  • to have your information deleted
  • to restrict the use of your information
  • to receive your information in a portable format
  • to object to the use of your information
  • to withdraw your consent to the use of your information
  • not to have significant decisions made about you based solely on automated processing of your information, including profiling
  • to complain to a supervisory authority
  • Sensitive personal information: we do not knowingly or intentionally collect what is commonly referred to as ‘sensitive personal information”: racial or ethnic origin, political opinions, Religious or philosophical beliefs, trade union membership, genetic data, biometric data, health data, data concerning an individual’s sex life and data concerning an individual’s sexual orientation.  Please do not submit sensitive personal information about you to us.

Our details

The data controller in respect of our website is

Citycom Technologies Limited,
11th Floor, The Mille
1000 Great West Road
Brentford
London, TW8 9HH
Tel: 03309121212

Company Registered number 08248506

If you have any questions about this Privacy Policy you can contact the data controller by writing to the address above or sending an email to support@citycom.co.uk

How we collect information about you

Information we collect when you visit our website

We collect and use information from website visitors in accordance with this section and the section entitled Disclosure and additional uses of your information. We use a third-party server to host our website.

Our website server is located in the EEA and automatically logs the IP address you use to access our website as well as other information about your visit such as the pages accessed, information requested, the date and time of the request, the source of your access to our website, e.g. the website or URL (link) which referred you to our website your browser version and operating system.

Cookies and similar technologies

We use cookies or similar technologies on our website. Cookies are data files which are sent from a website to a browser to record information about users for various purposes. we use cookies and similar information-gathering technologies on our website including essential, functional, analytical and targeting cookies. For more information, please visit our cookies policy here: www.citycom.co.uk/cookies-policy

You can reject some or all of the cookies we use on or via our website by changing your browser settings or non-essential cookies by using our cookie control tool, but doing so can impair your ability to use our website or some or all of its features. For further information about cookies, including how to change your browser settings, please visit www.allaboutcookies.org or see our cookies policy.

E-Newsletter

When you sign up for our e-newsletter on our website or opt to receive news and offers from us by entering your name and email address ticking a box indicating that you would like to receive our e-newsletter, we collect your name, email address and phone number

Use of web beacons [and similar technologies] in emails]

We use technologies such as web beacons For more information on how we use web beacons in our e-newsletter emails, see our cookies policy which is available here: www.citycom.co.uk/cookies-policy

For more information about our third party mailing list provider and they use web beacons, please see their privacy policy which is available here: https://www.salesforce.com/company/privacy/

Explaining the legal basis, we rely on

The GDPR law on data protection sets out a number of different reasons a company may collect and process your personal data, including:

Consent

In specific situations, we can collect and process your data with your consent – e.g. when you access our customer service webform. When collecting your personal data, we’ll always make clear to you which data is necessary in connection with a particular service.

Contractual obligations

In some instances, we need your personal data to comply with our contractual obligations. For example, if you place an order with us, we need your address details to deliver your order and we also need to pass your details to a courier.

Legal compliance

We may be legally bound to collect and process your data. For example, if someone is involved in any criminal activity or fraud affecting Citycom, we need to pass details to law enforcement.

Legitimate interest

We require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests. For example, we may use your purchase history and preferences to offer more personalised offers or services.

Information we collect when you contact us

We collect and use information from individuals who contact us in accordance with this section and the section entitled Disclosure and additional uses of your information.

Email

When you send an email to the email address displayed on our website we collect your email address and any other information you provide in that email such as your name, telephone number and the information contained in any signature block in your email.

Transfer and storage of your information

We use a third-party email provider to store emails you send us. Our third-party email provider is located in the EEA and Emails you send us will be stored within the European Economic Area on our third party servers

Contact form

When you contact us using our web contact form, we collect First Name, Last Name, Company, Job Title, Phone, Email address   We also collect any other information you provide to us when you complete the contact form including any optional information, such as optional information on which specific expertise you require and how you would like to be contacted. If you do not provide the mandatory information required by our contact form, you may not be able to submit the contact form and If you do not supply the optional information required by our contact form, we may not be able to return your enquiry with the most relevant information.

Transfer and storage of your information

Information you send us via our contact form will be stored within the European Economic Area on our third-party hosting servers

Phone

When you contact us by phone, we collect your phone number and any information provide to us during your conversation with us.

We record phone service calls for training purposes and in order to get information  that help us to keep the level of our service to you to the highest standards.

Transfer and storage of your information

Information about your calls, such as your phone number and the date and time of your call will be stored by our third-party telephone service provider in a secured server within the European Economic Area.

Post

If you contact us by post, we will collect any information you provide to us in any postal communications you send us in a secured manner.

Information collected or obtained from third parties

This section sets out how we obtain or collect information about you from third parties.

Information received from third parties

Generally, we do not receive information about you from third parties; However, It is also possible that third parties with whom we have had no prior contact may provide us with information about you.

Information we obtain from third parties will generally be your name, phone number, date of birth, sex address and email and contact details, but will include any additional information about you which they provide to us.

Similarly, third parties may pass on information about you to us if you have infringed or potentially infringed any of our legal rights. In this case, we will have a legitimate interest in processing that information to investigate and pursue any such potential infringement.

Where we receive information about you in error

If we receive information about you from a third party in error and/or we do not have a legal basis for processing that information, we will delete your information.

We do not make use of automated decision making and automated processing for profiling with your information to evaluate personal aspects about you, in particular to analyse or predict things like your economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.

Disclosure and additional uses of your information

This section sets out the circumstances in which will disclose information about you to third parties and any additional purposes for which we use your information.

Disclosure of your information to service providers

We use a number of third parties to provide us with services which are necessary to run our business or to assist us with running our business including the following:

  • Telephone provider(s),
  • Email provider(s),
  • IT service provider(s),
  • Web developer(s),
  • Hosting provider(s),

Your information will be shared with these service providers where necessary to provide you with the service you have requested, whether that is accessing our website or ordering goods and services from us.

If you would like to obtain information about our service providers, please contact us directly by email to support@citycom.co.uk and we will provide you with such information where you have a legitimate reason for requesting it.

Disclosure of your information to other third parties

We disclose your information to other third parties in specific circumstances, as set out below.

Google Analytics and Pardot collecting information through our website and from our CRM System. This information is used for a number of purposes, on an aggregated or anonymised basis.

To find out more about what information Google and Pardot collect, use this information and how to control the information sent to Google and Pardot, please see the following page: https://www.google.com/policies/privacy/partners/ and https://www.salesforce.com/company/privacy/

Information collected by Google Analytics and Pardot is stored in the European Economic Area

We may share your information also with accountants, financial advisors, lawyers and public relations professionals. For example, we share invoices we issue and receive with our accountants for the purpose of completing tax returns and our end of year accounts.

Business partners

Business partners are businesses we work with which provide goods and services which are complementary to our own or which allow us to provide goods or services which we could not provide on our own. We share information with our business partners where you have requested services which they provide whether independently from, or in connection with our own services.

Independent contractors

Occasionally, we use independent contractors in our business. Your information will be shared with independent contractors only where it is necessary for them to perform the function we have hired them to perform in relation to our business.

Insurers

We will share your information with our insurers where it is necessary to do so, for example in relation to a claim or potential claim we receive or make or under our general disclosure obligations under our insurance contract with them.

If you would like information about the identities of such third parties, please visit our website www.citycom.co.uk or contact us directly by email to support@citycom.co.uk and we will provide you with such information where you have a legitimate reason for requesting it (where we have shared your information with such third parties, for example).

Disclosure and use of your information for legal reasons

Indicating possible criminal acts or threats to public security to a competent authority

If we suspect that criminal or potential criminal conduct has been occurred, we will in certain circumstances need to contact an appropriate authority, such as the police. This could be the case, for instance, if we suspect that we fraud or a cybercrime has been committed or if we receive threats or malicious communications towards us or third parties.

We will generally only need to process your information for this purpose if you were involved or affected by such an incident in some way.

In connection with the enforcement or potential enforcement our legal rights

We will use your information in connection with the enforcement or potential enforcement of our legal rights, including, for example, sharing information with debt collection agencies if you do not pay amounts owed to us when you are contractually obliged to do so. Our legal rights may be contractual (where we have entered into a contract with you) or non-contractual (such as legal rights that we have under copyright law or tort law).

In connection with a legal or potential legal dispute or proceedings

We may need to use your information if we are involved in a dispute with you or a third party for example, either to resolve the dispute or as part of any mediation, arbitration or court resolution or similar process.

For ongoing compliance with laws, regulations and other legal requirements

We will use and process your information in order to comply with legal obligations to which we are subject. For example, we may need to disclose your information pursuant to a court order or subpoena if we receive one.

How long we retain your information

This section sets out how long we retain your information. We have set out specific retention periods where possible. Where that has not been possible, we have set out the criteria we use to determine the retention period.

Retention period

Server log information about our clients: we normally retain your information on our server logs for 12 months after your contract has expired with the exception of:

Order information: when you place an order for goods and services, we retain that information for six years following the end of the financial year in which you place your order, in accordance with our legal obligation to keep records for tax purposes.

Correspondence and enquiries: when you make an enquiry or correspond with us for any reason, whether by email or via our contact form or by phone, we will retain your information for as long as it takes to respond to and resolve your enquiry, and for 12 further months after which point we will delete your information.

E-Newsletter: we retain the information you used to sign up for our e-newsletter for as long as you remain subscribed (i.e. you do not unsubscribe) and for 12 further months.

In any other circumstances, we will retain your information for no longer than necessary, taking into account the following:

  • the purpose(s) and use of your information both now and in the future (such as whether it is necessary to continue to store that information in order to continue to perform our obligations under a contract with you or to contact you in the future);
  • whether we have any legal obligation to continue to process your information (such as any record-keeping obligations imposed by relevant law or regulation);
  • whether we have any legal basis to continue to process your information (such as your consent);
  • any relevant agreed industry practices on how long information should be retained;
  • the levels of risk, cost and liability involved with us continuing to hold the information;

How we secure your information

We take appropriate technical and organisational measures to secure your information and to protect it against unauthorised or unlawful use and accidental loss or destruction, including:

  • only sharing and providing access to your information to the minimum extent necessary, subject to confidentiality restrictions where appropriate, and on an anonymised basis wherever possible;
  • using secure servers to store your information
  • verifying the identity of any individual who requests access to information prior to granting them access to information;
  • using Secure Sockets Layer (SSL) software to encrypt any information you submit to us via any forms on our website;
  • only transferring your information via closed system or encrypted data transfers

Transmission of information to us by email

Transmission of information over the internet is not entirely secure, and if you submit any information to us over the internet (whether by email, via our website or any other means), you do so entirely at your own risk.

We cannot be responsible for any costs, expenses, loss of profits, harm to reputation, damages, liabilities or any other form of loss or damage suffered by you as a result of your decision to transmit information to us by such means.

Transfers of your information outside the European Economic Area

All of your information is stored in secured servers within the European Economic Area (EEA).

Other than to comply with any legal obligations to which we are subject (compliance with a court order, or a specific contractual obligation, for example), we do not intend to transfer your information outside the EEA or to an international organisation. In the event that we are required to transfer your information outside the EEA (or to an international organisation) for such a purpose, we will ensure appropriate safeguards and protections are in place. Information collected via email when you visit our website and when you submit information to us via our web contact form is not transferred outside of the EEA. Information collected by Google Analytics and Pardot (your IP address and actions you take in relation to our website) is not transferred outside the EEA

Your rights in relation to your information

Subject to certain limitations on certain rights, you have rights in relation to your information, which you can exercise by writing to:

Customer Support,
Citycom technologies ltd,
11th Floor, The Mille
1000 Great West Road
Brentford
London, TW8 9HH

or sending an email to support@citycom.co.uk

you have the following rights in relation to your information,

  • to request access to your information and information related to our use and processing of your information;
  • to request the correction or deletion of your information;
  • to request that we restrict our use of your information;
  • to receive information which you have provided to us in a structured, commonly used and machine-readable format (e.g. a CSV file) and the right to have that information transferred to another data controller (including a third-party data controller);
  • to object to the processing of your information for certain purposes (for further information, see the section below entitled Your right to object to the processing of your information for certain purposes); and
  • to withdraw your consent to our use of your information at any time where we rely on your consent to use or process that information. Please note that if you withdraw your consent, this will not affect the lawfulness of our use and processing of your information on the basis of your consent before the point in time when you withdraw your consent.

In accordance with Article 77 of the General Data Protection Regulation, you also have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or of an alleged infringement of the General Data Protection Regulation.

For the purposes of the UK, the supervisory authority is the Information Commissioner’s Office (ICO), the contact details of which are available here: https://ico.org.uk/global/contact-us/

Your right to object to the processing of your information for certain purposes

You have the following rights in relation to your information, which you may exercise in the same way as you may exercise by writing to us  or sending an email to support@citycom.co.uk to object to us using or processing your information where we use or process it in order to carry out a task in the public interest or for our legitimate interests, including ‘profiling’ (i.e. analysing or predicting your behaviour based on your information) based on any of these purposes; and

  • to object to us using or processing your information for direct marketing purposes (including any profiling we engage in that is related to such direct marketing).

You may also exercise your right to object to us using or processing your information for direct marketing purposes by:

  • clicking the unsubscribe link contained at the bottom of any marketing email we send to you and following the instructions which appear in your browser following your clicking on that link;
  • sending an email to support@citycom.co.uk asking that we stop sending you marketing communications or asking to unsubscribe to our newsletter.

For more information on how to object to our use of information collected from cookies and similar technologies, please see the section entitled Controlling the use of Cookies in our cookies policy, which is available here: www.citycom.co.uk/cookies-policy

Sensitive Personal Information

‘Sensitive personal information’ is information about an individual that reveals their racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic information, biometric information for the purpose of uniquely identifying an individual, information concerning health or information concerning a natural person’s sex life or sexual orientation.

We do not knowingly or intentionally collect sensitive personal information from individuals, and you must not submit sensitive personal information to us.

If, however, you inadvertently or intentionally transmit sensitive personal information to us, you will be considered to have explicitly consented to us processing that sensitive personal information under Article 9(2)(a) of the General Data Protection Regulation. We will use and process your sensitive personal information for the purposes of deleting it.

Changes to our Privacy Policy

We update and amend our Privacy Policy from time to time.

Minor changes to our Privacy Policy

Where we make minor changes to our Privacy Policy, we will update our Privacy Policy with a new effective date stated at the beginning of it. Our processing of your information will be governed by the practices set out in that new version of the Privacy Policy from its effective date onwards.

Major changes to our Privacy Policy or the purposes for which we process your information

Where we make major changes to our Privacy Policy or intend to use your information for a new purpose or a different purpose than the purposes for which we originally collected it, we will notify you by email (where possible) or by posting a notice on our website.

We will provide you with the information about the change in question and the purpose and any other relevant information before we use your information for that new purpose.

Wherever required, we will obtain your prior consent before using your information for a purpose that is different from the purposes for which we originally collected it.