Privacy Policy

Effective date: 25th May 2018

This Privacy Policy sets out how we, Light Degree Limited Trading as Workflows for Business, collect, store and use information about you when you use or interact with our website, lightdegree.com including my.lightdegree.com (our website) and where we otherwise obtain or collect information about you.

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: Light Degree Limited
• How we collect or obtain information about you:
  • when you provide it to us (e.g. by contacting us, signing up for the Light Degree Limited Service, registering for our newsletter updates),
  • from your use of our website, using cookies, and
  • from third parties.
• Information we collect: name, contact details, IP address, information about your browser type, information about which pages you browse, the time and date that you accessed our website, your geographical location and your company name and address.
• How we use your information: for administrative and business purposes (particularly to contact you, to provide the Light Degree Limited database service, to improve our website and our business, to analyse your use of our website and in connection with our legal rights and obligations).
• Disclosure of your information to third parties: only to the extent necessary to run our business, to fulfil any contracts we enter into with you and where required by law or to enforce our legal rights.
• Do we sell your information to third parties (other than in the course of a business sale or purchase or similar event): No
• How long we retain your information: for no longer than necessary, taking into account any legal obligations we have (e.g. to maintain records for tax purposes), any other legal basis we have for using your information (e.g. your consent, performance of a contract with you or our legitimate interests as a business).
• How we secure your information: using appropriate technical and organisational measures such as storing your information on secure servers, encrypting transfers of data to and from our servers using Secure Sockets Layer (SSL) technology, and only granting access to your information where necessary.
• Use of cookies: We use cookies on our website for functional and security purposes.
• 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.
• Use of automated decision making and profiling: we do not use automated decision making or 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
  • 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'. Please do not submit sensitive personal information about you to us.

Our details

The data controller in respect of our website is Light Degree Limited (company registration number 08151487) of Roehyde House, St Albans AL4 0PJ. You can contact the data controller by writing to Light Degree Limited, Roehyde House, St Albans AL4 0PJ or sending an email to legal@lightdegree.com.

If you have any questions about this Privacy Policy, please contact the data controller.

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.

Web server log information

We use third party servers to host our websites called Herts Services for lightdegree.com and Amazon Web Services for my.lightdegree.com. Our website servers automatically log the IP address you use to access our website as well as other information about your visit such as the pages accessed, the date and time of the request and details about your browser version and operating system.

Use of website server log information for IT security purposes

Our servers collect and store server logs to ensure network and IT security and so that the server and website remain uncompromised. This includes analysing log files to help identify and prevent unauthorised access to our network, the distribution of malicious code, denial of services attacks and other cyber attacks, by detecting unusual or suspicious activity.

Legal basis for processing: compliance with a legal obligation to which we are subject (Article 6(1)(c) of the General Data Protection Regulation).

Legal obligation: we have a legal obligation to implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk of our processing of information about individuals. Recording access to our website using server log files is such a measure.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interests: we have a legitimate interest in using your information for the purposes of ensuring network and information security.

Use of website server log information to analyse website use and improve our website

We use the information collected by our website server logs to analyse how our website visitors interact with our website and its features. For example, we analyse the number of visits and unique visitors we receive, the time and date of the visit, the location of the visit and the operating system and browser used.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interests: improving our website for our website users and getting to know our website users' preferences so our website can better meet their needs and desires.

Cookies

Cookies are data files which are sent from a website to a browser to record information about users for various purposes.

We use cookies on our website, including essential and functional cookies required to maintain site security.

You can reject some or all of the cookies we use on or via our website by changing your browser settings but doing so can impair your ability to use our website or some or all of its features.

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 or you enter your details into our secure messaging service, 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).

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services, we will process your information in order to do so.

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 Google located in USA.

Contact form

When you contact us using our contact form, we collect your name, company name, email address and IP address. We also collect any other information you provide to us when you complete the contact form including your phone number.

If you do not provide the mandatory information required by our contact form, you will not be able to submit the contact form and we will not receive your enquiry.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services, we will process your information in order to do so.

Transfer and storage of your information

Messages you send us will be stored on our Amazon Web Services servers in the EEA and will also be copied by email provided by Google in the USA.

Phone

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

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services, we will process your information in order to do so.

Transfer and storage of your information

Information about your call, such as your phone number and the date and time of your call, is processed by our third party telephone service provider Ansacom Ltd which is located in Kent, UK.

Post

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

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services, we will process your information in order to do so.

Information we collect when you interact with our website

We collect and use information from individuals who interact with particular features of our website in accordance with this section and the section entitled Disclosure and additional uses of your information.

E-Newsletter

When you sign up for our e-newsletter on our website or opt to receive news, offers or other updates from us, we collect your name and email address.

Legal basis for processing: your consent (Article 6(1)(a) of the General Data Protection Regulation).

Consent: you give your consent to us sending you our e-newsletter by signing up to receive it using the steps described above.

Transfer and storage of your information

We use a third party service to send out our e-newsletter and administer our mailing list, Campaign Monitor. Information you submit to subscribe for our e-newsletter will be stored outside the European Economic Area on our Campaign Monitor servers in Australia.

Use of web beacons and Java script in emails

In some cases we and/or third parties use technologies such as web beacons (small graphic files) and Java script in the emails we send to allow us to assess the level of engagement our emails receive by measuring information such as the delivery rates, open rates and click through rates and the location of recipients which our emails achieve. We will only use web beacons and Java script in our emails if you have consented to us doing so.

Registering on our website

When you register and create an account on our website, we collect the following information: name, email address, IP address and any other information you provide to us when you complete the registration form, including any optional information, such as a phone number, website link, time zone, any password that you set to gain access to our website or your company name.

If you do not provide the mandatory information required by the registration form, you will not be able to register or create an account on our website.

Legal basis for processing: necessary to perform a contract or to take steps at your request prior to entering into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: creating an account on our website is necessary to allow you to access the goods and services you have purchased from us.

Information we collect when you place an order on our website

We collect and use information from individuals who place an order on our website in accordance with this section and the section entitled Disclosure and additional uses of your information.

Information collected when you place an order

Mandatory information

When you place an order for goods or services on our website, we collect your name, email address, billing address, shipping address, company name (if applicable) and VAT number (if applicable).

If you do not provide this information, you will not be able to purchase goods or services from us on our website or enter into a contract with us.

Legal basis for processing: necessary to perform a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: we need the mandatory information collected by our checkout form to establish who the contract is with and to contact you to fulfil our obligations under the contract, including sending you receipts and order confirmations.

Legal basis for processing: compliance with a legal obligation (Article 6(1)(c) of the General Data Protection Regulation).

Legal obligation: we have a legal obligation to issue you with an invoice for the goods and services you purchase from us where you are VAT registered and we require the mandatory information collected by our checkout form for this purpose. We also have a legal obligation to keep accounting records, including records of transactions.

Optional information

We also collect optional information from you, such as your phone number, information about how you heard about us and also, relevant details of your business processes, so that we are able to provide our services to you. We also ask you if you would like to receive marketing communications from us.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interests: information about how you heard about us and details of your business practices we will not be able to improve our business marketing or update and provide relevant services required to operate your business.

Legal basis for processing: your consent (Article 6(1)(a) of the General Data Protection Regulation).

Legitimate interests: you consent to us processing any optional information you provide by submitting that information to us.

Processing your payment

After you place an order on our website you will need to make payment for the goods or services you have ordered. In order to process your payment we use third party payment processors, including Go-Cardless and PayPal. Your payment will be processed by Go-Cardless or other the third party payment processor you choose to process your payment via a payment gateway.

The third party payment processor you choose to process your payment collects, uses and processes your information, including payment information, in accordance with their privacy policies.

• Go-Cardless: located in the United Kingdom
• PayPal (Europe): located in Luxembourg

Legal basis for processing: necessary to perform a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: to fulfil your contractual obligation to pay for the goods or services you have ordered from us.

Marketing communications

At checkout you will have the option of receiving marketing communications from us.

Our similar goods and services

You can opt-out from receiving marketing communications in relation to our goods and which are similar to those which you purchase from us, by unticking a pre-ticked box. We will send you marketing communications in relation to similar goods and services if you do not opt out from receiving them.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interests: direct marketing and advertising our products and services.

Our goods and services

You can opt in to receiving marketing communications from us in relation to our goods and services by email, phone, and/or post by specifically requesting an opt in or by unticking a pre-ticked box. We will send you marketing communications in relation to our goods and services only if you opt-in to receive them.

Legal basis for processing: consent (Article 6(1)(a) of the General Data Protection Regulation).

Consent: you give your consent to us sending you information about our goods and services by signing up to receive such information in accordance with the steps described above.

Our use of automated decision-making and profiling

We do not use automated decision making and profiling on our website. We do not consider that this has any legal effect on you or similarly significantly affects you.

You have the right to object to our use of automated decision making and profiling described in this section. You can do that by opting-out of cookies and similar technologies in accordance with the method described in the relevant section below.

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. It is possible, however, 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 and contact details, but will include any additional information about you which they provide to us.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Legal basis for processing: consent (Article 6(1)(a) of the General Data Protection Regulation).

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interests: where a third party has shared information about you with us and you have not consented to the sharing of that information, we will have a legitimate interest in processing that information in certain circumstances.

Information obtained by us from third parties

In certain circumstances we will obtain information about you from certain publicly accessible sources, both EU and non-EU, such as Companies House, online customer databases, business directories, media publications, social media, and websites (including your own website if you have one).

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Disclosure and additional uses of your information

This section sets out the circumstances in which we 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 and who process your information for us on our behalf. These include the following:

• Telephone service provider(s), including Ansacom Ltd which is located in Kent, UK.
• Email provider(s), including Google in the USA.
• Hosting provider(s), including Amazon Web Services in Ireland.
• Hosting provider(s), including Herts Network and Security in the United Kingdom.
• Email Marketing provider(s), including Campaign Monitor.

Legal basis for processing: legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legal basis for processing: necessary to perform a contract and/or to take steps at your request prior to entering into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Disclosure of your information to other third parties

Providing information to third parties such as Google Inc. Google collects information through our use of Google Analytics on our website. Google uses this information, including IP addresses and information from cookies, for a number of purposes, such as improving its Google Analytics service. Information is shared with Google on an aggregated and anonymised basis.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

We may also share your information with our accountants, advisors, business partners, independent contractors, and insurers, where necessary to run and manage our business efficiently.

Sharing your information within our business group

We may share your information within our business' group of companies for internal administrative purposes, including client, customer and employee information.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest: running and managing our business effectively.

Disclosure and use of your information for legal reasons

If we suspect that criminal or potential criminal conduct has occurred, we will in certain circumstances need to contact an appropriate authority, such as the police.

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.

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.

Legal basis for processing: compliance with a legal obligation (Article 6(1)(c) of the General Data Protection Regulation).

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 periods

• Server log information: we retain information on our server logs for a minimum period of 10 years.
• 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 placed 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 a minimum period of 2 years, after which point we may 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 or if we decide to cancel our e-newsletter service, whichever comes earlier.

Criteria for determining retention periods

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;
• whether we have any legal obligation to continue to process your information;
• whether we have any legal basis to continue to process your information (such as your consent);
• how valuable your information is (both now and in the future);
• 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 hard it is to ensure that the information can be kept up to date and accurate; and
• any relevant surrounding circumstances (such as the nature and status of our relationship with you).

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 and any payment transactions you make on or via 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 the following European Economic Area (EEA) countries, United Kingdom and Ireland, with the exception of emails and marketing campaigns.

Other than to comply with any legal obligations to which we are subject, 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 for such a purpose, we will ensure appropriate safeguards and protections are in place.

Contact form

Information you submit to us via our contact form is stored on our Amazon Web Services servers hosted in Ireland and the United Kingdom. A copy of the form is transmitted by email using Google when sent directly to Light Degree. The Google emails are hosted outside the EEA and stored on our third party email provider's servers in the USA.

Email

Information you submit to us by email is transferred outside the EEA and stored on our third party email provider's servers. Our third party email provider is: Google Inc. in the USA.

Safeguard(s) used: Our third party email provider has self-certified its compliance with the EU-U.S. Privacy Shield.

E-Newsletter

Information you submit to us when you sign up for our e-newsletter is transferred outside the EEA and stored on our third party mailing list provider's servers. Our third party mailing list provider is Campaign Monitor in Australia.

Safeguard(s) used: All data is transferred using Secure Sockets Layer (SSL) technology.

Google Analytics

Information collected by Google Analytics (your IP address and actions you take in relation to our website) is transferred outside the EEA and stored on Google's servers in the United States of America.

Safeguard(s) used: Google has self-certified its compliance with the EU-U.S. Privacy Shield.

Your rights in relation to your information

Subject to certain limitations on certain rights, you have the following rights in relation to your information, which you can exercise by writing to or sending an email to legal@lightdegree.com:

• 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 or a .png image file) and the right to have that information transferred to another data controller;
• 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.

In accordance with Article 77 of the General Data Protection Regulation, you also have the right to lodge a complaint with a supervisory authority. For the purposes of the UK, the supervisory authority is the Information Commissioner's Office (ICO): 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 by writing to legal@lightdegree.com:

• 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'; 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; or
• sending an email to legal@lightdegree.com, asking that we stop sending you marketing communications or by including the words "OPT OUT".

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.

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.

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.

Children's Privacy

Because we care about the safety and privacy of children online, we comply with the Children's Online Privacy Protection Act of 1998 (COPPA). We do not knowingly contact or collect information from persons under the age of 18. The website is not intended to solicit information of any kind from persons under the age of 18.

If you would like to notify us of our receipt of information about persons under the age of 18, please do so by sending an email to legal@lightdegree.com.

California Do Not Track Disclosures

"Do Not Track" is a privacy preference that users can set in their web browsers. When a user turns on a Do Not Track signal in their browser, the browser sends a message to websites requesting that they do not track the user.

Copyright, credit and logo

This Privacy Policy is based on a General Data Protection Regulation (Regulation (EU) 2016/769) (GDPR) compliant template provided by GDPR Privacy Policy.

The copyright in this Privacy Policy is either owned by, or licensed to, us and is protected by copyright laws around the world and copyright protection software. All intellectual property rights in this document are reserved.