1. Only those within your organisation with the appropriate access level are able to view your information & we restrict access on our end.
2. If you’d like to access, amend or delete any information please contact email@example.com
If at any time you are concerned or have questions about how we might be handling your data, please reach out to our Data Protection Officer at firstname.lastname@example.org
Sunlight Technologies Limited (“Sunlight”, "We", “Us” and “Our”) remain fully committed to the protection of your and your Users’ privacy at all times. The information contained in this policy has been published to inform you of the way in which any Personal Data (as defined below) you provide us with or we collect from you will be used. Please read this information carefully in order to fully understand how we treat such Personal Data.
We will collect, store, use and disclose Personal Data in accordance with all applicable laws relating to the protection of Personal Data, including the EU Data Protection Directive 95/46/EC, the EU General Data Protection Regulation 2016/679, the EU ePrivacy Directive 2002/58/EC as amended by Directive 2009/136/EC, as amended or superseded from time to time, and any national implementing legislation (“Data Protection Laws”).
For the purpose of Data Protection Laws, in relation to any Personal Data you or any Users submit to our platform, you will be the data controller and we will be a data processor of such Personal Data.
“Personal Data” means any information relating to an identified or identifiable natural person; an identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
We may obtain and use the following Personal Data about you and anyone you chose to add to our platform:
Any correspondence we have with you and your Users should you or your Users contact us. Data you or your Users provide when you fill out forms on our Website, including but not limited to data you provide when you register to become a user of the Service. Data and information you or your Users submit or upload to Sunlight or the Service, including employee data (which may include, among other things, dates of birth, residential addresses, names, email addresses, telephone numbers, bank details). Details of transactions made by you through the Website. Responses to optional research surveys we ask you or Users to complete. Details of your or your Users’ visits to our Website, which includes without limitation location and traffic data, weblogs, resources you access and other communication data.
You will be submitting and providing Client Data which may contain Personal Data (and potentially Sensitive Personal Data of Users and third parties. “Sensitive Personal Data” means any data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic or biometric data, data concerning health, data concerning sex life or sexual orientation and data concerning the commission or alleged commission of any offence.
You represent and warrant that you
i) have the right to transfer such Personal Data (including Sensitive Personal Data, if applicable) to us for the purpose of receiving the Service; and
You agree to indemnify us in accordance with Clause 13 of the Sunlight Terms and Conditions for any claims made by any Users arising from any unauthorised access or accidental loss, damage, corruption or disclosure of Client Data arising from or in connection with your and/ or our use or disclosure of Client Data.
We may obtain information about your and your Users’ computer, which includes your and your Users’ IP address, browser type and operating system where available. This accumulation of data is used to assist system administration.
We may also collect information regarding your or your Users’ browsing activity and interests through use of a cookie file. This cookie file is stored on the hard drive of your or your Users’ computer, and contains information that is transferred to your or your Users’ computer's hard drive. We use the collection of this data to help us improve the experience of users on our Website and Service, and to deliver a more personalised service with more relevant content. The collection of this data allows us to:
The Personal Data we obtain from you and your Users (including, without limitation, Client Data) may be moved to and stored at a destination within the European Economic Area ("EEA"). Staff members operating within the EEA who work for or on behalf of us may process this information. Such staff members may, among other things, be involved in the processing of payment details, the provision of support services and the delivery of your and your Users’ request(s) for us to provide the Service.
Without limiting the foregoing, you agree that Personal Data we obtain from you and your Users (including, without limitation, Client Data) may be processed by our service providers based in, countries outside of the EEA for the purposes of providing you with the Service. Such countries may not have laws offering the same level of protection for Personal Data as those inside the EEA; however where such transfers of data occur, we will take steps to prevent the transfer of Personal Data without adequate safeguards being put in place and will ensure that your and your Users’ Personal Data collected in the EEA and transferred internationally is afforded the same level of protection as it would be inside the EEA. For further information on, or a copy of, the adequate safeguards adopted by us for the international transfer of Personal Data, please email email@example.com.
We store the Personal Data you and your Users provide us with on our secure servers. In the event of us giving you or your Users (or you/they choosing) a password which grants you/them access to specific areas within our Website or Service, it remains your/their responsibility to maintain the confidentiality of this password. This includes the responsibility to refrain from sharing your/their password with other parties.
As the transmission of data via the Internet cannot be assumed completely secure, we cannot guarantee the security of any of your or your Users’ data transmitted to our Website or Service; you are therefore responsible for any risk associated with such transmission. We will however at all times take all reasonable steps to ensure the transmission of your and your Users’ data is executed as securely as possible, and upon receipt of your/their data we will continue at all times to enforce strict security procedures and features in an attempt to prevent any unauthorised access.
We will take reasonable steps to maintain appropriate technical and organizational measures to protect the Personal Data you provide to us against accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to your Personal Data. For more information, please have a look at ourSecurity Policy.
The Personal Data we hold about you and your Users may be used in any of the following ways:
Disclosure of your and your Users’ Personal Data (including, without limitation, Client Data) to third parties will only occur in any of the following events:
You acknowledge and agree that we may also disclose Personal Data (including, without limitation, Client Data) with:
Our service providers have to follow our express instructions when processing the Personal Data you or your Users provide and must have in place appropriate technical and organisational security measures to safeguard such Personal Data, and we do not allow them to use this information for their own commercial purposes.
You retain the right to request us to refrain from processing your data for the purposes of marketing. To exercise such right, you may reply to any information we send you, detailing your request that we refrain from sending any marketing correspondence, or you can exercise this same right by contacting us electronically via email at firstname.lastname@example.org. If at any time we intend to use your data for such marketing purposes however, it is standard practice for us to make you aware in advance of collecting such data.
We may at times provide links on our Website to third party websites, including without limitation those owned or managed by our partner networks, affiliates or advertisers. These websites have separate privacy policies, and we therefore cannot accept any responsibility for the content. As such, choosing to follow these links is a choice you make at your own risk, and we advise that you check these websites' individual privacy policies before submitting any personal data.
You retain at all times the right to access / amend / delete any Personal Data we hold about you or to exercise your right of data portability or to object to, or restrict, the purposes for which your Personal Data is processed on certain grounds. You may exercise this right by making a request in accordance with Data Protection Laws, by email at email@example.com You may also lodge a complaint with the UK data protection regulator, the Information Commissioner should you be dissatisfied with the way that we handle your Personal Data.
We will keep your and your Users’ Personal Data for the duration of the Service and in accordance with your instructions or for such periods as may be required by law.
If at any time we make a change to this policy, we will update this page to reflect such change. Where we feel it appropriate, we will notify you by email, however we recommend you review this page periodically to ensure you remain happy with the latest version.