Date of last update: 25th June 2018
- Why we use your personal data
- Your legal rights
- How to make a complaint
Spotted Parrot Ltd area of business is Software development/IT services. It’s services can be categorised into two categories:
Providing development/IT expertise as a service to its clients via a contract either direct ‘Business to Business (B2B)’ or via a ‘Recruitment agency’.
Providing Website or Mobile app services directly to end users via the internet or mobile app stores.
This privacy notice is issued on behalf of Spotted Parrot Ltd, so when we mention “Spotted Parrot”, “SP” , “we”, “us” or “our” in this privacy notice, we are referring to the Spotted Parrot Ltd company responsible for processing your data. Spotted Parrot Limited is the controller and responsible for this website and the services provided to its clients.
Spotted Parrot is firmly committed to privacy, the responsible use of information, the need to safeguard the privacy of our clients and visitors to our website, and to maintaining compliance with privacy legislation.
Spotted Parrot will ensure that the data you supply to Spotted Parrot is processed fairly and lawfully, and with skill and care. We take our responsibilities in respect of your personal data extremely seriously.
Entering into a contract to purchase our services.
Day to day communication conducted under contract.
Requesting information about our services (e.g. via email, telephone, website contact form etc).
Sending Spotted Parrot Ltd a request for proposal or
Enquiring about Spotted Parrot Ltd’s availability for new contract work.
Spotted Parrot Ltd’s services are not intended for children and we do not knowingly collect data relating to children through our services.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.
We have a data privacy contact who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights please contact the data privacy person at firstname.lastname@example.org.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
This website may include links to third-party websites, plug-ins and applications as well as embedded content such as YouTube videos. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
2. The data we collect about you
Personal data, or personal information, means any information which identifies an individual. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
|Contact Data||includes email address, phone number, postal address or other information included in your correspondence or contracts with us.|
|Identity Data||includes first name, last name or other information included in correspondence, contracts or mobile app/website accounts created with us.|
|Marketing and Communications Data||includes your Contact Details for us to send marketing communications to you|
|Technical Data||includes 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, our mobile apps or other services.|
|Usage Data||includes information about how you use our website, mobile apps or other services.|
We also collect, use and share “Aggregated Data” such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website/mobile app feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any Special Categories of Personal Data about you (this includes details 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). Nor do we collect any information about criminal convictions and offences.
3. How is your personal data collected
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us on this website, by email or by telephone. This includes personal data you provide when you:
subscribe to our service(s).
request marketing to be sent to you
send us information about a request for proposal
contact us in relation to a business, media, supplier or career enquiry
enter into a contract for services either directly (B2B) or via a recruitment agency.
communicate day to day whilst Spotted Parrot Ltd provide their service(s) to you.
give us some feedback.
report bugs or issues.
Automated technologies or interactions. As you interact with our website or mobile applications, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using server logs and other similar technologies.
Third parties or publicly available sources. We may receive personal data about you from analytics providers.
4. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
where we need to perform the contract we are about to enter into or have entered into with you
where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests
where we need to comply with a legal or regulatory obligation
to confirm specific dates that Spotted Parrot Ltd provided services to you or your company (e.g. as required by Vetting services).
Section 5 gives more information about the lawful basis that we will rely on to process your personal data.
Generally, we do not rely on consent as a legal basis for processing your personal data. You have the right to opt out from marketing at any time by emailing email@example.com and requesting to be unsubscribed from any marketing.
5. Why we use your personal data
In the table below, we have described all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us via email on firstname.lastname@example.org if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To provide development services contracted with you or your employer.||(a) Identity (b) Contact (c)||(a) Performance of a contract with you or your employer|
|To administer and protect our business and the services we provide (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity (b) Contact (c) Technical||(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation|
|To contact you following you making a request for further information from us via the website/email/telephone or any other form of communication.||(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical||Necessary for our legitimate interests (to study how customers use our services, to develop them, to grow our business and to inform our marketing strategy.|
|To use data analytics to improve our website, services, marketing, customer relationships and experiences||(a) Technical (b) Usage||Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. If you no longer want to receive marketing communications from us you can contact us via email on email@example.com.
We may use your Identity, Contact or which of our services you have previously used to form a view on whether you may be interested in Spotted Parrots services in the future. This is how we decide which services and offers may be relevant for you.
You will receive marketing communications from us if you:
have requested information from us
purchased services from us
provided us with your contact details when we met you at a event, conference or meeting
and, in each case, you have not opted out of receiving marketing communications from us.
7. Opting out
You can ask us to stop sending you marketing messages at any time by contacting us via email on: firstname.lastname@example.org
Where you opt out of receiving these marketing messages, Spotted Parrot Ltd may still hold personal data provided to us as a result of us providing a service or other interaction with Spotted Parrot Ltd.
8. Change of purpose
We will only use your personal data for the purposes that we collected it for, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us via email on email@example.com
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
9. Correcting and updating your profile
To help us keep our information up-to-date we would be grateful if you would let us know as soon as any of your contact details change or if you notice any inaccuracies in your details.
10. Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
Internal Third Parties as set out in the Glossary.*
External Third Parties as set out in the Glossary.*
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
*: Please note that where we use third parties to provide us with a IT service(s) to store your data (e.g. Email provider, Backup data service), Spotted Parrot pick providers that have strong security measures in place to ensure only Spotted Parrot Ltd has access (for example: via account passwords and encryption).
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. We will not disclose any personal data you have given to us other than as described in this statement, unless you have authorised us to so do, or if we are required to do so by law. Please note that if at any time Spotted Parrot is required by law to release information about you, Spotted Parrot will do so and will co-operate fully with the relevant authorities.
11. International transfers
Where a third party is used by Spotted Parrot to provide IT services (e.g. Email provider, Data backup service). They may provide the service involve transferring your data outside the European Economic Area (EEA).
In such a case, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model Contracts for the transfer of personal data to third countries.
Where we use providers based in the US, we may transfer data to them either based on Model Contracts, or if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
Please contact us via email on firstname.lastname@example.org if you want further information on the specific mechanism used by us when third parties are transferring your personal data out of the EEA.
12. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
13. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we keep basic information about our customers (including Contact, Identity, Contract data) for six years after they cease being customers for tax purposes.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
14. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
If you wish to exercise any of the rights set out above, please contact us via email on email@example.com.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Legitimate Interest means Spotted Parrot’s interest in holding and managing your details to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
External Third Parties
Service providers acting as processors based in the European Union and outside the European Union who provide IT and system administration services.
Professional advisers acting as processors including marketing professionals, accountants, lawyers, bankers, auditors and insurers based in the European Union or outside the European Union who provide consultancy, banking, legal, insurance and accounting services.
Your legal rights
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
16. How to make a complaint
If you are unhappy with the way in which your personal data has been processed you may in the first instance contact us by email firstname.lastname@example.org. If you remain dissatisfied then you have the right to apply directly to the Information Commissioner for a decision. The Information Commissioner can be contacted at:
Information Commissioner’s Office
If the changes are significant, we may also choose to email all our clients with the new details.
If required by law, we will get your permission or give you the opportunity to opt out of any new uses of your data.