Privacy Policy

When you request information from Nutbourne Ltd, access our website, or purchase any services or products from us including but not limited to IT Services where Nutbourne Ltd gathers information via its automated systems and ticketing systems, we obtain information about you. This statement explains how we look after that information and what we do with it.

Nutbourne Ltd (company registration number 06347139 and registered address 85 Great Portland Street, First Floor, London, W1W 7LT (“Nutbourne” or “we” or “us” or “our”) is committed to compliance with all relevant Data Protection regulations including the General Data Protection Regulation (GDPR). As part of this, we ensure we maintain appropriate procedures and work instructions to control your data.

Most information we hold comes directly from you and our lawful basis for processing this data is our contract with you and our legitimate interest in marketing our goods and services. Whenever we collect information from you, we make it clear which information is required in order to provide you with the information, services or goods you are requesting. All information we hold on you is stored in a central, audited system and access is restricted to those who need to know.

Nutbourne’s services are provided from our Head Office in 11 Burford Rd, London E15 2ST, United Kingdom along with our field services team who work across the country. The information you provide us is used to deliver our managed services, projects and occasionally contacting you with information or opportunities. All employees will be provided with training to ensure that they understand the policies and procedures Nutbourne Ltd’s has put into place.

You have the right to ask us not to contact you and we will always provide you a clear way to opt out of communications. You can also contact us directly at [email protected] at any point to get further information on our policies, the data we hold on you or opt out of any future marketing material.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide (including our terms and conditions and terms of business as well as any other associated policies either referred to within this policy or other documents or otherwise available from us on request) 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. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Controller

Nutbourne Ltd (company registration number 06347139 and registered address 85 Great Portland Street, First Floor, London, W1W 7LT is the controller and responsible for your personal data.

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact our DPO in the following ways:

Full name of legal entity: Nutbourne Ltd (company registration number 06347139 and registered address 85 Great Portland Street, First Floor, London, W1W 7LT)

Email address: [email protected]

Contact postal address: 11 Burford Rd, London E15 2ST, United Kingdom

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.

Changes to the Privacy Policy

We keep our privacy policy under regular review. 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.

1. THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. 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 as follows:

“Identity Data” includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
“Contact Data” includes billing address, delivery address, email address and telephone numbers.
“Financial Data” includes bank account and payment card details.
“Transaction Data” includes details about payments to and from you and other details of products and services you have purchased from us.
“Technical Data” includes internet protocol (IP) address, all technical information and data we hold as an MSP IT Provider, your login data, 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.
“Profile Data” includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
“Usage Data” includes information about how you use our website, products and services.
“Marketing and Communications Data” includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share “Aggregated Data” such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will 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 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 policy.

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.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

2. 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, Contact and Financial Data] by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- apply for our products or services as part of which the following apply and gather and/or hold data:
  - our automated monitoring software (referred to as Remote monitoring and/or Nutbourne Lifeline but subject to any changes in said software as we in our sole discretion may determine)which gathers data on all computers (including but not limited to username, IP address etc) and which gathers information through this related to the computer & servers we support; and
  - within our ticketing system, via email back and forth;
- require or are otherwise provided with our IT Services where Nutbourne Ltd gathers and/or hold data:
  - our automated monitoring software (referred to as Remote monitoring and/or Nutbourne Lifeline but subject to any changes in said software as we in our sole discretion may determine) which gathers data on all computers (including but not limited to username, IP address etc) and which gathers information through this related to the computer & servers we support; and
  - within our ticketing system, via email back and forth;
  - create an account on our website;
  - subscribe to our service or publications;
  - request marketing to be sent to you;
  - enter a competition, promotion or survey; or
  - give us feedback or contact us.
Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.
Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
- Technical Data from the following parties:
  - analytics providers;
  - advertising networks; and
  - search information providers:
  - Contact, Financial and Transaction Data from providers of technical, payment and delivery services;
  - Identity and Contact Data from data brokers or aggregators; and/or
  - Identity and Contact Data from publicly available sources.

3. 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 obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message, including those via data brokers via legitimate interest where the data broker has obtained consent via opt in to communications and we thereafter, will use a search perimeter to define legitimate interest. You have the right to withdraw consent to marketing at any time by contacting us and we will provide an opt-out in all email communications.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of 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 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	Retention Periods for Data
To register you as a new customer	(a) Identity (b) Contact (c) Financial	Performance of a contract with you	Life of the Contract + 1 Year
To process and deliver your order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us)	Life of the Contract + 6 Years
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)	Life of the Contract + 1 Year
To enable you to partake in a prize draw, competition or complete a survey	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)	1 Year
To administer and protect our business and our website (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	6 Months
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(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 products/services, to develop them, to grow our business and to inform our marketing strategy)	6 Months
To use data analytics to improve our website, products/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)	6 Months
To make suggestions and recommendations to you about goods or services that may be of interest to you	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications	Necessary for our legitimate interests (to develop our products/services and grow our business)	4 Years from last customer response
To provide technical support to your users and your company under our status as an MSP IT Provider	(a) Identity (b) Contact (c) Usage (d) Profile (e) Marketing and Communications	Performance of a contract with you	12 Years since last contact
To provide technical support to your users and your company under our status as an MSP IT Provider	(a) Passwords	Performance of a contract with you	Life of the contract + 3 Months or 3 months since last project engagement
To provide technical support to your users and your company under our status as an MSP IT Provider	(a) Technical	Performance of a contract with you	Life of the contract + 1 Year or 1 Year since last project engagement
To delivery one off systems or security audits	(a) Identity (b) Contact (c) Usage (d) Profile (e)Passwords (f)Technical Data	Performance of a service with you	3 months from delivery of audit
To deliver Design & Build Services	(a) Identity (b) Contact	Performance of a service with you	10 years since last project engagement
Call recording for the purposes of training and monitoring	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications	Performance of a service with you	6 Year

Email Retention

Email may contain Personal Data which is sent by either the customer or Nutbourne for the application, provision or cancelation of services or other reasons. For the avoidance of doubt our email retention policy is as follows:

All email: retain on fast storage for 24 months
All Email between 24 months and 48 months retained in online archive
Senior Management & Finance Email between 48 months – 120 months – Retain in Encrypted Offline Storage
“Fast storage” = accessible through end user’s email clients normally only individual users can access, but administrators can access too
“Online Archive” = accessible to end users email client on encrypted devices but not mobile devices. Normally only individual users can access, but administrators can access too
“Encrypted Offline storage” = accessible through internal utility and search; only administrators can access

Where a data removal request is made to Nutbourne personal data it will be purged where possible and where it is not subject to other reasons for retention such as contract, legal, taxation or any other legitimate reason, it will be retained for the applicable time period as set out within the above table. In all other cases Personal Data will purge from email in line with the retention policy above.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods and/or services from us and you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookies policy.

Change of purpose

We will only use your personal data for the purposes for which we collected it, 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 on the details above within this privacy policy.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

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.

4. DISCLOSURES OF YOUR PERSONAL DATA

We may share your personal data with the parties set out below for the purposes set out in the table above.

Internal Third Parties being – other companies in the Nutbourne Group acting as joint controllers or processors and who are based in the United Kingdom.
External Third Parties being –
- Service providers acting as processors based in the United Kingdom who provide IT and system administration services.
- Professional advisers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
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 policy.

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.

5. INTERNATIONAL TRANSFERS

We do not transfer your personal data outside the European Economic Area (“EEA”).

6. 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.

7. DATA RETENTION

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

Details of retention periods for different aspects of your personal data are set out in the table above. By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances we will 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.

8. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

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.
“Request erasure” of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
“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:

If you want us to establish the data’s accuracy.
Where our use of the data is unlawful but you do not want us to erase it.
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.
You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

“Request the transfer” of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
“Withdraw consent at any time” where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us.

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 could 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 could 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.

9. GLOSSARY

“Legitimate Interest” means the interest of our business in conducting and managing our business 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 on the details set out above within this privacy policy.

“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 obligation” means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.