Thank you for trusting Seven Software Ltd (we, us or Seven Software) to be responsible for your personal data, which we want you to know that we take seriously.
It also informs you how we will look after your personal data when, and about your privacy rights and how the law protects you. It does not cover any third party website you have used to access our websites or any third party websites that you access from them.
It applies to all processing of personal data undertaken by Seven Software other than processing of personal information in the context of recruitment and employment, which is dealt with under separate internal policies.
It is important that you read this policy so that you are fully aware of how and why we are using your data.
- WHO WE ARE
1.1. Contact Details
Our full details are:
Full Name of Legal Entity: Seven Software Ltd, a company incorporated in Northern Ireland under registered company number NI683347
Email Address: email@example.com
Postal Address: 32a Speerstown Road, Ballymena, County Antrim, Northern Ireland, BT42 3DD
ICO Registration Number: ZB293672 (this is the number under which we are registered with the UK Information Commissioner’s Office as a fee paying data controller)
1.2. Under the UK General Data Protection Regulation or the EU General Data Protection Regulation (collectively GDPR) and other relevant data protection legislation, we act as both a data controller (i.e. where we make decisions) in relation to your personal data that we collect, as well as a data processor (i.e. process data broadly in accordance with your instructions).
When we act as a Data Processor: Whenever we act as a processor, or a sub-processor, we will be restricted in the manner and purpose for which we can use personal data (including where applicable in the manner outlined in this policy) and we will also be subject to other obligations under data protection legislation. For example, any personal data contained in any footage or embedded content will be processed by us as a data processor. You are the data controller in respect of any such personal data, responsible for determining the means by which and the purposes for which such personal data is processed.
When we act as a Data Controller: By contrast, we collect personal data and determine the purposes and means of processing that personal data we act as a data controller with respect to that data. For example, when you provide your name, email address and other personal details including email addresses, or we collect other personal data from you when visiting our websites (for example subscriptions to any mailing lists), we act as a data controller.
1.3. Third Party Links
- WHAT KIND OF PERSONAL DATA DO SEVEN SOFTWARE PROCESS?
INFORMATION YOU SUPPLY TO US
2.1. General Personal Data – This is personal information about you that you share with us by online forms on our website (including when submitting footage and/or embedded content), through email, through the post, on the telephone, when you complete customer surveys, engage with us through our contact form or by any other means.
Typically, when you deal with us, you may provide direct information about yourself and other data about your business, including your full name, billing address, business name, personal and/or personal email address, telephone and/or mobile phone number and other contact details. You may provide similar information where you contact us or sign up to our newsletter (if applicable).
2.2. Processed Data (including Third Party Data): When you use our services, you may upload personal data relating to yourself or third parties, either as contained in the footage or embedded content, or in respect of user profiles (email addresses and names) that you upload for marketing campaigns involving footage you share through our platform - in respect of which we act as a data processor. Any such personal data you provide is described as Customer Data below.
2.3. Feedback Data: If you agree to take part in feedback sessions to improve our services, or otherwise provide suggestions or comments regarding our services (feedback), such feedback may be incorporated into, or used to improve, our services. You agree any such feedback shall be non-confidential and non-proprietary and that you shall grant us a perpetual, royalty free, irrevocable, worldwide, transferable and sub-licensable licence to use any such feedback as we see fit. You also agree to waive, or procure the waiver of, all moral rights (or equivalent rights) in respect of same.
2.4. Financial Details: Where you are one of our suppliers and provide us with your financial details in order to facilitate payments by us to you, we will collect these financial details. All such details will be kept securely.
2.5. Verbal Information: If you provide verbal personal information that you give us consent to use you will have such consent confirmed back to you in writing.
2.6. Marketing Information: You may also communicate your preferences in receiving marketing from us and our third parties and your communication preferences (including details you provide when you opt-in to receive marketing communications from us).
IF YOU FAIL TO PROVIDE PERSONAL DATA
2.7. Where we need to collect personal data by law, or under 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 our services or to make payments to you as a supplier). In this case, we may not be able to fulfil any such contract, but we will notify you if this is the case at the time.
PERSONAL DATA WE COLLECT
2.8. Technical Data from our Website: We use certain technical services to gather technical data online whenever you use our website including information about your device and your visits to our website such as your IP address, geographical location, browser type, referral source, length of visit and pages viewed.
We will collect this data using cookies and other similar technologies. There is account login functionality on our website, so if you are logged in you will be personally identifiable from such data.
Please see our cookie and similar technologies policy in relation to our website for further details which can be accessed here. [Note: insert hyperlink to cookies policy]
PERSONAL DATA WE RECEIVE FROM THIRD PARTIES
2.9. Device Data: We may receive data about the device from which you have accessed our website from analytics providers such as Google Analytics, who may be based outside the UK.
2.10. Social Media: Publicly available information through social media sites, such as Facebook, LinkedIn, Twitter and Google. This includes where you have responded to a promotional item or offer from us through, or otherwise interacted with us via, social media facilities, in which case we may receive profile information about you which can include your name, address, telephone number(s) and/or your contact details. This information would be used to respond to your interest, to fulfil a request from you and/or to send you future information and offers, where you have given clear consent to do so.
2.11. Publicly Available Information: We may also collect personal information about you from other publicly available sources. This can include your name, address and other publicly available information. As far as possible, we ensure that where any third-parties are involved in supplying such information, they are legally permitted to do so.
2.12. Customer Data: As noted above, we may have received personal data about you from someone other than yourself, where comprised in the Customer Data they upload using our services.
2.13. Other Sources: From time to time, we may receive personal information from other sources. We will always endeavour to ensure such information is provided from reputable sources.
KEEPING YOUR PERSONAL DATA UP TO DATE
2.14. It is important that the data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
- WHAT INFORMATION IS NOT COLLECTED?
3.1. Other than as captured incidentally in any Customer Data that is uploaded to our services, we do not intentionally collect sensitive personal data or special category data (including details about your race or ethnicity, religious or philosophical beliefs, medical information, sex life, sexual orientation, political opinions, trade union membership, genetic and biometric data, social security numbers). Nor do we collect any information about criminal convictions and offences.
However, we do not proactively monitor this and cannot be held responsible where our customers breach these restrictions.
3.2. If you’re a child under the age of 16 (or are otherwise younger than the legal age limit required in the country in which you reside), you may not use our services or create an account on our website.
If you are a child aged between 16 and 18 using our services / websites from the UK or European Union, you must have informed your parents or guardians of this and of the terms of this policy and have their consent to do so.
We do not knowingly collect information from or direct any of our content specifically to children under relevant ages of consent in any jurisdiction, but personal data relating to children may be captured as part of any Customer Data that is uploaded by third parties.
- HOW IS INFORMATION USED?
4.1. 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:
4.1.2.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.
4.1.3. Where we need to comply with a legal or regulatory obligation.
4.2. On a practical level, other than storing the Customer Data or disclosing it to third parties as set out elsewhere in this policy, we will typically only use the Customer Data for the following purposes:
4.2.1. To operate, maintain and improve our services and its related features, including, for example, generating a copy of the footage as uploaded by you, but incorporating the embedded content you provide, before providing you with a link to a hosted copy of the combined footage (this URL will be shared solely with you, but will be accessible to third parties who click it, and does not sit behind any restricted access URL);
4.2.2. Where we need to comply with a legal or regulatory obligation, including, for example, where a data subject requests a copy of any footage we hold for their own purposes (discussed further below).
In respect of such Customer Data, we rely on the consent you have obtained from the relevant data subjects identifiable in such content to permit us to process it in accordance with this policy.
4.3. Generally, we do not rely on consent as a legal basis for processing your personal data other than as set out below in relation to marketing and testimonials. If we are acting as a We may process your personal data for more than one lawful ground depending on the specific purposes for which we are using your data.
4.4. Our Standard Business Operations:
4.4.1.To provide the services and any other responsibilities we contract with you to fulfil;
4.4.2.To provide you with information that you request from us; and
4.4.3. To confirm your identity as a natural living person;
We may also use contact information to notify you of any issues which might impact the provision of our services.
We maintain multiple contact lists (with email addresses and other information) to allow us to communicate with individuals who do business with us or who have expressed an interest in our services.
We may contact you to respond to requests that you make, notify you of changes to the services, for marketing purposes, or to otherwise inform you of information related to our business.
You will only receive marketing communications from us if you have opted to receive them. This includes where you have consented to being contacted by us by email or telephone. You can opt in over the phone, by email, or online. You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us, as appropriate, at any time.
Where you opt out of receiving marketing messages, this will not apply to personal data provided to us as a result of your engagement with us to provide products to you.
We will never sell your personal data to any third party (as noted below).
We may, with your consent, post customer testimonials and comments on our website or other platforms, which may contain personal data.
4.7. 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.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allow 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.
4.8. Legal Requirements
We will keep and use your data in terms of any legal or regulatory requirements that we have and can use your data to protect our legal position, if legal action is required, including the recovery of any outstanding debts.
By way of further example, we will share your personal data or any Customer Data with the relevant agencies and without notice, where we are requested to or suspect fraudulent activities, money laundering, terrorist related activities or other illegal behaviour.
4.9. Website Administration and Customisation
We may use the information we collect about you for a variety of website administration purposes, and customisation purposes. For example, we use your information to process your registration request, provide you with services and communications that you have requested, send you email updates and other communications, customise features and advertising that appear on our website, deliver our website content to you, measure Website traffic, measure user interests and traffic patterns, and improve our website and the services and features offered via our website.
4.10. Aggregated or Non-Identifying Information
Non-identifying information includes information collected from or about you that does not personally identify you – including aggregated information. Seven Software IP addresses, log file information, anonymised feedback, user agent strings, computer IDs, and related information as non-identifying information, except if applicable law suggest us to do otherwise. Seven Software may use non-identifying information for any purpose.
Certain jurisdictions, including the European Union, may deem IP addresses and/or Unique IDs, to be personal data. Accordingly, for persons in such jurisdictions, our use of Non-Identifying Information as described in this policy should be assumed to include IP address and Unique ID data.
- WHAT INFORMATION IS SHARED?
5.1. We do not disclose personal data outside Seven Software, except in the situations listed in this section or in the section below on Compelled Disclosure, but may have to share your personal data with the categories of data processors or data controllers set out below for the purposes set out in above or otherwise below:
5.1.1. with 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;
5.1.2. with third party purchasers, if we buy, sell or merge any business or assets of our business and are required to share data as part of the buying, selling or merger agreement or if our assets are acquired by a third-party, and data is transferred as part of the purchased assets. If any such change happens, we will ensure that it is under terms that preserve the confidentiality of your personal data, and we will notify you on our website or by email before any transfer of your personal data;
5.1.3. with professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services, where they have a need to know same for any of the purposes set out above;
5.1.4. with reputable and trusted third-parties where we have asked them to contact you on our behalf, where you have given us consent, it is part of our contractual agreement, is a legal requirement or there is clear legitimate interest between us (these services may include sending you email, calling you by telephone, sending you information through the post etc.);
5.1.5. with specific selected third parties, determined by us, if you breach any agreement with us, including so as to enforce our rights against you, including credit-reference agencies, debt-collection firms or service providers, solicitors or barristers and law enforcement agencies (if applicable); and
5.1.6. with service providers acting as processors based in the European Union or United Kingdom who provide IT and system administration services, including for the performance of our contract with you, as set out below. When we transfer your data to our service providers we remain responsible for it:
with email marketing services to send marketing emails where you have opted in to receiving them. You can unsubscribe directly from any mailing list using the unsubscribe links provided within emails (excluding footage);
with analytical service providers in order to analyse our website’s traffic to improve products and services (excluding footage); and
with processors offering software tools, or EU or UK based external servers (including externally provided original and backup servers), that are used to store personal data provided by you on our behalf, specifically Heroku and Amazon Web Services, whose privacy policies are available at https://www.salesforce.com/company/privacy/ and https://aws.amazon.com/privacy/.
5.2. 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 provides to use your personal data for their own purposes and only permit them to process the minimal personal data required for the specified purposes, in accordance with our instructions, where they have agreed to privacy restrictions similar to our own policy.
5.3. We do not share, sell, rent or trade personal data with third parties for their commercial purposes. We may also share personal data with your permission, so we can perform services you have requested.
5.4. We may also share personal data with your permission, so we can perform services you have requested.
- IS CUSTOMER DATA TREATED DIFFERENTLY?
6.1. Any footage or embedded content contained on the footage we generate with that call to action via our services may be viewed or captured by third parties where you share it with a third party. We will generate a URL link to the footage featuring the embedded content. Please note that this URL will be publicly accessible from our website, and the relevant footage can be viewed by anyone who accesses the URL, until it is deleted from our platform.
6.2. Whilst there is no download feature permitting third parties to download the footage (including the embedded content) we cannot guarantee that they will not use screen recording or capture, or other features, to take a record of same.
6.3. If you do not want Customer Data to viewed or accessible by third parties, please do not share a link to the footage available to them. However, please note the provisions of Section 7 below.
6.4. Where footage has otherwise been shared under the circumstances outlined above, for example where we are required or requested to provide it to regulatory authority or Governmental body, we cannot control how the footage may be used.
- HOW IS MY INFORMATION SECURED?
7.1. Seven Software takes what we believe to be reasonable measures to protect personal data from unauthorised access, alteration, or destruction, maintain data accuracy and help ensure the appropriate use of personal data. However, please note that our services and website are provided free of charge, and as a start-up company we do not utilise extensive security measures to prevent third parties accessing Customer Data that does not relate to them. Nor can we guarantee that any security measures we employ will not be circumvented. No method of transmission, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee security of your personal data, or any Customer Data.
7.2. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have business need to know. They will only process your personal data on our instructions and they are subject to duties of confidentiality and access to any Customer Data which might feature you will only be permitted to our direct employees or consultants who have been suitably trained in relevant data protection and privacy principles. They will only process your personal data on the relevant customer who provided its lawful instructions and they are subject to duties of confidentiality.
7.3. 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.
- HOW IS INFORMATION COLLECTED AND STORED GLOBALLY?
8.1. Information that we collect will be stored and processed in the United Kingdom or the European Union in accordance with this policy. However, we understand that we have users from different countries and regions with different privacy expectations and local legal requirements, and we try to meet those needs and requirements.
8.2. We provide the same standard of privacy protection to all our users around the world, regardless of their country of origin or location, and we are proud of the levels of notice, choice, accountability, security, data integrity, access, and recourse we provide. We work hard to comply with the applicable data privacy laws wherever we do business. Additionally, we require that if our vendors or affiliates have access to personal data, they must comply with applicable data privacy laws, including signing data transfer agreements such as EU standard contractual clause agreements, where required by law.
8.3. In particular:
8.3.1. We provide clear methods of unambiguous, informed consent at the time of data collection, when we do collect your personal data and if applicable. Where consent is not the applicable ground for processing. We will ensure that we have an appropriate ground for processing any personal data (including but not limited to contractual obligation or legitimate interest);
8.3.2. We collect only the minimum amount of personal data necessary unless you choose to provide more. We encourage you to only give us the amount of data you are comfortable sharing;
8.3.3. We offer you simple methods of accessing, correcting, or deleting data we have collected; and
8.3.4. We provide our users notice, choice, accountability, security, and access, and we limit the purpose for processing.
- WHAT HAPPENS IF I HAVE A COMPLAINT?
9.1. If you have concerns about the way Seven Software is handling your personal data, please let us know immediately. We want to help and there are several ways available that you can contact us. You may also email us directly at firstname.lastname@example.org with the subject line “Data Privacy”. We will do our best to respond as soon as we can, unless required to respond earlier under relevant law.
9.2. If you are a data subject based in the UK, you may 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), or other competent supervisory authority of an EU member sate if your data is collected in an applicable EU member state or you are resident in such member state. We would appreciate the chance to deal with your concerns before you approach such bodies so would ask that you please contact us in the first instance.
- HOW DO YOU RESPOND TO COMPELLED DISCLSOURE REQUIREMENTS?
10.1. Seven Software may disclose personal data or other information we collect about you to law enforcement in response to a valid subpoena, court order, warrant, or similar governmental order, or when we believe in good faith that disclosure is reasonably necessary to protect our property or rights, or those of third parties or the public at large.
10.2. In complying with court orders and similar legal processes, Seven Software strives for transparency. When permitted, we will make a reasonable effort to notify users of any disclosure of their information, unless we are prohibited by law or court order from doing so, or in rare, exigent circumstances.
- HOW CAN I ACCESS MY OWN PERSONAL INFORMATION?
If you're already a user, you may access, update, alter, or delete your basic user profile information by editing your user profile or contacting us.
Under certain circumstances, where you are a citizen of the European Union or UK, you have rights under data protection laws in relation to your personal data under GDPR.
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.
Please 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: (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.
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.
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.
Where you exercise one of your rights, we may need to request specific information from you to help us confirm your identity and ensure your right to exercise such 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.
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.
- DATA RETENTION AND DELETION
Personal Data Generally
12.1. 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.
12.2. 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.
12.3. We will keep your personal data for the term you have consented to, the contracted term between us where there is a legitimate interest for us to remain in contact with you, or for the legally required period, whichever is the longest.
We are not responsible for your data retention requirements in respect of any Customer Data, and you should ensure that any Customer Data you provide is adequately secured and backed-up, as we may delete it at any time.
12.4. By law we have to keep basic information about any of our customers (including contact, identity, financial and transaction data) for six years after you cease being a customer for tax purposes. For the purposes of contract administration, we will also store all data as long as the contract you have placed through us endures and for the six year limitation period thereafter in case you raise any claims in relation to any products you have purchased from us.
12.5. 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.
Customer Data and Data Deletion Requests
12.6. If you would like to initiate deletion of your personal data or any Customer Data you have provided or which you believe features you (e.g. where you have not consented to being included in such footage) you may do so by emailing us directly at email@example.com withthe subject line “Deletion Request”. This email should contain information that allows us to identify the personal data or Customer Data referred to, including the date and approximate time of upload (and a link to any footage we have generated and provided to you).
12.7. As above, we will reserve a right to retain and use your information as necessary to comply with our legal obligations, resolve disputes, maintain security, and enforce our agreements, but barring legal requirements, the timeframes above will be observed for deletion.
- HOW DO YOU COMMUNICATE WITH ME?
13.1. We will use your email address to communicate with you, if you've given us the OK, and only for the reasons you’ve permitted. Emails by default are not disclosed with other users. This will not change how we contact you, as we always utilise your primary email address.
13.2. Depending on your email settings, Seven Software may occasionally send notification emails about new products, requests for feedback, important policy changes, or to offer customer support. We also send marketing emails, including ones featuring, services and products offered by our commercial partners, but only with your consent. There's an unsubscribe link located at the bottom of each of the emails we send you.
13.3. Our emails might contain a pixel tag, which is a small, clear image that can tell us whether or not you have opened an email and what your IP address is. We use this pixel tag to make our email more effective for you and to make sure we’re not sending you unwanted email. If you prefer not to receive pixel tags, please opt out of marketing emails.
If there are material changes to this policy or in how we use your personal data, we will prominently post such changes prior to implementing the change. We encourage you to periodically review this policy to be informed of how we are collecting and using your information.
We keep this policy under regular review, for example, to reflect changing business circumstances and legal developments.
Although most changes are likely to be minor, it may change and if it does, these changes will be posted on this page. Otherwise, any changes shall be applicable without further notice.
This version one of this policy was last updated on 6th May 2022 and historic versions can be obtained by contacting us.
- HOW CAN I CONTACT YOU?
This policy shall be governed by and interpreted in accordance with the laws of Northern Ireland and you irrevocably agree that the courts of Northern Ireland shall have exclusive jurisdiction to settle any dispute which may arise out of, under, or in connection with this policy.