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We are Agile Solutions (GB) Ltd, a company registered in England and Wales with company no. 8997297 and registered office at 454 Exchange House, Midsummer Boulevard, Milton Keynes, England, MK9 2EA. We may also use several other companies that we own or control when providing services to you or your business (our “Affiliates”).
We operate or control the following domains (collectively, our (“Website”)):
For the purposes of data protection law, we will be a controller of the personal data we hold about you. This means we make decisions about how and why your data is used, and have a legal duty to make sure that your rights are protected. Our Data Protection Officer can be contacted using the details given below.
We collect the following types of personal data:
Data you give us
When you fill in forms on our Website, we will receive the personal data they contain. This information may be provided at the time of requesting information about what we do or registering to attending a training session we provide. If you contact us, we may keep a record of that correspondence.
Information we collect about you from Public sources
We pride ourselves on having deep knowledge of the industry we operate in. This involves conducting research on other companies whom we might like to purchase goods or services from, or whom we may wish to open discussions with about our own offerings. We may gather personal information about you as part of this research e.g. from your publically-available LinkedIn profile, from press articles about you or your company, or from open government databases e.g. Companies House. We may also receive information about you if you post on any of our social media pages, connect with us on LinkedIn or interact with us on Twitter.
We will never collect personal information which is not publically accessible and will not use it in a way which is privacy-intrusive. We will respect your wishes if you tell us that you do not want to be contacted for these purposes.
Information we collect From Affiliates
We may obtain personal information about you from our Affiliates (Agile Recruitment) regardless of whether these entities share the Agile Solutions brand. We may use any high-level personal information that we obtain from our Affiliates in accordance with the terms under which that information was collected by that Affiliate.
Information we collect as part of our contract with you
If you engage us to develop software, integrate software packages into your system, or provide tech support for any of the above, we may need to access your customer database in order to do so. Your database will likely contain personal data about your individual customers (or their employees if they are business-to-business customers). There are certain situations where we cannot develop software, improve performance or fix bugs without accessing or holding this information. If we do need access to your customer database, we will tell you. We store your data on secure servers within the EU (either at our own premises or in the data centres of trusted third-party providers). All our employees are bound by strict rules regarding confidentiality and we will never use this customer personal information in a way which you have not authorised.
When you visit our Website, we may collect information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our Website (including the date and time); pages you viewed; page response times, download errors, lengths of visits to certain pages, page interaction information (such as scrolling, clicks and mouse-overs), methods used to browse away from the page; if you linked to our site from another website, the address of that website, and, if you linked to the site from a search engine, the address of that search engine and the search term you used; and actions performed on the Website using cookies and page tagging techniques to help us improve the Website.
Special Category Data (also known as sensitive personal data)
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.
A cookie is a small file of letters and numbers that we store on your browser or device if you agree.
We use the following types of cookies:
(a) Strictly necessary cookies.
These are cookies that are required for the operation of our Website. They include, for example, cookies that enable you to log into secure areas of our Website.
(b) Analytical/performance cookies
These cookies allow us to recognise and count the number of visitors and to see how visitors move around our Website. This helps us to improve the way it works, for example, by ensuring that users are finding what they are looking for easily.
(c) Google Analytics
If you wish to refuse Google’s cookies, you can do so by downloading and installing Google Analytics Opt-out Browser Add-on. More generally, you can refuse to accept some or all cookies by modifying settings within your browser. For guidance on how to do this visit www.aboutcookies.org. However, if you block strictly necessary cookies, you may be unable to access certain parts of our Website.
You can manage your cookie settings at any time using the button below.
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:
(a) where we need to perform a contract with you;
(b) 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 (see the “Legitimate Interests” section below); and
(c) where we need to comply with a legal or regulatory obligation.
We may use personal data held about you in the following ways:
(a) to provide users with offerings that have been requested;
(b) to communicate with you about news, new products and other activities happening at Agile Solutions;
(c) to research the effectiveness of the Website and the marketing, advertising and sales approach we have taken;
(d) to process job applications;
(e) to ensure that content from our Website is presented in the most effective manner for you and for your device;
(f) to respond to queries you send us; and
(g) to carry out our obligations arising from any contracts entered into between you and us, or between us and our clients e.g. where you are an employee of a client.
When contacting you for the above purposes we may do so by phone, post, email or other electronic means, unless you instruct us not to do so.
Your data will be treated in accordance with applicable data protection law. It will not be disclosed to anyone outside of Agile Solutions, its Affiliates and any other parties named or described in section 7 below.
We may rely on legitimate interests to process your personal data, provided that your interests do not override our own. Where we rely on legitimate interests, these interests are:
(a) to keep our records updated and to study how our Website is used;
(b) to administer and protect our business and web presence (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting); and
(c) to grow our business and inform our marketing strategy.
Agile Solutions (GB) Ltd has a telephone system that is capable of recording conversations. Like many other organisations, this is a standard practice that allows the recording of telephone calls for quality monitoring, training and to make sure that we are providing you with information tailored specifically to the needs of your business.
We shall ensure that the use of these recordings is fair and that we comply with the requirements of the relevant legislation. This includes:
- The Regulation of Investigatory Powers Act 2000
- The Telecommunications (Lawful Business Practice) (Interception of Communications Regulations) 2000
- The Telecommunications (Data Protection and Privacy) Regulations 1999
- The General Data Protection Regulation 2016
- The Data Protection Act 2018
- The Human Rights Act 1998.
Scope of policy
All calls made to our internal sales teams will be recorded following the guidelines below.
If it becomes clear that a communication is private or the person making the call says that they do not wish to have their call recorded, the call recording will be stopped.
We will only retain call recordings which result in a meeting with us, the recording will be deleted once the meeting has taken place. These recordings will only be used for the purposes specified in this policy.
The recordings will be stored securely, with access to the recordings controlled and managed by the Data Protection Officer. Access will be given to Directors, Heads of Departments and Managers, as they will be assessing call quality and attending meetings.
Presumably every employee who makes recorded calls has the power to stop a recording if this occurs?
What is the longstop e.g. if an employee has a few calls with a prospect, and a month then goes by without a meeting, will the calls be deleted? Is deletion an automated process? If not, who has the authority to delete recordings?
Where you are acting as an agent, employee or contractor of one of our business customers, we may send you information about our products and services by e-mail or post. If you wish to opt out of receiving such material, please either contact us using the details given in section 1 above, or click the “unsubscribe” link in any of our marketing e-mails.
We employ a variety of physical and technical measures to keep your personal data safe and to prevent unauthorised access to, use or disclosure of it. Electronic data and databases are stored on secure servers in the EU and we control who has access to them (using both physical and electronic means). Our staff receive data protection training and we have a set of detailed data protection procedures which they are required to follow when handling personal data.
Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. We cannot absolutely guarantee the security of the internet, external networks, or your own device, accordingly any online communications (e.g. information provided by email or through our Website) are at your own risk.
Where we store your personal data
We store all of your personal data within the European Economic Area (“EEA”) and do not foresee a need to transfer it outside of the EEA. However, if this does occur, we will make sure that it is transferred securely, and in a way which complies with applicable law.
How long we keep it
We collect and store personal data for purposes connected with our business. As such, we will only retain your personal data for as long as necessary for those purposes. If you send us personal data in connection with a job application but are not given a position within Agile, we may keep it for up to 2 years in order to guard against legal risks.
We keep information which forms part of our business record for 6 years, in order to guard against the risk of a legal claim or a request by the tax authorities to review our business records.
We may need to disclose your personal data to third parties. Where we do so, any such disclosure will be on the basis that these third parties are required to keep the data we give them confidential and secure, and will not use it for any other purpose than to carry out the services they are performing for us. We may disclose personal data to:
(a) 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 policy;
(b) our professional advisors; and
(c) our Affiliates.
We are subject to the law like everyone else. We may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order.
We also may need to retain and disclose certain personal data about you to regulatory authorities and to appropriate agencies to conduct anti-money laundering checks and to assist with fraud prevention. We will disclose this information as is required by law.
We want you to remain in control of your personal data. Part of this is making sure you understand your legal rights, which are as follows:
(a) where your personal data is processed on the basis of consent, the right to withdraw that consent;
(b) the right to confirmation as to whether or not we are holding any of your personal data and, if we are, to obtain a copy of it;
(c) the right to have certain data provided to you in a portable electronic format (where technically feasible);
(d) the right to have inaccurate personal data rectified;
(e) the right to object to your personal data being used for marketing or profiling, or on the basis of our or a third party’s legitimate interests;
(f) the right to restrict how your personal data is used; and
(g) the right to be forgotten, which allows you to have your personal data erased in certain circumstances (though this is not an absolute right and may not apply if we need to continue using it for a lawful reason).
If you would like further information about any of your rights or wish to exercise them, please contact us using the details given in section 1 above.
Please keep in mind that there are exceptions to the rights above and, though we will always try to respond to your satisfaction, there may be situations where we are unable to do so (for example, because the information no longer exists or there is an exception which applies to your request).
If you are not happy with our response, or you believe that your data protection or privacy rights have been infringed, you should contact the UK Information Commissioner’s Office, which oversees data protection compliance in the UK. Details of how to do this can be found at www.ico.org.uk.
We may update this Policy at any time. When we do, we will post a notification on the main page of our Website and we will also revise the updated date at the bottom of this page. We encourage users to frequently check this page for any changes to stay informed about how we are helping to protect the personal data we hold.
This policy was last updated on 9 September 2018