SQA Consulting Ltd – Privacy Notice & Cookies Policy– 2018

Who we are:

SQA Consulting Ltd are experts in quality assurance, software testing, Microsoft development and compliance screening. SQA Consulting Ltd is based in the UK and has a team in the Republic of Ireland and New York, USA.
SQA Consulting Ltd is committed to protecting the privacy of all personal information obtained from you during your visits to our website and collected by us when engaging with you via email, or in information you give to us in documents and data we collect about you.
Our aim is to safeguard the security and privacy of all users. This policy explains our information practices and the choices you can make about the way in which SQA Consulting Ltd collects and uses your information and the limited conditions under which we may disclose it to others.

Types of data we collect:

Information you voluntarily provide to us:

When you enquire about or sign up for and use the services provided by SQA Consulting Ltd, consult with technical consultants, send us an email, post on our social media sites, send us a copy of your CV, or communicate with us in any way, you are voluntarily giving us information that we collect.
That information may include your company name, physical address, email address, IP address, phone number, credit card information, as well as details including gender, occupation, location, purchase history, and other demographic information. By giving us this information, you consent to this information being collected, used and stored by us for the purpose of fulfilling contractual and legal obligations regarding services provided by you, or received from us and for marketing and lead generation. You also consent to us storing your data in 3rd party datacentres for the purposes of storing and analysing said data.
We receive personal data about you when you use the services of our customers and partners, such as prospective employees and applicant tracking systems providing us job application data, or referrals from strategic business partners.

Information we collect automatically:

When you use SQA Consulting Ltd online services or browse one of our websites, we may collect information about your visit to our website, your usage of the services, and your web browsing. That information may include, but is not limited to, your IP address, your operating system, your browser ID, your browsing activity, and other information about how you interacted with our website.

Lead Forensics: Website analytics and lead generation data.

When someone visits www.sqa-consulting.com we use a third-party service, Lead Forensics, to collect standard internet log information and details of visitor behaviour patterns.
We use IP Address tracking technology to identify businesses visiting our site and the pages that they visit. While this technology does not identify individuals who have visited our website, it does help us analyse data about web page traffic to develop and improve our website for business visitors and to generate leads.
For further information please visit the Lead Forensics privacy policy:

Customer Relationship Management data relevant to contracts and lead generation.

SQA Consulting Ltd employs various applications for the purposes of customer relationship management (CRM), for example but not limited to, HubSpot and Trello. SQA Consulting Ltd stores data relevant to contacts and individuals that is necessary for us to do business with those individuals, such as developing contracts and statements of work, or providing information regarding relevant services and updates. This data may be derived from Lead Forensics data acquired from visits to our website.
HubSpot and Trello have several global datacentres, both inside and outside of the EU where your data may be stored. For more information please see the following links:

Email and online storage, other areas we may store your data:
SQA Consulting Ltd uses Microsoft Office 365 for business productivity services, such as email, video conferencing and data storage.
For the ongoing management of our business, SQA Consulting Ltd stores various forms of information records in Microsoft datacentres, within the UK and wider European Union, for example, but not limited to, data relating to financial transactions, contracts, marketing and sales information, communications via email and instant messaging.
For more information please visit the Microsoft privacy policies:
To maintain our business management and CRM capability, data that we may collect and store may include, but is not limited to:
• Business name, individual name and job title
• Contact information including email address, phone number(s), instant messaging and social media details.
• Demographic information such as business address(s) including post code
• Any other data relevant to maintaining legal and contractual obligations and to provide relevant marketing materials and updates.

A ‘cookie’ is a small data file that a website may send to your browser and that your browser may then store information about you, tracking information about your interaction with a website and authentication information.
SQA Consulting Ltd does not currently utilise cookies in any area of the website. Your browser will not store any cookies tracking your website visit to www.sqa-consulting.com.

How we process your data:

Where you have given us explicit consent, we will retain data in line with the purpose for which you originally consented and will always request permission to use the data for any other purpose. If for any reason the purpose for which the data was acquired becomes obsolete, we will delete your data, or request permission to retain it.

When you haven’t given us written consent, we store your data for the following reasons, or don’t store the data.
To meet potential legal obligations:
Where processing is necessary for compliance with a legal obligation to which the we are subject. We might have to share personal information about you to government and law-enforcement agencies, such as the police:
• to fulfil our obligations to HMRC, regulatory bodies and
• Law Enforcement, to help detect and stop crime, prosecute offenders and protect national security, but only when legal process has been followed.

They might ask for the following details:
• Your contact details. This includes your name, gender, address, phone number, date of birth, email address, passwords and credentials to our services, needed to confirm your identity and your communications with us.
• Your communications with us, such as calls, emails and instant messaging chats.
• Your payment and financial information.
• Details of the products and services you’ve bought and how you use them – including your call, browser (including IP address) and details of services used.
We may also share personal information about you where we must legally share it with another person. That might be when a law obliges us to share that information or because of a court order.
In limited circumstances, we may also share your information with other public authorities, such as HMRC, even if we do not have to. However, we would need to be satisfied that a request for information is lawful and proportionate (in other words, appropriate to the request). And we would need appropriate assurances about security, how the information is used and how long it is kept.

• to fulfil our contractual obligations to you, or for you to fulfil your contractual obligations to us; or
• because you have provided personal data as part of entering into a contract (e.g. asked us to provide a quote, or information regarding our services).

Legitimate Interest:
Where we believe it is reasonable for you to expect that we hold data about you, we may use your personal information if we consider it is in our legitimate business interests so that we can operate as an efficient and effective business, as long as we cannot reasonably achieve the same results without that data.
We use your information to:
• Identify, and let you know about, products and services that are relevant to you
• share within SQA Consulting for administrative purposes
• create aggregated and anonymised information for further use
• detect and prevent fraud
• secure our systems and data

Such data includes, but is not limited to:
• Data provided to us that we further process as part of a service provided by us.
• Data we share with or shared with us by 3rd parties, that is necessary for carrying out our contractual and legal obligations.
• Data provided to us as part of communications required for providing services, including marketing and sales activities.

To market to you and to identify products and services that interest you
We may use your personal information to send you direct marketing and to better identify products and services that interest you. We do that if you’re one of our customers, or if you’ve been in touch with us another way (such as emailed us for a quote, or visited our website and by doing so generated a lead for us).
This means we’ll:
Create a profile about you to better understand you as a customer and tailor the communications we send you (including our marketing messages)
• tell you about other products and services you might be interested in;
• try to identify products and services you’re interested in; and
• we use the following for marketing and to identify the products and services you’re interested in.
o Your contact details. This includes your name, gender, address, phone number, date of birth and email address.
o Information from other organisations such as aggregated demographic data, data brokers (such as Lead Forensics), our partners and publicly available sources like the electoral roll and business directories.
We may send you information (about the products and services we provide) by phone, post, email, text message.
We also use the information we have about you to personalise these messages wherever we can, as we believe it is important to make them relevant to you. We do this because we have a legitimate business interest in keeping you up to date with our products and services that are relevant to you. In each message we send, you also have the option to opt out, easily identified in the footer of the message.

Who else do we share data with?

We do not routinely share your personal information with third parties unless it is necessary for carrying out our contractual and legal obligations. We will never sell your personal data to any third parties.
If the services we are employed for at the time dictate transfer to a third party, this will be confirmed by all parties before data is transferred.
Data may be shared with third parties, with your consent, or with confirmation to you at the time of sharing.
For instance, but not limited to:
• We may share your details with a contractor we employ to work for you.
• We may forward an email to a provider, with you also in the recipients’ list.
• If the services we are employed for at the time dictate transfer to a third party, this will be confirmed by all parties before data is transferred.
SQA Consulting Ltd respects your rights.
• Data Retention
SQA Consulting will only retain your data for as long as is necessary to provide services to you. SQA Consulting may retain your data after a contract is completed, if SQA Consulting feel doing so will allow us to provide details of products and services relevant to you in the future and you have not asked us to stop processing your personal data.
SQA will make every effort to maintain accurate records and will only retain data for as long as is necessary.
SQA will retain data where it is needed to comply with legal requirements, such as for HMRC, or for legal requirements regarding contracts
• The right to be informed:

If SQA Consulting Ltd is going to store your data, we will make every effort to ensure you are adequately notified how it will be stored and used. This may be in the form of additional information in email footers, via reference to this privacy notice, or confirmed in writing via mail, email, or documents, such as contracts.

• The right of access:

If at any time you wish to know what data SQA Consulting Ltd is holding about your, how it is processed and where it is stored, please contact. privacy@sqa-consulting.com and your request will be assessed and responded to within 14 days, with a proposed timescale to provide the requested information. Please note: There is no charge for this service and we’ll reply electronically unless you ask us to send the information by post.

• The right to rectification:
If you believe that SQA Consulting Ltd is holding inaccurate information about you, please do contact us and highlight any changes necessary, so we can rectify them as soon as possible. If you know the data controller for the data in question (this may well be the person you gave the data to, or who you gave consent to), you can contact them directly, or contact privacy@sqa-consulting.com
• The right to erasure:
If SQA Consulting Ltd is holding data that you no longer wish us to process, please contact privacy@sqa-consulting.com , or contact the data controller directly for the data (if known) and state the details of the data you would like to remove and the reason for deletion.
The data controller will then make an assessment of the data and if applicable delete and confirm deletion within 30 days of the request. Please note that requests for erasure are subject to review and we may not be able to delete your data if it is required for legal or contractual reasons.
• The right to restrict processing:
If you feel that SQA Consulting Ltd is holding your personal data and processing it in a manner that is outside the scope of consent, you have the right to object and ask us to stop processing your data for that particular reason.
If you feel that this is the case, please contact privacy@sqa-consulting.com , or contact the data controller for the data directly (if known) and state the details of the data we have and for which purpose you would like us to stop processing it.
For example: If we hold your contact details and you no longer want to receive sales materials about new services, but are happy for us to retain and process your details for contractual reasons.

• The right to data portability:
While SQA Consulting Ltd does not generally use automated processing of data, we understand that you may want to use the data we hold elsewhere. If this is the case, please contact privacy@sqa-consulting.com and let us know what data we hold and why you want to transfer it. We will make every effort to provide the data in a clear and useable format at no charge.
• The right to object to SQA Consulting Ltd having, or storing your data – Your data, Your choice:
You have the right to object to SQA Consulting Ltd storing your information. At the point of passing any information to us, you can inform us that you don’t want to allow us to process your data.
SQA Consulting Ltd will make every effort to ensure that we obtain your permission at the point we capture your data for instances where may have to retain your data, however we cannot guarantee permission will be provided in every instance.
We may retain data where we feel there are:
Compelling legitimate grounds for the processing, which override the interests, rights and freedoms of the individual; or the processing is for the establishment, exercising or defence of legal claims. While this is highly unlikely if SQA Consulting Ltd becomes the controller or processor of data, that for instance shows illegal activity, SQA Consulting Ltd may retain the data to comply with legal requirements.

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