Privacy policy

Last updated 1^stJune 2018

COPRONET PRIVACY POLICY

1. INTRODUCTION

At Copronet (referred to as “we”, “us”, “our”) we take privacy seriously and we are committed to protecting it.

This policy explains when and why we collect personal information about individuals, how this information is used, with whom we share that information and the rights they have over it.

This policy may change from time to time so please check this page occasionally to ensure that you are happy with any changes.

This policy was last updated on the date set out at the start of this page. Please see further the section Changes to this policy below.

2. WHO WE ARE

We (The Tender Space Limited) are the controller in relation to the processing activities described below. A ‘controller’ is an organisation that decides why and how your personal information is processed and is responsible for such processing.

If you provide any personal information to our site located at www.copronet.com or we collect personal information when you interact with it, we will be the controller of that personal information.

We are registered in England and Wales with company registration number 09418213. Our registered office is at 22 Barn Rise, Wembley, Middlesex, HA9 9NQ.

3. HOW WE COLLECT YOUR PERSONAL INFORMATION

We collect personal information from you in the following ways:

Personal information you give to us:

This is information about you that you give to us when:

submitting information via our site;
downloading and using our mobile application;
If you use Facebook (or any other social media) log in to Copronet (or later connect your accounts for example uploading your profile photo), you authorise Facebook (or the social media used to log in) to share your personal information with us, including your name and email address;
You may choose to import your address book contacts or enter your contacts’ information manually to access certain features of the Copronet Platform, like inviting them to use Copronet.
following us and posting on our social media pages including our Facebook, Twitter, Instagramand LinkedInpages; and
corresponding with us by phone, email or in another way.

This information is provided by you entirely voluntarily.

This includes information provided at the time of registering to use our site, subscribing to services or requesting further services and generally using our site, for example by filling in forms, uploading profile information and other content to the site, interacting with other users, managing your account online and engaging in correspondence with us by phone, email or otherwise. We may also ask you for information when you report a problem with our site. If at our request you complete any surveys for research purposes, we will collect your personal information in such circumstances as well.

The information you give to us may include your name, address, account password, email address and phone number, enquiry details and other business and contact information. If you register for access to a premium Service via the site, we will also process your payment details and billing information in order to process payment for your subscription. We may also keep records of any correspondence and responses to any surveys.

If you opt to import your address book, we receive your contacts (including contact information your service provider(s) or app automatically added to your address book when you communicated with addresses or numbers not already in your list). Synced contacts are not automatically invited to connect with you on Copronet.

If we do not receive this information, you may be unable to use or interact with certain parts of our site, communicate with us effectively or allow us to comply with our own obligations to you.

Personal information we collect about you:

We may automatically collect the following information:

details of your visits to our site, including, but not limited to, transaction data, traffic data, location data, weblogs and other communication data, and the resources you access. We may also automatically collect technical information, including anonymous data collected by the hosting server for statistical purposes, the Internet protocol (IP) address used to connect your computer or device to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform. Please see Cookies for further information. We may also view any personal information which you allow to be shared, such as the information you upload to the site (such as your Copronet profile), and information you share on third party social networks.

Personal information we may receive from other sources:

We may obtain certain personal information about you from other sources (including those outside of our business) which may include our suppliers and our clients. The third parties that may send us personal information about you are as follows:

Source of personal information	The circumstances in which we may obtain personal information (as about you from this source
Other users of the site	Users of the site may share information about you with us, for example if you misuse the site or breach the Content Policy. Our Content Policy requires all users registering with the site to ensure that they have permission to use personal information relating to another user before submitting or disclosing it via the site.
Companies House (publicly available source)	We may verify customer and company information against UK company registration information (including director and shareholder details) available from Companies House and Creditsafe.
Creditsafe Social media networks (publicly available source)	We may view your social media profile registration data where you choose to register with our site using your existing social media profile and log-in details

4. CATEGORIES OF PERSONAL INFORMATION WE PROCESS ABOUT YOU

We process different types of personal information about you. To make it easier to understand the information that we use about you, we have categorised this information in the table below and provided a short explanation of the type of information each category covers.

Category	Personal information included in this category
Behavioural	your activities, actions and behaviours
Biographical	your life experiences
Contact	information which can be used to address, send or otherwise communicate a message to you
Banking/Billing and cardholder data (where applicable)	information used to send/receive funds to/from you or that appears on your bills, and your payment card details (note this may not include personal information if make payment on behalf of the organisation you represent using a corporate card)
Fraud	information relating to the occurrence, investigation or prevention of fraud
Legal	information relating to legal claims made by you or against you or the claims process
Sales	information relating to your subscription(s)
Marketing preferences	Your preferences in respect of any marketing communications form us from time to time in relation to products or services which we believe may be of interest to you
Correspondence	information contained in our correspondence or other communications with you about our products, services or business

5. HOW WE USE YOUR PERSONAL INFORMATION

The purposes for which we use your personal information and the legal basis under data protection laws on which we rely to do this are explained below.

Where you have provided CONSENT

We may use and process your personal information where you have consented for us to do so, as follows:

to contact you with marketing communications about our products and services:
where you have indicated at the time you register an account with us that you would like us to do so by ticking the relevant box (telephone, post and/or email); or
when you reconfirm your marketing preferences after we invite you to do so from time to time;
to share your personal information with specified third parties where you have indicated at the time you register an account with us that you would like us to do so by ticking the relevant box (telephone, post and/or email).

You may withdraw your consent for us to use your information in any of these ways at any time. Please see Withdrawing your consent for further details.

Where there is a LEGITIMATE INTEREST

We may use and process your personal information where it is necessary for us to pursue our legitimate interests as a business, or that of a third party, for the following purposes:

Processing necessary for us to promote our products and services and our business

to contact you with marketing communications about our products and services (by telephone post and/or email) where you made a purchase with us and did not opt-out using the tool we provided to you at that time;
to create a profile of you and analyse this to obtain insight about market or industry trends, client behaviours which inform our marketing strategy, and to enhance and personalise your customer experience as a visitor (including ensuring that content from our site is presented in the most effective manner for you and your device);
to tailor or personalise the marketing communications you receive to make them relevant to you or the organisation for whom you work;

Processing necessary for us to support our clients and prospects with sales and other enquiries

to correspond and communicate with you when supporting you in connection with our products or services or your queries in relation to them;

Processing necessary for us to respond to changing market conditions and our clients’ needs

for market research in order to improve our services;
to notify you about changes to the service and our business;

Processing necessary for us to operate the administrative and technical aspects of our business efficiently and effectively

to provide the online tools and subscription services to you and fulfil requests and other actions you make using those tools and services;
to administer the site and our social media pages and for our internal operations, including troubleshooting, quality control, testing and statistical reporting purposes;
to enable us to take payment for your subscription to the service (where applicable) and carry out our obligations arising from any contracts entered into with you;
to notify you about changes to the service;
to enable us to make payments to contractors and freelancers who provide products and services to us;
for the prevention of fraud and other criminal activities;
to verify the accuracy of information that we hold about you and create a better understanding of you as a visitor to our site;
for network and information security purposes in order for us to take steps to protect your information against loss or damage, theft or unauthorised access;
to comply with a request from you in connection with the exercise of your rights (for example where you have asked us not to contact you for marketing purposes, we will keep a record of this on our suppression lists in order to be able to comply with your request);
for the purposes of a corporate restructure or reorganisation or sale of our business or assets;
for efficiency, accuracy or other improvements of our databases and systems e.g. by combining systems or consolidating records we hold about you;
to enforce or protect our contractual or other legal rights or to bring or defend legal proceedings; and
for general administration, including managing your queries, complaints, or claims, to send service messages and to provide you with important information about our business.

Where there is a LEGAL REQUIREMENT

We will use your personal information to comply with our legal obligations:

to assist any public authority or criminal investigatory body, where we are under a legal obligation to do so;
to identify you when you contact us;
to verify the accuracy of data we hold about you; and
to respond to and resolve your complaints in relation to the service.

6. DATA ANONYMISATION AND USE OF AGGREGATED INFORMATION

Your information may be converted into statistical or aggregated data in such a way as to ensure that you are not identified or identifiable from it. Aggregated data cannot be linked back to you as a natural person. We may use this data for analytical and research purposes.

For more information on how we use cookies and how to switch them off on your device, please visit our Cookies Policy.

7. OTHERS WHO MAY RECEIVE OR HAVE ACCESS TO YOUR PERSONAL INFORMATION

Other Copronet users

Users of the site may view information you post to the site, including:

your profile name, profile image and any personal information you include within your company profile;
any personal information you include in the documents you upload to the site or in your online discussions in relation to a project;
location information in relation to a project (where such information relates to your location);
any personal information you include in the messages you send via the site;
any information included in your company profile regarding criminal or civil court action (including bankruptcy or insolvency proceedings) where that information relates to you; and
any information relating to you contained in any articles, posts, comments and reviews posted to the site.

Some of this information will be visible to any member that searches the applicable area of the Site and we have provided notices on the site so that you can identify which of the information you submit will be accessible by all members.

Other users may share the above information about you with us or with other users of the site. Our Content Policy requires all users registering with the site to ensure that they have permission to use personal information relating to another user before submitting or disclosing it via the site.

You should avoid excessive sharing of your personal information (including your contact details) with other site users. If you intend to share any personal information, please exercise the same level of caution as you would if dealing with the user in person. Never give any personal information to anyone until you are confident that it is safe to do so. You should in any event only reveal such personal information via secure communications that cannot be viewed by people other than the intended recipients.

Our suppliers and service providers

We may disclose your information to our third party service providers, agents, subcontractors and other organisations (as listed below) for the purposes of providing services to us or directly to you on our behalf.

Recipient / relationship to us	Industry sector (& sub-sector)
Accountancy services and software providers (e.g. Kashflow)	Professional services (accountancy)
Outsourced customer support providers	Professional services (customer services)
Advertising agencies	Media (advertising)
Banks, credit check agencies, payment processors, subscription managers and financial services providers (e.g. Stripe, Creditsafe, GoCardless)	Financial (banking)
Cloud service providers including storage and live chat	IT (cloud services)
Data destruction and archiving service providers	IT (data lifecycle management)
Financial auditing services	Audit (financial)
Government tax administration offices	Government (tax)
Insurance services providers	Insurance (brokers/underwriting)
IT support service providers (e.g. Ex-Networks, Amazon Web Services, Yammayap)	IT (support, hosting and maintenance)
Legal advisers	Professional services (legal services)
Market research and analytics service providers (e.g. Google Analytics)	Media (research and analytics)
Online email marketing, campaign management and customer relationship management platform services	IT (cloud services)
On-site security access control services	Security (on-site)

The recipients mentioned above are located in Europe and the USA.

When we use third party service providers, we only disclose to them any personal information that is necessary for them to provide their service and we have a contract in place that requires them to keep your information secure and not to use it other than in accordance with our specific instructions.

When we share your personal information to third parties that are controllers of that information, they may disclose or transfer it to other organisations in accordance with their data protection policies. This does not affect any of your data subject rights as detailed below. In particular, where you ask us to rectify, erase or restrict the processing of your information, we take reasonable steps to pass this request on to any such third parties with whom we have shared your personal information.

Other ways we may share your personal information

We may transfer your personal information to a third party as part of a sale of some or all of our business and assets to any third party or as part of any business restructuring or reorganisation. We may also transfer your personal information if we’re under a duty to disclose or share it in order to comply with any legal obligation, to detect or report a crime, to enforce or apply the terms of our contracts or to protect the rights, property or safety of our visitors and customers. We will always take steps with the aim of ensuring that your privacy rights continue to be protected.

8. WHERE WE STORE YOUR PERSONAL INFORMATION

All information you provide to us may be transferred to countries outside the European Economic Area (EEA). By way of example, this may happen if any of our servers or those of our third party service providers are from time to time located in a country outside of the EEA. These countries may not have similar data protection laws to the UK and so may not protect the use of your personal information to the same standard. Please see Others who may receive or have access to your personal informationfor details regarding the locations to which your personal information is transferred.

If we transfer your information outside of the EEA in this way, we will take steps to ensure that appropriate security measures are taken with the aim of ensuring that your privacy rights continue to be protected as outlined in this policy. These steps include:

ensuring the non-EEA countries to which transfers are made have been deemed adequately protective of your personal information for the purposes of data protection law by the relevant bodies;
imposing contractual obligations on the recipient of your personal information using provisions formally issued by relevant bodies for this purpose; or
ensuring that the recipients are subscribed to ‘international frameworks’ that aim to ensure adequate protection.

Please contact us using the details at the end of this policy for more information about the protections that we put in place and to obtain a copy of the relevant documents.

If you use our services whilst you are outside the EEA, your information may be transferred outside the EEA in order to provide you with those services.

9. HOW LONG WE KEEP YOUR PERSONAL INFORMATION FOR

We do not retain personal information in an identifiable format for longer than is necessary.

If we collect your personal information, the length of time we retain it is determined by a number of factors including the purpose for which we use that information and our obligations under other laws. We determine the period of retention of your personal information based on the following criteria:

Retention in case of your future use of the service. Unless you request otherwise, we will store your personal information on the site or as long as your account on the site is open, so that we can continue to make the service available to you and you can continue to enjoy the benefit of the service in the future, up until the point at which you decide to close your account.

Once you have informed us of your decision to close your account, we will (unless otherwise requested) generally delete your personal information within thirty days, except in the circumstances below.

Retention in case of queries and complaints. We will retain your personal information for as long as is reasonably required to resolve your complaint or query.
Retention in case of direct marketing lists.We will store your personal information for the period during which your consent to receive email marketing messages has expired and you have not re-consented, when we will keep your email address on our suppression list to ensure that we do not send you marketing emails;
Retention in accordance with legal and regulatory requirements.We will carefully consider whether we need to retain your personal information after the date of closure in case of a legal or regulatory requirement.
Retention in case of claims.We will retain certain of your personal information for the period in which you or a third party might bring claims against us.

The only exceptions to the above are where:

you exercise your right to require us to retain your personal information for a period longer than our stated retention period (see further Erasing your personal information or restricting its processing);
you exercise your right to have the information erased (where it applies) and we do not need to hold it in connection with any of the reasons permitted or required under the law (see further Erasing your personal information or restricting its processingbelow);
we bring or defend a legal claim or other proceedings during the period we retain your personal information, in which case we will retain your personal information until those proceedings have concluded and no further appeals are possible; or
in limited cases, existing or future law or a court or regulator requires us to keep your personal information for a longer or shorter period.

10. SECURITY AND LINKS TO OTHER SITES

We implement appropriate technical and organisational measures to keep your personal information safe and secure.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your information transmitted to our website and any transmission is at your own risk. Once we have received your personal information, we put in place reasonable and appropriate controls to ensure that it remains secure against accidental or unlawful destruction, loss, alteration, or unauthorised access.

You are responsible for keeping your account password confidential. We ask you not to share your password with anyone.

Our website may contain links to other websites run by other organisations. This policy does not apply to those other websites‚ so we encourage you to read their privacy statements. We cannot be responsible for the privacy policies and practices of other websites even if you access them using links that we provide. In addition, if you linked to our website from a third party website, we cannot be responsible for the privacy policies and practices of the owners and operators of that third party website and recommend that you check the policy of that third party website.

11. COOKIES

Like many other websites, our website uses cookies (including Google Analytics) cookies to obtain an overall view of visitor habits and visitor volumes to our website). ‘Cookies’ are small pieces of information sent to your computer or device and stored on its hard drive to allow our websites to recognise you when you visit.

It is possible to switch off cookies by setting your browser preferences. For more information on how we use cookies and how to switch them off on your device, please visit our Cookies Policy.

12. AUTOMATED DECISION MAKING

Our site may use your personal information such as your role or skills to put you in touch with other members based on their search requirements, however, we do not envisage that any decisions that have a legal or significant effect on you will be taken about you using purely automated means, however we will update this policy and inform you if this position changes.

13. YOUR RIGHTS

You have a number of rights in relation to your personal information under data protection law. In relation to certain rights, we may ask you for information to confirm your identity and, where applicable, to help us to search for your personal information. Except in rare cases, we will respond to you within one month from either the date that we have confirmed your identity or, where we do not need to do this because we already have this information, from the date we received your request.

Accessing your personal information

You have the right to ask for a copy of the information that we hold about you by emailing or writing to us at the address at the end of this policy. We may not provide you with a copy of your personal information if this concerns other individuals or we have another lawful reason to withhold that information.

Correcting and updating your personal information

The accuracy of your information is important to us and we are working on ways to make it easier for you to review and correct the information that we hold about you.

In the meantime, if you change your name or address/email address, or you discover that any of the other information we hold is inaccurate or out of date, please let us know by contacting us in any of the details described at the end of this policy.

Withdrawing your consent

Where we rely on your consent as the legal basis for processing your personal information, as set out under How we use your personal information, you may withdraw your consent at any time by contacting us using the details at the end of this policy. If you would like to withdraw your consent to receiving any direct marketing to which you previously opted-in, you can do so using our unsubscribe tools. If you withdraw your consent, our use of your personal information before you withdraw is still lawful.

Objecting to our use of your personal information

Where we rely on your legitimate business interestsas the legal basis for processing your personal information for any purpose(s), as out under How we use your personal information,you may object to us using your personal information for these purposes by emailing or writing to us at the address at the end of this policy. Except for the purposes for which we are sure we can continue to process your personal information, we will temporarily stop processing your personal information in line with your objection until we have investigated the matter. If we agree that your objection is justified in accordance with your rights under data protection laws, we will permanently stop using your data for those purposes. Otherwise we will provide you with our justification as to why we need to continue using your data.

You may object to us using your personal information for direct marketing purposes and we will automatically comply with your request. If you would like to do so, please use our unsubscribe tool.

Erasing your personal information or restricting its processing

In certain circumstances, you may ask for your personal information to be removed from our systems by emailing or writing to us at the address at the end of this policy. Unless there is a reason that the law allows us to use your personal information for longer, we will make reasonable efforts to comply with your request.

You may also ask us to restrict processing your personal information where you believe it is unlawful for us to continue processing, you have objected to its use and our investigation is pending or you require us to keep it in connection with legal proceedings. In these situations we may only process your personal information whilst its processing is restricted if we have your consent or are legally permitted to do so, for example for storage purposes, to protect the rights of another individual or company or in connection with legal proceedings.

Transferring your personal information in a structured data file (“data portability”)

Where we rely on your consent as the legal basis for processing your personal information or need to process it in connection with your contract, as set out under How we use your personal information, you may ask us to provide you with a copy of that information in a structured data file. We will provide this to you electronically in a structured, commonly used and machine readable form, such as a CSV file.

You can ask us to send your personal information directly to another service provider, and we will do so if this is technically possible. We may not provide you with a copy of your personal information if this concerns other individuals or we have another lawful reason to withhold that information.

Complaining to a data protection regulator

You have the right to lodge a complaint with a data protection regulator in Europe, in particular in a country you work or live or where your legal rights have been infringed. The contact details for the Information Commissioner’s Office (ICO), the data protection regulator in the UK, are available on the ICO website, for you to use where your personal information has or is being used in a way that you believe does not comply with data protection law. However, we encourage you to contact us before making any complaint and we will seek to resolve any issues or concerns you may have.

14. CHANGES TO THIS POLICY

We may review this policy from time to time and any changes will be notified to you by posting an updated version on our website and/or by contacting you by email. Any changes will take effect 7 days after the date of our email or the date on which we post the modified terms on our website, whichever is the earlier. We recommend you regularly check for changes and review this policy whenever you visit our website. If you do not agree with any aspect of the updated policy you must immediately notify us and cease using our services.

15. CONTACT US

Please direct any queries about this policy or about the way we process your personal information to us using the details below.

If you wish to write to us, please write to Copronet, Strata House, 12-14 Castle Street, Poole, BH15 1BQ, UK or contact us using the details below..

Our email address for data protection queries is: info@copronet.com.

If you would prefer to speak to us by phone, please call +44 (0)330 122 0014.