This policy was last updated on the 18th March 2022
Skywheels – who are we?
Skywheels is a limited company registered in England under company number 13161231 and whose registered address is Unit D4, 7 Tudor Road, Altrincham, Cheshire WA14 5RZ.
In this policy ‘Skywheels’, ‘we’, and ‘us’ means Skywheels Ltd.
Skywheels is the controller for the personal data.
- how we use your personal data;
- types of personal data we collect;
- legal grounds for processing your personal data;
- sharing your personal data;
- retention of personal data;
- our policy on correcting and updating personal data;
- making a complaint about our handling of your personal data.
How we use your information?
Under the Data Protection Legislation, we must always have a lawful basis for using personal data.
We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details below.
If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.
In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.
If you have requested information from Skywheels, we will collect and process the personal data that you provide in order to respond to your request. Unless you consent to the contrary, we shall only use your personal data to provide the information you have requested.
We may collect some or all of the following personal data (this may vary according to your relationship with us):
- Email address
- Telephone number
- Business name
- Job title
We will process your personal information where there is a legitimate interest in us doing so, if it is reasonably necessary to achieve our or others’ legitimate interests (as long as that processing is fair, balanced and does not unduly impact your rights). For example, if you are requesting information about a company or a service from Skywheels then we may pass your personal data onto another member of the group to enable them to appropriately respond to your request. Again, unless you consent to the contrary, that member shall only use your personal data to provide the information you have requested.
Our Workplace Privacy Notice explains how and why we use your personal data, including how long we keep it and who we share it with. You will be given the Workplace Privacy Notice if you are offered employment by us.
We obtain information directly from you, via normal business channels such as email, telephone, video conferencing etc. and in person, for example at conferences and events. Personal data is required to allow Skywheels to provide our services to our clients.
We will not share your personal information with any third parties save with your permission or required or allowed by law, for example, to obtain legal advice.
If you have contacted us, then we shall rely on our legitimate interests to record your information.
If we wish to record any sensitive information about you, for example, about your dietary requirements, then we will have to have a legal reason to do so or ask for your explicit consent. If we are in negotiation with you for goods or services then we shall rely upon contractual obligations to process the information, as we will either have a contract in place, or be in negotiations to enter into one.
If you are a business contact, we will ask you if you would like to receive regular communications from us, and we shall do this in accordance with any guidelines concerning the data protection or ePrivacy (electronic marketing) regulations. You can change your preferences at any time, and if you ask us to stop communicating with you, we shall action this request immediately.
Skywheels needs to manage the business for example, processing invoices, entering into contracts and to do that we rely on our legitimate interests, legal obligations and fulfilment of our contractual obligations.
We may use your personal information to obtain legal advice or if it is necessary to defend a legal claim or pursue a bad debt, and we may have to pass your information to public authorities and organisations where the law requires us to do so.
What types of personal data we collect and how?
Most of the personal data Skywheels processes is provided directly by you, or by one of our employees.
The nature of the personal data collected about you will depend on your relationship with Skywheels and the type of work we conduct, but may include the following:
- Your contact details, such as title, name, email address, mobile/telephone number, and company information such as job title/role, office location, mobile/telephone number;
- Records of communications with you and other parties e.g., telephone calls, on-line meetings, emails, chat, or text messages;
- Information supplied by you, your colleagues, our client or third parties, such as academic, career history, professional specialism information;
- Relevant activities associated with the work we undertake, on social media and other publicly available digital channels, used as part of services and business activities we undertake for or that which is necessary as part of our wider business engagement.
- System access information, such as usernames, passwords and other personally identifiable information that would allow Skywheels to access IT systems and/or operate on your behalf when nominated to do so by you.
We may with your consent, also retain the following:
- Your date of birth, age, gender
- Your nationality
- Your bank account details
- Details of nominated contact, such as next of kin
We do not collect any ‘special category’ or ‘sensitive’ personal data, personal data relating to children or data relating to criminal convictions and/or offences.
Under data protection legislation, there are various grounds on which we can rely when processing your personal data. In some contexts, more than one ground applies. Typically, we rely on Contract, Legitimate Interests and Consent. Skywheels may also be required to use your personal data to comply with its legal obligation.
A: Legitimate interests
Examples of personal data that may be processed using legitimate interests:
- Adhering to regulatory bodies guidance and compliance requirements;
- Audit requirements;
- Tracking and record-keeping of communications between you and staff.
Example of personal data that may be processed using the performance of a contract:
- The processing is necessary for the execution of a contract in which you are a party. The contract may be with you and Skywheels or you and our client.
To process your personal data, we obtain your explicit consent. This means that before we collect any information from you, we ensure that you are provided with full details about the purpose and nature of the research and what will happen to the information we collect.
Example of personal data that may be processed where you have given specific consent to the processing of your data.
- Retaining your contact details and company information for potential future projects.
If we have relied on consent as a ground for processing, you may withdraw consent at any time – though if you do so that will not affect the lawfulness of what we have done before you withdraw consent. See section Your data protection rights.
In some cases, we may need to share personal information with third parties. Any third party that receives personal information is obligated to follow all the same privacy protection regulations as followed by Skywheels.
Skywheels may share information with the following third parties:
- Clients of Skywheels;
- Suppliers and agents;
- Regulatory organisations.
We are required by law to keep your personal data only for as long as is necessary for the purposes for which we are using it. The period for which we keep your personal data will be determined by several criteria, including the purposes for which we are using the information, the amount and sensitivity of the information, the potential risk from any unauthorised use or disclosure of the information, and our legal and regulatory obligations.
We keep a backup of our data to restore the original data after a data loss event. When we delete your personal data, it will be deleted from the live storage immediately but there will be a delay before it is removed from the backup data.
If you use our website
When you visit the Skywheels website, we automatically use some cookies that are strictly necessary to provide our services to you and allow the website to operate; for all other cookies we need your consent. This is why when you first logged onto our website you were asked for your permission to append these non-essential cookies such as Google Analytics/Click Dimensions.
Our web servers capture IP Addresses that are stored in log files by default for troubleshooting connections. We purge all web server log files every 30 days. We do not make any attempt to find out the identities of those visiting our websites. We will not associate any data gathered from these sites with any personally identifying information from any source. If we do want to collect personally identifiable information through our websites, we will ask your permission and explain what we intend to do with it.
Appropriate security measures are in place, in our physical facilities to protect against the loss, misuse or alteration of information that we have collected from our websites.
Like most websites we use ‘cookies’ to collect anonymous statistics about how people use the site, and to help us keep it relevant for the user. Cookies ‘remember’ bits of information from your visit to the site. to tell us how many people have visited each web page, how they got there, and where they navigate from there. The data collected is completely anonymous and does not store any personal details. A cookie is a simple text file that’s stored on your computer or mobile device by a website’s server. Only that server can retrieve or read the contents of that cookie. Each cookie is unique to your web browser. So, if we put a cookie on your computer, it can’t be read by any other website. If you don’t want your web visits to be tracked for statistical purposes like this, you can disable the cookies from the cookie banner that is displayed when you first log onto our website or by clicking the cookie tab. You can also set your computer to block cookies at any time. The way in which you do this depends upon the web browser which you use. Go to http://www.allaboutcookies.org/ to find out more.
- Google Maps/Places
Our website may have our Google Maps/Places profile embedded within an iframe. Google Maps creates cookies that enable the functionality of their powerful mapping software. No personal information is stored or shared on the cookies deployed by Google Maps/Places.
- Social Network Sharing
We encourage users to share our content and/or like our on profile on the popular Social Media websites Facebook, Twitter, YouTube, Google+ and LinkedIn. In order to make ‘Social Sharing’ accessible, our website utilises widgets either provided directly from the Social Networks and/or via amalgamative widgets from third parties such as AddThis. Cookies and privacy implications from the social networks vary and will be dependent on your nominated privacy settings with each Social Network. Social Sharing buttons will only deploy cookies if you are signed to that respective Social Network at the time of being on our website.
Our website, either in full or in part, is built on the popular open-source CMS framework – WordPress. WordPress utilises cookies to allow visitors to register, login and comment on our website’s content. If you do not wish to participate in commenting on our website, WordPress will not deploy any cookies onto your device. Cookies will only be created by WordPress if you actively register or comment via the clear forms on our website.
- Enquiry Forms
Visitors can choose to contact us via enquiry form(s) on our website. In order to prevent spam enquiries, we protect our forms with a ‘CAPTCHA’ challenge to ensure the submission is from a living person, rather than a computer bot. This CAPTCHA challenge creates a cookie that is used only to check the input response from the user is correct. The CAPTCHA cookie does not store any other information from your enquiry.
Who do we share your information with?
We will not share any of your personal data with any third parties for any purposes, subject to the following exceptions.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
If any of your personal data is shared with a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law.
If any personal data is transferred outside of the UK, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation.
We use selected agents to process your information on our behalf, such as software providers to host our website. Such third parties will be authorised to see and use your information but only to fulfil their contractual obligations to us and will not be permitted to use it for any other purpose. We retain full responsibility for how your personal information may be used by such agents.
We may share your personal information so that we can comply with a legal obligation to which we are subject. For example: where we are obliged to share your personal information with regulatory bodies which govern our work and services; government departments such as law enforcement and HMRC; court orders etc. We will process your personal information where there is a legitimate interest in us doing so if it is reasonably necessary to achieve our or others’ legitimate interests (as long as that processing is fair, balanced and does not unduly impact your rights). For example, if you are requesting information about a company or a service from a member of Skywheels), then we may pass your personal data onto another member of the group to enable them to appropriately respond to your request. Again, unless you consent to the contrary, that member shall only use your personal data to provide the information you have requested.
How and where do we store or transfer your personal data?
We will only store your personal data in the UK. This means that it will be fully protected under the Data Protection Legislation.
We may store some of your personal data within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the EU GDPR and/or to equivalent standards by law. Transfers of personal data to the EEA from the UK are permitted without additional safeguards.
We may store some or all of your personal data in countries outside of the UK. These are known as “third countries”. We will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation as follows:
We will only store or transfer personal data in or to countries that are deemed to provide an adequate level of protection for personal data. For further information about adequacy decisions and adequacy regulations, please refer to the Information Commissioner’s Office.
Please contact us using the details below for further information about the particular data protection safeguards used by us when transferring your personal data to a third country.
How we protect your information?
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a legitimate business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
To protect your personal data Skywheels employ:
- technical measures, including but not limited to, robust network security, firewalls, anti-virus protection, regular internal and external oversight, and inspection, including penetration testing, access controls, audit trails, encryption of devices and data both whilst at rest and during any transmission to and from third parties in order to keep your personal data secure.
- organisational measures including, but not limited to, training of all individuals who process personal data in data protection and information governance, the creation of and adherence to appropriate policies and procedures.
Your data protection rights
You have specific rights connected to provision of your personal information to Skywheels, although in some cases these rights are subject to certain conditions and limitations. To exercise any of these rights please contact us.
This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details below.
You can request a copy of the information held relating to you. This is known as a “subject access request”. All subject access requests should be made in writing and sent to the email or postal addresses shown below. Please ensure that you include your name and clear instructions on what you would like us to do.
If you require us to supply you with details of the personal information that we hold about you, then we will provide this information free of charge and we will provide this information to you within one month of your request unless the request is complex or is numerous requests. If this is the case, we will inform you within one month of your request about the reason for the extension of time.
You have the right to have your personally identifiable data deleted.
If you believe the records that Skywheels keep are inaccurate or incomplete, you have the right to ask for these to be updated.
If we have collected and processed your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
- Right to restrict
The right to restrict (i.e., prevent) the processing of your personal data. The right to object to us using your personal data for a particular purpose or purposes
- Right to object
The right to object to us using your personal data for a particular purpose or purposes.
- Right to data portability
This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
- Rights relating to automated decision-making and profiling
We do not use your personal data in this way.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided.
It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details below.
How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details:
Email address: firstname.lastname@example.org
Telephone number: 0161 928 4989.
Postal Address: Unit D4, 7 Tudor Road, Altrincham, Cheshire, WA14 5RZ.
Changes to this Privacy Notice
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.
Any changes will be made available immediately via the Company website and can also be requested at any time using the contact details above.
This Privacy Notice was last updated on 18th March 2022.