Flags Software respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
1. Important information and who we are
Purpose of this privacy notice
This privacy notice aims to give you information on how Flags Software Ltd collects and processes your personal data through your use of this website, including any data you may provide through this website.
It is important that you read this privacy notice together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements other privacy notices and is not intended to override them.
This website is not intended for children and we do not knowingly collect data relating to children.
Flags Software Ltd is the controller and responsible for your personal data (collectively referred to as “we“, “us” or “our” in this privacy notice).
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.
If you have any questions about this privacy notice or our privacy practices, please contact our data privacy manager in the following ways:
Full name of legal entity: Flags Software Ltd
Email address: email@example.com
Phone number: : +44 (0)121 746 5270
Postal address: 7 The Pavilions,
We would appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance. You 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).
Changes to the privacy notice and your duty to inform us of changes
We keep our privacy notice under regular review. This version was last updated on [15/05/2022].
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
2. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any Special Categories of Personal Data about you. We do not collect any information about criminal convictions and offences.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
Technical Data from the following parties:
(a) analytics providers such as Google and Hotjar based outside the EU.
(b) advertising networks such as Facebook, Instagram, LinkedIn, Twitter and YouTube (based inside and outside the EU).
(c) search information providers such as Google (based outside the EU).
4. How we use your personal data
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:
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
We have set out a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out below.
Purpose/Activity: To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy notice (b) responding to any enquiries for our services.
Type of data: (a) Identity (b) Contact.
Lawful basis for processing including basis of legitimate interest: (a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to respond to new enquiries about our services and to keep our records updated)
Purpose/Activity: Asking you to take a survey
Type of data: (a) Identity (b) Contact (c) Usage (d) Marketing and Communications.
Lawful basis for processing including basis of legitimate interest: (a) Necessary for our legitimate interests (to study how customers use our services, to develop them and grow our business).
Purpose/Activity: To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).
Type of data: (a) Identity (b) Contact (c) Technical.
Lawful basis for processing including basis of legitimate interest: (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation.
Purpose/Activity: To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.
Type of data: (a) Identity (b) Contact (c) Usage (d) Marketing and Communications (e) Technical.
Lawful basis for processing including basis of legitimate interest: Necessary for our legitimate interests (to study how customers use our services, to develop them, to grow our business and to inform our marketing strategy).
Purpose/Activity: To use data analytics to improve our website, products/services, marketing, customer relationships and experiences.
Type of data: (a) Technical (b) Usage.
Lawful basis for processing including basis of legitimate interest: Necessary for our legitimate interests (to define types of customers for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy).
Purpose/Activity: To make suggestions and recommendations to you about goods or services that may be of interest to you.
Type of data: (a) Identity (b) Contact (c) Technical (d) Usage (e) Marketing and Communications.
Lawful basis for processing including basis of legitimate interest: Necessary for our legitimate interests (to develop our services and grow our business).
Promotional offers from us
We may use your Identity, Contact, Technical and Usage Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us or third parties 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 at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase, service experience or other transactions.
Description: This cookie is installed by Google Analytics. The cookie is used to calculate visitor, session, campaign data and keep track of site usage for the site’s analytics report. The cookies store information anonymously and assign a randomly generated number to identify unique visitors.
Duration: 2 years
Description: This cookie is installed by Google Analytics. The cookie is used to store information on how visitors use a website and helps in creating an analytics report of how the website is doing. The data collected includes the number of visitors, the source where they have come from, and the pages visited in an anonymous form.
Duration: 1 day
Description: This cookie is installed by Google Universal Analytics to throttle the request rate to limit the collection of data on high traffic sites.
Duration: 1 minute
The cookies used by Google Analytics are used to collect information about how you use our site. We use this information to compile reports and to help us improve our site. The cookie collects information in an anonymous form, including the number of visitors to our site, where visitors have come to the site from and the pages that they visited.
You can read more about Google’s overview of privacy and safeguarding your data at https://support.google.com/analytics/answer/6004245.
We do not share the information collected by the cookies with any third parties.
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.
Different cookies may be stored for different periods of time. In many cases these cookies are updated automatically each time you visit our site or may expire and be deleted by your computer automatically. It is important to understand that when a cookie is placed on your computer it will reside on your hard drive until it expires and is deleted or it may reside on your hard drive until you manually delete it – this entirely depends on your individual browser settings and we do not have control over this.
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 at firstname.lastname@example.org.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows 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.
5. Disclosures of your personal data
We may share your personal data with the parties set out below for the purposes set out in the table above.
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 providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. International transfers
Some of our external third parties are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
Please contact us at email@example.com if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
7. Data security
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 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.
8. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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, regulatory, tax, accounting or other requirements.
In some circumstances you can ask us to delete your data: see your legal rights below for further information.
In some circumstances we will 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.
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
If you wish to exercise any of the rights set out above, please contact us at firstname.lastname@example.org
No fee usually required
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 could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other 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.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could 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.