Angel Solutions Ltd understands that your privacy is important to you and that you care about how your personal data is used.
2. INFORMATION ABOUT US
Our products are owned and operated by Angel Solutions Ltd, a limited company registered in England under company number 03866805.
- Registered office and postal address: Angel Solutions Ltd, Liverpool Science Park, 131 Mount Pleasant, Liverpool, L3 5TF
- VAT number: GB748408410
- Data Protection Officer: Hendrikje Fell
- Email Address: email@example.com
- Telephone number: 0151 705 3666
3. WHAT DOES THIS POLICY COVER?
4. WHAT IS PERSONAL DATA?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
5. WHAT DATA DO WE COLLECT?
5.1 Things that you do, this can include:
- when you've logged in
- the reports or documents you've accessed
- the pages you've visited
- your IP address, browser, device information and location
- cookie data as further explained in our Cookies policy
5.2 THINGS THAT YOU’VE CREATED OR ARE ASSOCIATED TO
- What you can create or be associated to is dependent on your permissions within the web application.
- We record what Batch Reports you’ve set up, the files you’ve imported, the school groups you’ve set up and the forum posts you’ve made. If you’re an administrator we’ll record which users you’ve created.
- For Pendulum users we also collect the records you create when you visit a school and a list of schools that you’re associated to.
- For Broadcast users we record what documents you’ve uploaded, received from schools or distributed to schools.
5.3 YOUR ACCOUNT INFORMATION. THIS CAN INCLUDE YOUR:
- email address and telephone number
- the Local Authorities, Academy Trusts and schools you are associated to.
5.4 YOUR SUPPORT REQUESTS. THIS CAN INCLUDE:
- when you contacted the help desk
- if you contacted us by phone or email
- the duration of the phone call
- the nature of the call
6. WHY DO WE NEED THIS DATA
We hold this data for a variety of reasons including:
- to enable you to login and use our applications;
- to keep a record of who has accessed confidential information held within our web applications to enable us to comply with our obligations;
- to enable us to determine the most frequently used aspects of our web application, so that we know where to invest future development;
- to enable us to track support requests so that we know how much capacity our support team has and so that we can charge the correct amount to our clients;
- to enable us to send users critical updates about the web site.
7. WHAT DO WE DO WITH IT?
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 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.
All the personal data we process is processed by our staff in England however for the purposes of IT hosting and maintenance this information is located on servers within the European Economic Area (EEA), either at the offices of Angel Solutions or at our hosting supplier Rackspace. We do not transfer your personal data outside the EEA.
No 3rd parties (including Rackspace) have access to your personal data unless the law allows them to do so. 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 any third party service providers to user 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.
8. HOW LONG DO WE KEEP THE DATA?
If you’ve been involved in making a purchase of one of our products then we are required under UK tax law to keep your basic personal data (name, address, contact details) for a minimum of 6 years after which time it will be destroyed.
Audits within our web application detailing who has accessed confidential information and when will be kept as long as we deem reasonable.
The things you’ve created in the web application and the things you’re associated to will usually be retained until your organisation terminates their contract with Angel Solutions, plus a little time for us to purge this information.
9. WHAT ELSE WOULD WE LIKE TO DO WITH YOUR DATA?
We would like to use your name and email address to inform you of our future offers and similar products. All product users have the opportunity to opt in to receive different types of communications from us using settings within the web application. This contact information is not shared with third parties and you can unsubscribe at any time via our website. An audit of your communication preferences will be retained.
10. WHAT ARE YOUR RIGHTS?
Under the GDPR, you have the following rights, which we will always work to uphold:
- the right to access the personal data we hold about you;
- the right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete;
- the right to ask to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have;
- the right to request restriction (i.e. prevent) of the processing of your personal data;
- the right to object to us using your personal data for a particular purpose or purposes;
- the 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.
There is not normally any charge for accessing your personal data (or to exercise any other rights). However, if your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a reasonable fee may be charged or we may refuse to comply with your request in such circumstances.
We may need to request specific information from you to help us to 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.
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.
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.
11. 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 (for the attention of Hendrikje Fell):
- Email Address: firstname.lastname@example.org
- Telephone number: 0151 7053667
- Postal Address: Angel Solutions Ltd, Liverpool Science Park, Liverpool, L3 5TF