[Last updated 15 July 2020]
Contacting Us about Your Privacy
Please let us know if you have any requests, feedback or concerns regarding the way we manage your personal data. Use the contact details listed in the below schedule. We will usually respond to you within 30 days and take action, within reason, as quickly as possible.
If you are not happy with how we manage your concerns, you can contact your local data protection supervisory office. For example, in the EU this would be https://edps.europa.eu/, in the UK this would be https://ico.org.uk/. There is no federal regulator in the United States.
Solicom Communications SL [insert appropriate company or tax identifier number]
Real 9, Office 12, 28991 Torrejon de la Calzada, Madrid, Spain
+43 608 123 518
Our contact details
If you have questions, require more information, have a complaint to register or details to amend, correct or delete in relation to your personal information, please contact our privacy compliance officer via email at:
Name: Mr Gert Mellak
Email: insert privacy contact email email@example.com
When we talk about ‘us’, we mean our company detailed above, including our officers and employees. When we talk about ‘you’, we mean you as a user of our website or purchaser of our services. Our contact details are above.
‘Personal data’ or ‘personal information’ is information that directly identifies you, such as your name and email address, or data that could be used, on its own or in combination with other data, to identify you. Sensitive personal data is information about you that requires additional protection and includes health information, criminal history, ethnicity and religious beliefs or sexual preferences. We do not intentionally collect sensitive personal information about you and request you do not unintentionally share it with us.
We aim for compliance with the General Data Protection Regulations (GDPR).
Under the GDPR, we are a data controller when it comes to your personal information.
You can browse our website anonymously, although cookies may be used. You will not be able to access our services anonymously. Once you access our services, including for example by joining our mailing list, opening an account on our website or purchasing our services, we will begin collecting your personal information in accordance with this policy.
Collection and Use of Data
We collect personal data about you when you give it to us for an agreed purpose. This generally occurs when you purchase a service, ‘Like’ or follow our social media pages, request information from us, or subscribe to our mailing list. We collect your personal data in this manner for our business purposes and to complete the services you have requested from us.
We may use your personal information to contact you about your purchase, answer enquiries, to keep you up-to-date with our activities, or to send you our newsletters (if you have consented to receiving our newsletters). We use your personal data in this manner for our legitimate business purposes or with your consent.
We collect and process the minimum amount of information required to deliver our services to you. We process this information to fulfill your request. This information includes:
- your first and last name
- your company name and VAT details
- your phone number (only if supplied by you)
- your email address
- payment details
- any other information you supply to us
When you purchase through our website, we will also store your IP address. We process this information for our legitimate business purpose of matching your IP address with your user information. Unless stated otherwise in this policy, personal information will be held for our business purposes for a period of up to [insert period] years. After that time, we may still retain your personal information however if we do so, it will be in a form where personal details are de-identified. This means once the data is made anonymous and you will not be able to be identified.
With your permission, we may use your email address to send you emails about our activities. These emails may contain links to other information. We process this information based on your consent. You may always withdraw your consent and unsubscribe from these emails by clicking on the unsubscribe link at the bottom of the email or by contacting us using the information set out above.
If you interact with us on social media sites (eg. Facebook, Instagram, Twitter, LinkedIn, YouTube), we may receive information about you. We may process this data as a legitimate business interest to properly administer our business and website and our communications with users. You should be aware that personal information you disclose on social media sites, forums or discussion panels, is publicly available and when you make information available on public areas, we can no longer keep the information private. Please do not share your personal information within these areas.
We may process the following categories of personal data about you:
Communication Data that includes any communication that you send to us whether that be through the contact form on our website, through email, text, social media messaging, social media posting or any other communication that you send us. We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defence of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.
Customer Data that includes data relating to any purchases of goods and/or services such as your name, title, billing address, delivery address email address, phone number, contact details, purchase details and your card details. We process this data to supply the goods and/or services you have purchased and to keep records of such transactions. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract.
User Data that includes data about how you use our website and any online services together with any data that you post for publication on our website or through other online services. We process this data to operate our website and ensure relevant content is provided to you, to ensure the security of our website, to maintain back- ups of our website and/or databases and to enable publication and administration of our website, other online services and business. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business.
Technical Data that includes data about your use of our website and online services such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is from our analytics tracking system. We process this data to analyse your use of our website and other online services, to administer and protect our business and website, to deliver relevant website content and advertisements to you and to understand the effectiveness of our advertising. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business and to grow our business and to decide our marketing strategy.
Marketing Data that includes data about your preferences in receiving marketing from us and our third parties and your communication preferences. We process this data to enable you to partake in our promotions, such as competitions, to deliver relevant website content and advertisements to you and measure or understand the effectiveness of this advertising. Our lawful ground for this processing is our legitimate interests which in this case are to study how customers use our products/services, to develop them, to grow our business and to decide our marketing strategy.
We may use Customer Data, User Data, Technical Data and Marketing Data to deliver relevant website content and advertisements to you (including Facebook adverts or other display advertisements) and to measure or understand the effectiveness of the advertising we serve you. Our lawful ground for this processing is legitimate interests which is to grow our business. We may also use such data to send other marketing communications to you. Our lawful ground for this processing is either consent or legitimate interests (namely to grow our business).
We may also receive information through third party sites like HubSpot or HelpScout.
We accept payments using PayPal or Stripe via our online ecommerce platform ThriveCart which allows us to sell our services to you. We do not take custody of or store your card details, although our payment processors may store that information on our behalf.
ThriveCart – https://thrivecart.com/legal/privacy.html
We will share your personal data with our payment service providers only to the extent necessary to process your payments or deal with refunds, disputes or complaints in relation to your payments.
California Do Not Track Disclosure
Our website does not support or respond to Do Not Track (DNT) or similar signals or mechanisms. Some third-party sites we use keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting or encounter such sites, and they recognise DNT signals, your browser will likely allow you to set the DNT signal so that third parties (particularly advertisers) know you do not want to be tracked. For example, Chrome provides these instructions https://support.google.com/chrome/answer/2790761?co=GENIE.Platform%3DAndroid&hl=en
Embedded content from other websites
Testimonials and Podcasts
If you provide us with a testimonial, you give us your consent to use the following content on our website, or in marketing material:
- your name (supplied by you),
- your email address (supplied by you)
- your personal image, and
- your testimonial.
If you participate in a podcast with us, you give us your consent to use the following content on our website, or in marketing material:
- your name (supplied by you),
- your email address (supplied by you)
- your personal image, and
- the podcast footage and/or soundtrack
You also give us permission to store testimonial and podcast information in our secure records together with your email address and the date which you provided the testimonial or podcast. We will retain and use this information for its intended purpose for a period of up to [insert number] years. We process this information based on your consent, which you may withdraw. If you withdraw your consent, we will remove use of testimonials and/or pod casts that are within in our control.
We also may share your personal information when required to do so by law or with our professional advisers to obtain advice, for instance if there is a breach of the terms and conditions, or to meet our accounting or compliance obligations. We use your personal date in this manner as a requirement for the legitimate functioning of our business.
Storage, Communications and Security of Data
We use a variety of third party providers to host and manage our website and to communicate with our customers.
Your personal information is stored through their data storage, databases and their general platforms. They store your data on secure servers behind firewalls and their data privacy policies can be found via the links next to their names.
Active Campaign – https://www.activecampaign.com/au/legal/privacy-policy
Slack – https://slack.com/intl/en-au/privacy-policy
Monday.com – https://monday.com/terms/privacy
HubSpot – https://legal.hubspot.com/privacy-policy
HelpScout – https://www.helpscout.com/company/legal/privacy/
Google Suite – https://policies.google.com/privacy
CROSS-BOARDER TRANSFER: Depending on your location, your personal information may cross Country boarders and may be stored in a jurisdiction with different privacy laws to where you live. By agreeing to this policy, you agree to such a transfer.
Where we transfer your data to third parties outside of the EEA, we will ensure that certain safeguards are in place to ensure a similar degree of security for your personal data.
- We may transfer your personal data to countries that the European Commission have approved as providing an adequate level of protection for personal data by; or
- If we use US-based providers that are part of EU-US Privacy Shield, we may transfer data to them, as they have equivalent safeguards in place; or
- Where we use certain service providers who are established outside of the EEA, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe.
- If none of the above safeguards is available, we may request your consent to the specific transfer. You will have the right to withdraw this consent at any time.
We are committed to ensuring your information is secure. To prevent unauthorised access or disclosure, we use third party hosting and storage providers with industry standard security. We also have SSL certifications for our website with regular backups of the WordPress site and plug-ins to avoid misuse, interference loss or unauthorised access, modification or disclosure of your personal information.
DISCLAIMER: While we do our best to ensure the security of your data, no storage is 100% secure and we cannot guarantee the security of our website, our records, your data or your content. If you feel this is not sufficient, please do not provide us with your personal information, or, if you have already provided personal information, please contact us and we will securely destroy it.
If the security on our website is breached, we aim to contact you within 24 hours of becoming aware of the breach and will prompt you to change your login details (this only applies to users who have registered an on-line account with us and have up to date contact details).
Collection of Data of Minors
Our website is not intended to be used by minors nor do we do not intend to collect the personal data of persons under the age of 13. If you are the guardian of a minor and suspect they may have provided us with their personal information, please contact us and request to have the minor’s personal information destroyed (use the contact information in the schedule above).
You have the right to ensure:
- We process your data fairly and lawfully and within the purpose and/or consent it was provided to us.
- Your data is accurate.
- The data collected by us is not excessive.
To ensure this happens, you can –
- have your data updated and amended if incorrect, out of date or incomplete.
- restrict the level of processing or automated processing we do.
- know how long we keep your data.
- ask us to erase your data and be forgotten.
- ask us to provide details of the personal data we hold.
To achieve this, at your request, and upon production of satisfactory identification, we will tell you what personal data about you is being processed (eg. what information we have stored), on what basis, and by whom.
You may amend inaccurate, incomplete or outdated personal data at any time by applying directly to us using the contact information in the schedule below.
If you decide your data should not be processed for one or more purposes, you may withdraw your consent from using your data in that way. Please note that we will action your request as soon as practically possible however such a request will not take effect immediately and your data may still be used in the meantime.
You may request that all personal data we have collected about you be deleted from our records and erased from information stored by any third party organisations processing data on our behalf.
If data we have collected about you is processed using automated means, you have the right to receive that data in a structured, machine-readable format and to transmit it to another data controller without hindrance.
If you make a request to be forgotten:
- your personal information may not be removed from our back-ups as we are unable to remove specific files from our backup,
- comments you have made in public areas may not be able to be removed (or may be made anonymous if possible),
- video footage may be deidentified rather than being removed (eg. your image may be blurred and identifiable information removed).
What is a cookie?
A “cookie” is a piece of information that is stored on your computer’s hard drive and which records how you move your way around a website so that, when you revisit that website, it can present tailored options based on the information stored about your last visit. Cookies can also be used to analyse traffic and for advertising and marketing purposes.
Cookies are used by nearly all websites and do not harm your system.
We aim to help you to manage cookies by providing you cookie information the first time you visit our site. This includes the types of cookies we use and why and tools to manage cookie settings on our site. You may update your cookie choices at any time.
Cookies are either first party cookies set directly by us or third party cookies set by third party service providers we use.
Cookies can be:
- Session cookies: these are only stored on your computer during your web session and are automatically deleted when you close your browser – they usually store an anonymous session ID allowing you to browse a website without having to log in to each page but they do not collect any personal data from your computer; or
- Persistent cookies: a persistent cookie is stored as a file on your computer and it remains there when you close your web browser. The cookie can be read by the website that created it when you visit that website again. We use persistent cookies for Google Analytics.
Cookies can also be categorised as follows:
- Strictly necessary cookies: These cookies are essential to enable you to use the website effectively, such as when buying a product and / or service, and therefore cannot be turned off. Without these cookies, the services available to you on our website cannot be provided. These cookies do not gather information about you that could be used for marketing or remembering where you have been on the internet.
- Performance cookies: These cookies enable us to monitor and improve the performance of our website. For example, they allow us to count visits, identify traffic sources and see which parts of the site are most popular.
- Functionality cookies: These cookies allow our website to remember choices you make and provide enhanced features. For instance, we may be able to provide you with news or updates relevant to the services you use. They may also be used to provide services you have requested such as viewing a video or commenting on a blog. The information these cookies collect is usually anonymised.
- Analytical cookies: These cookies analyse your use of our website and other websites you visit. We use analytical cookies for targeted advertising.
To find out how to opt out of tailored advertising please check the options available here – http://www.networkadvertising.org/choices/.
- We use Google Analytics, Ads and Remarketing as well as Facebook and LinkedIn ads, these third party providers are likely to use analytical, performance or targeting cookies.
- If you make a purchase on our website you may opt-in to saving your name and email address using our cookies. These are for your convenience so that you do not have to fill in your details again when you make another purchase.
- If you create an account and visit our login page, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.
- When you log in, we will also set up several cookies to save your login information and your screen display choices.