Privacy Policy

1. Introduction

This privacy notice provides you with details of how we collect and process your personal data through your use of our site www.sdxmessaging.com.

By providing us with your data, you warrant that you are over 13 years of age.

Secure Digital Exchange Limited is the data controller, and we are responsible for your personal data (referred to as “we”, “us”, or “our” in this privacy notice).

We have appointed a Data Protection Officer who is in charge of privacy-related matters for us. If you have any questions about this privacy notice, please get in touch with the Data Protection Officer using the details set out below.

Contact Details

Full name of legal entity: Secure Digital Exchange Limited.

Name or title of Data Protection Officer: Jo Thurgood

Email address: jo.thurgood@sdxmessaging.com

Postal address: Suite A, 6 Honduras Street, London, EC1Y 0TH

It is very important that the information we hold about you is accurate and up to date. Please let us know if your personal information changes at any time by emailing us at info@sdxmessaging.com.

2. WHAT DATA DO WE COLLECT ABOUT YOU, FOR WHAT PURPOSE AND ON WHAT GROUND WE PROCESS IT

Personal data means any information capable of identifying an individual. It does not include anonymised data.

We may process the following categories of personal data about you:

• Communication Data includes any communication 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 you send us. We process this data to communicate with you for record-keeping and 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 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 to enter into such a contract at your request
• User Data includes data about how you use our website and any online services and any data 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 administer our website and our business properly.
• 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 business, grow our business, and decide our marketing strategy.
• Marketing Data includes data about your preferences in receiving marketing from our third parties and us and your communication preferences. We process this data to enable you to partake in our promotions, such as competitions, prize draws and free giveaways, 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, develop them, grow our business and 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).

Sensitive Data

We do not collect any Sensitive Data about you. Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We do not collect any information about criminal convictions and offences.

Where we are required to collect personal data by law or under the terms of the contract between you and us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have ordered, but if we do, we will notify you at that time.

We will only use your personal data for a purpose it was collected for or a reasonably compatible purpose if necessary. For more information on this, please email us at info@sdxmessaging.com. If we need to use your details for an unrelated new purpose, we will let you know and explain the legal grounds for processing.

We may process your personal data without your knowledge or consent, where this is required or permitted by law.

We do not carry out automated decision-making or any automated profiling.

3. HOW WE COLLECT YOUR PERSONAL DATA

We may collect data about you by you providing the data directly to us (for example, by filling in forms on our site or by sending us emails). We may automatically collect certain data from you through cookies and similar technologies as you use our website. Please see our cookie policy for more details about this.

We may receive data from third parties such as analytics providers such as Google based outside the UK and/or the EU, advertising networks such as Facebook based outside the UK and/or the EU, such as search information providers such as Google based outside the UK and/or the EU, providers of technical, payment and delivery services, such as data brokers or aggregators.

We may also receive data from publicly available sources such as Companies House and the Electoral Register based inside the UK and/or the EU.

4. MARKETING COMMUNICATIONS

Our lawful ground for processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely, to grow our business).

Under the Privacy and Electronic Communications Regulations, we may send you marketing communications from us if (i) you made a purchase or asked for information from us about our goods or services or (ii) you agreed to receive marketing communications and in each case you have not opted out of receiving such communications since. Under these regulations, if you are a limited company, we may send you marketing emails without your consent. However, you can still opt-out of receiving marketing emails from us at any time.

Before we share your personal data with any third party for their own marketing purposes, we will get your express consent.

You can ask third parties or us to stop sending you marketing messages at any time [by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences] OR by following the opt-out links on any marketing message sent to you or] OR by emailing us at info@sdxmessaging.com at any time.

If you opt out of receiving marketing communications, this opt-out does not apply to personal data provided as a result of other transactions, such as purchases, warranty registrations etc.

5. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below:

• Service providers who provide IT and system administration services.
• Professional advisers, including lawyers, bankers, auditors and insurers.
• Government bodies that require us to report processing activities.
• Marketing agencies – Europa Communications, our marketing agency.
• Third parties to whom we sell, transfer, or merge parts of our business or our assets.

We require all third parties to whom we transfer your data to respect the security of your personal data and treat it according to the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

6. INTERNATIONAL TRANSFERS

Where you are within the United Kingdom:

We are subject to the provisions of the UK General Data Protection Regulations that protect your personal data. Where we transfer your data to third parties outside of the UK, we will ensure that certain safeguards are in place to provide a similar degree of security for your personal data. As such:

• We may transfer your personal data to countries that the relevant regulatory authorities in the United Kingdom have approved as providing an adequate level of protection for personal data by; or
• If we use US-based providers that are part of a UK regulator-approved privacy framework, we may transfer data to them, as they have equivalent safeguards in place; or
• Where we use certain service providers established outside of the UK, we may use specific contracts or codes of conduct or certification mechanisms approved by the United Kingdom regulators which give personal data the same protection it has in the UK.

If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.

Where you are within the EEA:

• We may transfer your personal data to countries that the European Commission has approved as providing an adequate level of protection for personal data by; or
• If we use US-based providers that are part of an EU-approved privacy framework, we may transfer data to them, as they have equivalent safeguards in place; or
• Where we use certain service providers established outside of the EEA, we may use specific contracts or codes of conduct or certification mechanisms approved by EU regulators which give personal data the same protection it has in the EEA.

If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.

7. DATA SECURITY

We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorisation. We also allow access to your personal data only to those employees and partners who have a business need to know such data. They will only process your personal data on our instructions and must keep it confidential.

We have procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to.

8. DATA RETENTION

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including to satisfy any legal, accounting, or reporting requirements.

When deciding what the correct time is to keep the data for, we look at its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes, and if these can be achieved by other means and legal requirements.

For tax purposes, the law requires us to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers.

In some circumstances, we may anonymise your personal data for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9. YOUR LEGAL RIGHTS

Under data protection laws, you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, object to processing, portability of data and (where the lawful ground of processing is consent) to withdraw consent.

If you are within the UK, you can see more about these rights at: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/ If you wish to exercise any of the rights set out above, please email us at info@sdxmessaging.com.

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 or refuse to comply with your request in these circumstances.

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.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you.

When deciding what the correct time is to keep the data for, we look at its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes, and if these can be achieved by other means and legal requirements.

If you are within the UK and are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would be grateful if you would contact us first if you have a complaint so we can resolve it. If you are within the EU and are not happy with any aspect of how we collect and use your data, you have the right to complain to the data protection authority of the country in which you are based. We would be grateful if you would contact us first if you have a complaint so we can resolve it.

In some circumstances, we may anonymise your personal data for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

10. THIRD-PARTY LINKS

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 your data. 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.

11. COOKIES

You can set your browser to refuse all or some browser cookies or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see here