Overview

Valknut Automation (“Valknut Automation”, ”we”, “us”, or “our”) respects individuals’ privacy, and we are committed to protecting and respecting the personal information provided to us by individuals or third parties. This Policy will inform you as to how we look after your personal data and inform you about your privacy rights and how the law protects you.

This Policy sets out the basis on which any personal data we collect from an individual, or that is provided to us by an individual or any other third party, will be processed by us.

If you have any queries regarding this policy please contact us using the contact details located at the end of this document and we will do our best to deal with your query or complaint as soon as possible. You have the right to make a complaint at any time to the relevant governing body contained in the table below. We would, however, appreciate the chance to deal with your concerns before you approach these, so please contact us in the first instance.

Citizenship	Governing Body	Website
UK	Information Commissioner’s Office (ICO)	https://ico.org.uk/concerns
EU	European Data Protection Supervisor (EDPS)	https://edps.europa.eu/data-protection/our-role-supervisor/complaints/edps-complaint-form_en
USA	Federal Trade Commission (FTC)	https://reportfraud.ftc.gov
RSA	Information Regulator (InfoReg)	https://inforegulator.org.za/

Valknut Automation is the controller and responsible for your personal data.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Personal Information We May Collect

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 individuals which we have grouped together as follows:

• Identity Data including names, usernames or similar identifier, marital status, title, date of birth and gender.
• Contact Data including address, email address and telephone numbers.
• Financial Data including bank account and payment card details.
• Transaction Data including details about payments to and from you and other details of services individuals have purchased from us.
• Technical Data including internet protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices used to access our website.
• Profile Data including usernames and password, interests, preferences, feedback and survey responses.
• Usage Data including information about usage of our website, products and services.
• Marketing and Communications Data including preferences in receiving marketing and communications from us and our third parties and communication preferences.

Failure to Provide Personal Data

Where we need to collect personal data by law, or under the terms of a contract we have with an individual and they fail to provide that data when requested, we may not be able to uphold the contract we have or are trying to enter into with said individual (for example, to provide an individual with products or services). In this case, we may have to cancel such product or service. Notification will be given in writing to the affected individual in the event of such a cancelation occurring.

How We Use Collected Data

Corporate Clients

We use this information to enable our business functions and ensure our contractual obligations to you are met. We may also process this information to better understand your needs and increase the quality of our services to you. In particular, this data may be used in the following instances:

• To market our full range of services to you
• To answer your enquiries
• To carry out any contractual obligations entered into between us and you
• Where necessary, your information may be shared with our banking or finance provider
• Where necessary, to inform regulatory or law enforcement agencies if we believe in good faith that we are required to disclose it in connection with a crime or in order to comply with any applicable law or court proceedings

Individuals/Candidates

We will only use an individual’s personal data in accordance with applicable law and when required. Most commonly, an individual’s personal data is used in the following instances:

• In the process of performing contractual negotiations or obligations entered into with the individual.
• Where it is necessary for our legitimate interests (or those of a third party) and the individual’s interests, and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

Generally, we rely on consent as a legal basis for processing your personal data in relation to sending third party direct marketing communications to you via email or text message. Individuals have the right to withdraw consent to marketing at any time by contacting us at the details set out at the end of this document.

How We Collect Personal Data

The ways in which we collect, use, store and transfer personal data will vary depending on the individual with whom we are engaging. This will include differences in how we collect the personal data whether that is through direct interactions, third party or publicly available sources or through automated technologies or interactions.

We have set out below descriptions of the categories of individuals about whom we process personal data, and the ways we plan to process the personal data.

Corporate Clients

We process Identity, Contact, Financial, Transactional, Technical, Profile, Usage, Marketing and Communications Data about clients, including personal data of the employees, customers, and any other personal data disclosed to us by the client or their representatives, or obtained by us or anyone engaged by us, in relation to the services to be provided.

If you are a Client of Valknut Automation your personal data is processed by us, in relation to the matter on which you have instructed us, in accordance with our client privacy notice.

Suppliers and Service Providers

We process the Identity, Contact, Financial, and Transaction data of specific individuals at our suppliers and services providers to enable us to receive the services that they are providing.

We may also share this personal data with clients where the supplier or service provider needs to liaise directly with a client. We also need to process this personal data in order to manage the relationship between Valknut Automation and the relevant supplier or service provider.

Contacts

This category of individuals is quite broad and will include clients, suppliers, other individuals at professional services firms such as, third party service providers, and general business contacts made by our staff including individuals that they meet at marketing and other events. This includes personal data provided to us when individuals contact us via our website.

The categories of personal data that we will collect about our contacts will include Identity, Contact, Financial, Transactional, Technical, Profile, Usage, and Communications Data.

Automated Technologies or Interactions

We process Identity and Contact data for users that sign up for accounts on our website. As individuals interact with our website, we may automatically collect Technical Data about their equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.

Third Party or Publicly Available Sources

We may receive personal data about you from various third parties and public sources as set out below:

• Technical Data from the following parties.
• Analytics providers such as Google based outside the EU.
• Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
• Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.

Where We Store and Process Personal Data

The data that we collect from individuals may be transferred to, and stored at, a destination inside or outside the European Economic Area (EEA). It may also be processed by staff operating inside or outside the EEA who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfilment of your instructions, the processing of your payment details and the provision of support services.

Whenever we transfer 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:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.

Data Security

We have put in place appropriate security measures to prevent personal data from being accidentally lost, used, or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process personal data at our instruction. They are subject to confidentiality and the terms and conditions outlined in Valknut Automation’s Information Security Policy.

We have put in place procedures to deal with any suspected personal data breach and will notify individuals and any applicable regulator of a breach where we are legally required to do so.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect personal data, we cannot guarantee the security of any data transmitted to Our Website; any transmission is at the individual’s own risk. Once we have received an individual’s information, we will use procedures and security features to try to prevent unauthorised access.

Disclosure of Information

We may have to share personal data with the parties set out below for the purposes set out in this Policy.

• Service providers acting as processors based inside and outside the EU who provide IT and system administration services.
• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors, external advisors, and insurers who provide consultancy, banking, legal, insurance and accounting services.
• Revenue & Customs regulators or any other authorities acting as processors or joint controllers who require reporting of processing activities in certain circumstances.
• Third parties with whom we organise events.

We require all third parties to respect the security of personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use personal data for their own purposes and only permit them to process personal data for specified purposes and in accordance with our instructions.

Your Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These rights include:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us.

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 may 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 may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, you will be notified and kept up to date.

Data Retention

We will retain your personal information with us for 90 days to 2 years after users terminate their accounts or for as long as we need it to fulfill the purposes for which it was collected as detailed in this Privacy Policy. We may need to retain certain information for longer periods such as record-keeping / reporting in accordance with applicable law or for other legitimate reasons like enforcement of legal rights, fraud prevention, etc. Residual anonymous information and aggregate information, neither of which identifies you (directly or indirectly), may be stored indefinitely.

Changes to this Policy

We may update this Policy at any time without notice.

Contact

Questions, comments, and requests regarding this Policy are welcomed and should be addressed to enquiries@valknutgroup.com