Privacy Statement, effective as of May 24, 2018
At Tutex, your trust is important to us and we value your privacy. Our Privacy Statement describes our privacy practices. Please read this statement carefully to learn how we collect, use, share and otherwise process information relating to individuals (“Personal Data”), and your rights regarding our processing of your Personal Data. Any reference to “we,” “us,” “our,” or the “Company” is a reference to Tutex.
- Processing activities covered
This Privacy Statement applies to the following processing activities:
Visiting our website which displays this Privacy Statement;
Visiting our offices;
Receiving communications from us, including emails and texts;
Registering for our events;
Completing any hard copy or online questionnaires.
- Responsible entity
Tutex is the controller of your Personal Data and responsible for the collection, processing and disclosure of your Personal Data as described in this Privacy Statement, unless expressly specified otherwise.
- What Personal Data do we collect?
3.1 Personal Data we collect directly from you
The Personal Data that we collect directly from you may include the following:
If you express an interest in obtaining additional information about our services or products, request customer support, use our “Contact Us” or similar features, register to use our website, sign up for an event, we generally require you to provide us with your contact information, such as your name, job title, company name, address, phone number, email address, or username and password;
If you make purchases via our website or register for an event, we may also require you to provide us with financial information and billing information, such as billing name and address, credit card number, or bank account information;
If you attend an event, we may ask that you provide us with your name, title and company name, address, country, phone number and email address;
If you use and interact with our website, we automatically collect log files and other information about your device and your usage of our websites through cookies, web beacons or similar technologies, such as IP-addresses or other identifiers, which may qualify as Personal Data (view the “What device and usage data we process” section below);
If you visit our offices, you may be required to register as a visitor and to provide your name, email address, phone number, company name and time and date of arrival.
- What device and usage data we process
We use common information-gathering tools, such as log files, cookies, web beacons and similar technologies to automatically collect information, which may contain Personal Data, from your computer or mobile device as you navigate our website or interact with emails we have sent you.
4.1 Log Files
As is true of most websites, we gather certain information automatically via log files. This collected information may include your Internet Protocol (IP) address (or proxy server), device and application identification numbers, your location, your browser type, your Internet service provider and/or mobile carrier, the pages and files you viewed, your searches, your operating system and system configuration information, and date/time stamps associated with your usage. This information is used to analyse overall trends, to help us provide and improve our websites and to guarantee their security and continued proper functioning. We also collect IP addresses from users when they log into the services as part of the Company’s security features.
4.2 Cookies, web beacons and other tracking technologies
When you visit our website, our servers or an authorised third party may place a cookie on your browser, which can collect information, including Personal Data, about your online activities over time and across different sites. Cookies allow us to track overall usage, determine areas that you prefer, make your usage easier by recognizing you and providing you with a customised experience.
We also use web beacons on our websites. For example, we may place web beacons in marketing emails that notify us when you click on a link in the email that directs you to one of our websites. Such tracking technologies are used to operate and improve our website and email communications and track the clicking of links or opening of emails.
4.3 Notices on behavioural advertising and opt-out
As described above, we or third parties may place or recognise a unique cookie on your browser when you visit our website for the purposes of serving you targeted advertising (also referred to as “online behavioural advertising” or “interest-based advertising”).
To manage the use of targeting or advertising cookies on this website, consult your individual browser settings for cookies. Various browsers may offer their own management tools for removing HTML5 local storage.
4.4 Opt-Out from the collection of device and usage data
You may opt-out from the collection of device and usage data (see “What device and usage data we process” section above) by managing your cookies at the individual browser level. Please note, however, that by blocking or deleting cookies and similar technologies used on our website, you may not be able to take full advantage of the website.
4.5 Social Media Features
Our website may use social media features, such as the Facebook “like” button, the “Tweet” button and other sharing widgets. You may be given the option by such Social Media Features to post information about your activities on a website to a profile page of yours that is provided by a third party social media network in order to share with others within your network. Social Media Features are either hosted by the respective social media network or hosted directly on our website. To the extent the Social Media Features are hosted by the respective social media networks, the latter may receive information that you have visited our website from your IP address. If you are logged into your social media account, it is possible that the respective social media network can link your visit of our websites with your social media profile.
Your interactions with Social Media Features are governed by the privacy policies of the companies providing the relevant Social Media Features.
- Purposes for which we process Personal Data
We collect, process your Personal Data for the purposes and on the legal bases identified in the following:
Promoting security of our websites: We will process your Personal Data by tracking use of our websites, creating aggregated, non-personal data, verifying accounts and activity, investigating suspicious activity, as well as violations of and enforcement of our terms and policies, to the extent this is necessary for the purpose of our legitimate interests in promoting the safety and security of the systems and application used for our websites, and protecting our rights and the rights of others;
Handling contact and user support requests: If you fill out a “Contact Me” web form, request user support, or if you contact us by other means, we will process your Personal Data for the performance of our contract with you and to the extent it is necessary to fulfil your request and communicate with you;
Managing event registrations and attendance: We will process your Personal Data to plan and host the event, including related communication with you;
Managing payments: If you have provided financial information, we will process your respective Personal Data to check the financial qualifications and collect payments to the extent this is necessary for completing transaction with you under the contract entered into with you;
Developing and improving our websites: We will process your Personal Data to analyse trends, track your usage of our websites and interactions with emails to the extent this is necessary for our legitimate interests to develop and improve our website and to provide our users with more relevant and interesting content;
Managing office visitors: We will process your Personal Data for security reasons and to register who visited our offices;
Displaying personalised advertisements and content: We may process your Personal Data to conduct market research, advertise to you, provide personalised information about us on and off our website, and other personalised content based upon your activities and interests to the extent it is necessary for our legitimate interests to advertise our website or, where necessary, to the extent you have provided your prior separate consent;
Sending marketing communications: We will process your Personal Data to send you marketing information, product recommendations and other non-transactional communications (e.g., marketing newsletters, SMS, or push notifications) about us and our affiliates and partners, including information about our products, promotions or events as necessary for our legitimate interests to conduct direct marketing or to the extent you have provided your prior separate consent;
Complying with legal obligations: We will process your Personal Data when cooperating with public and government authorities, courts or regulators in accordance with our legal obligations under relevant laws to the extent this requires the processing or disclosure of Personal Data to protect our rights, and is necessary to protect against misuse or abuse of our website, to protect personal property or safety, to pursue remedies available to us and limit our damages, to comply with a judicial proceedings, court order or legal process, and/or to respond to lawful requests.
Where we need to collect and process Personal Data by law, or under a contract we have entered into with you and you fail to provide that required Personal Data when requested, we may not be able to honour the contract.
- Who do we share Personal Data with?
We may share your Personal Data with the following recipients:
Our contracted service providers which provide services such as IT and system administration and hosting, credit card processing, research and analytics, marketing, customer support and data enrichment;
If you attend an event organised or attended by us, we may share your information with sponsors of the event if you consent to such sharing via an event registration form. In that event, your information will be subject to the business partners’ respective privacy statements. If you do not wish for your information to be shared, you may choose not to opt-in via event registration;
With third–party social networks, advertising networks and websites, which usually act as separate controllers, so that Tutex can market and advertise on third party platforms and websites;
In individual cases we may also share Personal Data with professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers;
If we are involved in a merger or reorganisation, sell the business, or if all or a portion of our business, assets or stock are acquired by another company, we may transfer some or all of your Personal Data to such third party. In accordance with applicable laws, we will use reasonable efforts to notify you of any such transfer of Personal Data to an unaffiliated third party as processing of your Personal Data will be required for the purposes set out in “Purposes for which we process Personal Data and on which legal bases” section above.
Our websites are not intended for use by children. We do not knowingly collect Personal Data from children under the age of 16. If you are a parent or guardian and believe your child has provided us with Personal Data without your consent, please contact us and we will take steps to delete such Personal Data from our systems.
- How long do we keep your Personal Data?
We may retain your Personal Data for a period of time consistent with the original purpose of collection (see “Purposes for which we process Personal Data and on what legal basis” section above). We determine the appropriate retention period for Personal Data on the basis of the amount, nature, and sensitivity of your Personal Data, the potential risk of harm from unauthorized use or disclosure, and whether we can achieve the purposes of the processing through other means, as well as the applicable legal requirements (such as applicable statutes of limitation).
After expiry of the retention periods, your Personal Data will be deleted. If there is any information that we are unable, for technical reasons, to delete entirely from our systems, we will put in place appropriate measures to prevent any further use of the data.
- Your rights relating to your Personal Data
10.1 Your rights
You have certain rights regarding your Personal Data, subject to local data protection laws. These may include the following rights:
To access your Personal Data held by us (right to access);
To rectify inaccurate Personal Data and ensure it is complete (right to rectification);
To erase/delete your Personal Data to the extent permitted by other legal obligations (right to erasure; right to be forgotten);
To restrict our processing of your Personal Data (right to restriction of processing);
To transfer your Personal Data to another controller to the extent possible (right to data portability);
To object to any processing of your Personal Data carried out on the basis of our legitimate interests (right to object). Where we process your Personal Data for direct marketing purposes or share it with third parties for their own direct marketing purposes, you can exercise your right to object at any time to such processing without having to provide any specific reason for such objection;
Not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects (“Automated Decision-Making”); Automated Decision-Making currently does not take place on our websites;
To the extent we base the collection, processing and sharing of your Personal Data with your consent, to withdraw your consent at any time, without affecting the lawfulness of the processing based on such consent before its withdrawal.
10.2 How to exercise your rights
To exercise your rights, please contact us using the details below. We try to respond to all requests within one month and will contact you if we need additional information from you in order to honour your request.
In addition, if you have registered for an account with us, you may generally update your user settings, profile, organization’s settings or event registration by logging into the applicable website with your username and password and editing your settings or profile. To update your billing information, discontinue your account, and/or request return or deletion of your Personal Data and other information associated with your account, please contact us.
10.3 Your preferences for marketing communications
If we process your Personal Data for the purpose of sending you marketing communications, you may manage your receipt of marketing and non-transactional communications from us by clicking on the “unsubscribe” link contained in our marketing emails. Additionally, you may unsubscribe by contacting us using the Contact Us form on our website. Please note that opting-out of marketing communications does not opt you out of receiving important business communications related to your current relationship with us, such as information about your subscriptions or event registrations, service announcements or security information.
We take precautions including organisational, technical, and physical measures, to help safeguard against accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, the Personal Data we process or use.
While we follow generally accepted standards to protect Personal Data, no method of storage or transmission is 100% secure. You are solely responsible for protecting your password, limiting access to your devices, and signing out of our website after your sessions.
If you have any questions about the security of our website, please contact us using the details below.
- Changes to this Privacy Statement
We will update this Privacy Statement from time to time to reflect changes in our practices, technology, legal requirements and other factors. If we do, we will update the “effective date” at the top of this Privacy Statement. If we make an update, we may provide you with notice prior to the update taking effect, such as by posting a conspicuous notice on our website or by contacting you using the email address you provided.
We encourage you to periodically review this Privacy Statement to stay informed about our collection, processing and sharing of your Personal Data.
- Contacting us
To exercise your rights regarding your Personal Data, or if you have questions regarding this Privacy Statement or our privacy practices please contact us using the following details:
Gloucestershire office (Head office)
Firing Close Farm,
Wotton Under Edge,
Tel: 01454 809 060
E mail: firstname.lastname@example.org
We are committed to working with you to obtain a fair resolution to any complaint or concern about privacy. If, however, you believe that we have not been able to assist with your complaint or concern, and you are located in the EEA, you have the right to lodge a complaint with the competent supervisory authority.