Privacy Policy

1. Introduction

1.1 We are committed to safeguarding the privacy of our website visitors and service users. This policy is designed to ensure that we safely handle your personal data in accordance with relevant regulations and legislation such as Data Protection Act 1998 and EU General Data Protection Regulations 2018 (the “Data Protection Regulations”).

1.2 This policy applies in those cases where we act as a data controller for the personal data of our website visitors and service users. This means those cases where we can decide the purposes and method of processing your personal data.

1.3 By using our website and agreeing to this policy, you also consent to our use of cookies in accordance with the terms of this policy.

1.4 These privacy rules explain what data we may collect from you, what we will do with that data and explains how you can limitthe publication of your information and how you can choose whether or not you would like to receive direct marketing communications.

1.5 In this policy, "we","us" and "our" refer to Traffic Parrot Ltd. Further details about us can be found below, in section 10 of this Privacy Policy.

2. How we use your personal data

2.1 In this Section 2 we set out:

(a) the general categories of personal data that we may process;

(b) the purposes for which we may processpersonal data; and

2.2 We may process data about your use of our website and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your website or service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes ofanalysing the use of the website and services. The legal basis for this processing is either your specific consent or where we are not legally required to ask for consent, we may process this data for our legitimate interests, namely monitoring and improving our website and services.

2.3 We may process your account data ("account data"). The account data may include your name, email address, contact phone number and postal address. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is either your specific consent or where we are not legally required to ask for consent, we may process this data for our legitimate interests, namely monitoring and improving our website and services.

2.4 We may process personal data that is provided in the course of the use of our services ("service data"). The service data may include: Your name; contact information including your home/billing address, telephone number and email address and your credit / debit card details, should you choose to make a purchase with us. The servicedata may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is either your specific consent or where we are not legally required to ask for consent, we may process this data for our legitimate interests, namely the performance of the services you have requested through the website, or the monitoring and improving our website and services.

2.5 We may process information contained in any enquiry you submit to us regarding goods and/or services ("enquiry data"). The enquiry data may be processed for the purposes ofoffering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is either your specific consent or where we are not legally required to ask for consent, we may process this data for our legitimate interests, namely monitoring and improving our website and services.

2.6 We may process information relating to transactions, including purchases of goods and services that you enter into with us and/or through our website ("transaction data"). The transaction data may include your contact details, your card details and the transaction details. The transaction data may be processed for the purpose of supplying goods or services and keeping proper records of those transactions. The legal basis 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 and our legitimate interests, namely our interest in the proper administration of our website and business.

2.7 We may process any of your personal data identified in this policy where necessary for administrative purposes including in the exercise or defence of legal claims. The legal basis for this processing is our legitimate interests, namely for administrative record keeping, processing transactions and maintaining business records or for the protection and assertion of our legal rights.

2.8 If you supply any other person's personal data to us, you must do so only if you have the authority of such person to do so and you must comply with any obligations imposed upon you under the Data Protection Regulations.

3. Providing your personal data to others

3.1 We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our holding company and its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.

3.2 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks,obtaining professional advice, or to exercise or defend legal claims.

3.3 We may pass your personal information to credit reference agencies or other agencies that provide services to verify your identity or for any other checks or searches required by legislation or our regulators relating to money laundering. These agencies may keep a record of any search that they do.

3.4 Financial transactions relating to our website and services are handled by our payment services providers, Revolut, PayPal and HSBC. We share transaction data with our payment services providers to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You may also wish to review our payment services providers' privacy policies and practices at Revolut Privacy Policy, PayPal Privacy and HSBC Legal information .

3.5 We use several providers for online conferencing for demos, business demonstrations and calls. For further information, here are links to the privacy policies:

1. Cisco WebEx

2. AppearIn

3. Zoom

4. Skype

3.6 We may outsource or contract the provision of IT services to third parties. If we do, those third parties may hold and process your personal data. In these circumstances, we will require that the IT supplier only processes your personal data for us, as directed by us, and in accordance with the Data Protection Regulations.

3.7 If we sell all or part of our business, we may pass your personal data to the purchaser. In these circumstances, we will require the purchaser to contact you after completion of the sale to inform you of the identity of the purchaser.

3.8 In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your legal interests or the legal interests of another person.

4. International transfers of your personal data

4.1 In this Section 4, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).

4.2 Other than as set out in this policy, we are not aware of any current circumstances where your personal data may be transferred to any country outside the EEA.

4.3 You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

5. Retaining and deleting personal data

5.1 This Section 5 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

5.2 Personal data that we process for any purpose shall not be kept for longer than is necessary for that purpose. This means that unless there is a good reason to do so we won't keep your personal data more than 6 years after our business relationship has ended.

5.3 It is not possible for us to specify in advance the periods for which your personal data will be retained. However, we will determine the period of retention based on your continued use of our website or services and based on our requirements for proper record keeping and accounting and legal purposes.

5.4 Notwithstanding the other provisions of this Section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your legal interests or the legal interests of another person.

6. Amendments

6.1 We may update this policy from time to time by publishing a new version on our website.

6.2 You should check this page occasionally to ensure you are happy with any changes to this policy.

6.3 We may notify you of changes to this policy by email or through the private messaging system on our website.

7. Your rights

7.1 In this Section 7, we have summarised the rights that you have under data protectionlaw. Some of the rights are complex, and not all of the details have beenincluded in our summaries. Accordingly, you should read the relevant laws andguidance from the regulatory authorities for a full explanation of theserights.

7.2 Your principal rights under dataprotection law are:

(a) the right to access;

(b) the right to rectification;

(d) the right to restrict processing;

(e) the right to object to processing;

(f) the right to data portability;

(g) the right to complain to a supervisoryauthority; and

(h) the right to withdraw consent.

7.3 You have the right to confirmation as towhether or not we process your personal data and, where we do, access to thepersonal data, together with certain additional information. That additionalinformation includes details of the purposes of the processing, the categoriesof personal data concerned and the recipients of the personal data. Providingthe rights and freedoms of others are not affected, we will supply to you acopy of your personal data, as described below (clause 7.13).

7.4 You have the right to have any inaccuratepersonal data about you rectified and, taking into account the purposes of theprocessing, to have any incomplete personal data about you completed.

7.5 In some circumstances you have the rightto the erasure of your personal data without undue delay. Those circumstancesinclude: the personal data is no longer necessary in relation to the purposesfor which it was collected or otherwise processed; you withdraw consent toconsent-based processing; you object to the processing under certain rules ofapplicable data protection law; the processing is for direct marketingpurposes; and the personal data have been unlawfully processed. However, thereare exclusions of the right to erasure. The general exclusions include whereprocessing is necessary: for exercising the right of freedom of expression andinformation; for compliance with a legal obligation; or for the establishment,exercise or defence of legal claims.

7.6 In some circumstances you have the rightto restrict the processing of your personal data. Those circumstances are: youcontest the accuracy of the personal data; processing is unlawfulbut you oppose erasure; we no longer need the personal data for the purposes ofour processing, but you require personal data for the establishment, exerciseor defence of legal claims; and you have objected toprocessing, pending the verification of that objection. Where processing has beenrestricted on this basis, we may continue to store your personal data. However,we will only otherwise process it: with your consent; for the establishment,exercise or defence of legal claims; for theprotection of the rights of another natural or legal person; or for reasons ofimportant public interest.

7.7 You have the right to object to ourprocessing of your personal data on grounds relating to your particularsituation, but only to the extent that the legal basis for the processing isthat the processing is necessary for: the performance of a task carried out inthe public interest or in the exercise of any official authority vested in us;or the purposes of the legitimate interests pursued by us or by a third party.If you make such an objection, we will cease to process the personalinformation unless we can demonstrate compelling legitimate grounds for theprocessing which override your interests, rights and freedoms, or theprocessing is for the establishment, exercise or defenceof legal claims.

7.8 You have the right to object to ourprocessing of your personal data for direct marketing purposes (includingprofiling for direct marketing purposes). If you make such an objection, wewill cease to process your personal data for this purpose.

7.9 You have the right to object to ourprocessing of your personal data for scientific or historical research purposesor statistical purposes on grounds relating to your particular situation,unless the processing is necessary for the performance of a task carried outfor reasons of public interest.

7.10 To the extent that the legal basis forour processing of your personal data is:

(a) consent; or

(b) that the processing is necessary for theperformance of a contract to which you are party or in order to take steps atyour request prior to entering into a contract,

andsuch processing is carried out by automated means, you have the right toreceive your personal data from us in a structured, commonly used andmachine-readable format. However, this right does not apply where it wouldadversely affect the rights and freedoms of others.

7.11 If you consider that our processing ofyour personal information infringes data protection laws, you have a legalright to lodge a complaint with a supervisory authority responsible for dataprotection. You may do so in the EU member state of your habitual residence,your place of work or the place of the alleged infringement.

7.12 To the extent that the legal basis forour processing of your personal information is consent, you have the right towithdraw that consent at any time. Withdrawal will not affect the lawfulness ofprocessing before the withdrawal.

7.13 You may request thatwe provide you with any personal information we hold about you. Provision ofthis information will be subject to:

(a) the payment of a fee (currently fixed at (GBP) £10.00); and

(b) the supply of appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address).

8. About cookies

8.1 A cookie is a small file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser asking permission to be placed on your computer's hard drive. The file is added and the cookie helps analyseweb traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

8.2 Cookies may be either"persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its setexpiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

8.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

9. Cookies that we use

9.1 We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our services in order to tailor them to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

9.2 Overall, cookies help us provide you with a better experience, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

9.3 You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking fulladvantage of our services.

9.4 We may use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google's privacy policy can be found at the following web address: https://www.google.com/policies/privacy/.

9.5 We have engaged Inspectlet to analysethe activities of visitors to this website, and Inspectlet’sauthorized use of cookies and other tracking technologies enable it to have access to Personal Information of visitors to this website. Such access to and use of Personal Information by Inspectlet is governed by Inspectlet’s Privacy Policy.

10. Our details

10.1 This website is owned and operated by Traffic Parrot Ltd.

10.2 We are registered in England and Wales under registration number: 10048075, and our registered office is at: 20-22 Wenlock Road, London, England, N1 7GU.

10.3 You can contact us:

(a) by post, to the postal address givenabove;

(b) by telephone, on the contact numberpublished on our website from time to time; or

11. Data protection officer

11.1 Our data protection officer's contactdetails are: Wojciech Bulaty, at: data-officer@trafficparrot.com