Privacy & Cookie Policy

Last updated July 28, 2023

Welcome to Cuvama Limited’s privacy and cookie policy.

Cuvama Limited respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our Website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

Purpose of this privacy policy

This privacy policy aims to give you information on how Cuvama Limited collects and processes your personal data through your use of this Website, including any data you may provide through this Website when you send us feedback, submit data onto our Website, complete forms, report a problem with the Website, contact us for any reason or engage us to provide a service.

We take your privacy very seriously. We ask that you read this Privacy Policy carefully as it contains important information on who we are, how and why we collect, store, use and share personal information, your rights in relation to your personal information and on how to contact us and supervisory authorities in the event you have a complaint.

Who we are

https://cuvama.com (Website) is brought to you by Cuvama Limited, a company incorporated and registered in England and Wales under company number 11099130 whose registered office address is at 35 Westgate, Huddersfield, United Kingdom, HD1 1PA.

We collect, use and are responsible as the controller for certain personal information about you.

Controller

Cuvama Limited (hereafter referred to as “Cuvama”, “we”, “us” or “our”) acts as a data controller for the purposes of processing your personal data when you visit or use the Website.

We have appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO using the details set out in this document.

Our collection and use of your personal information

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 you which we have grouped together as follows:

We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific feature of the Website. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this 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). Nor do we collect any information about criminal convictions and offences.

Information that you provide

We will obtain personal data you provide when you send us feedback, submit data onto our Website, complete forms, report a problem with the Website, contact us for any reason and by any medium (including via the Website) or engage us to provide a service.

We may retain a record of any contact you make with us.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you at the time if this is the case.

Information from third parties

Occasionally we may receive information about you from other sources, which will be added to the information already held about you in order for us to help supply our services and products to you.

Information that will be collected automatically

We may monitor your use of the Website through the use of cookies and similar tracking devices. For example, we may monitor how many times you use the Website, which pages you go to and traffic data. Some of this data will be aggregated or statistical, which means that we will not be able to identify you individually. For further information on the use of cookies on the Website, please see the sections on cookies below.

How your personal data is collected

We use different methods to collect personal data from and about you including through:

  • Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
    • apply for our products or services;
    • subscribe to our newsletters and/or publications;
    • request marketing to be sent to you;
    • complete forms;
    • report a problem on our Website;
    • enter a competition, promotion or survey; or
    • give us feedback or contact us.
  • Automated technologies or interactions. As you interact with our Website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie section below for further details.
  • Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:

Technical Data from the following parties:

  • analytics providers;
  • advertising networks; and
  • search information providers.
  • Contact Data from providers of technical services.
  • Identity and Contact Data from data brokers or aggregators.
  • Identity and Contact Data from publicly available sources.

 

How your personal data will be used

Under relevant data protection laws, we will only use your personal information if we have a lawful reason for doing so. For example:

  • to comply with our legal and regulatory obligations;
  • for the performance of our contract with you or to take steps at your request before entering into a contract;
  • for our legitimate interests or those of a third party; or
  • where you have given consent.

A legitimate interest is where we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

The table below explains why we use (process) your personal data and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Please note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your personal data. Please contact us if you need details about the specific legal basis we are relying on to process your personal data where more than one basis has been set out in the table below.

 

What we use your personal data for

Lawful basis for processing

To provide our services and products to you.

For the performance of our contract with you or to take steps at your request before entering into a contract.

To prevent and detect fraud against you or Cuvama.

For our legitimate interests or those of a third party, i.e. to minimise fraud that could be damaging for us and for you.

Ensuring business policies are adhered to, e.g. policies covering security and internet use.

For our legitimate interests or those of a third party, i.e. to make sure we are following our own internal procedures so we can deliver the best service to you.

Operational reasons, such as improving efficiency, training and quality control.

For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price.

Ensuring the confidentiality of commercially sensitive information.

For our legitimate interests or those of a third party, i.e. to protect trade secrets and other commercially valuable information.

To comply with our legal and regulatory obligations.

Statistical analysis to help us manage our business, e.g. in relation to our financial performance, customer base, product range, use of our products and services or other efficiency measures.

For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price.

Preventing unauthorised access and modifications to our systems and products.

For our legitimate interests or those of a third party, i.e. to prevent and detect criminal activity that could be damaging for us and for you.

To comply with our legal and regulatory obligations.

Updating customer records.

For the performance of our contract with you or to take steps at your request before entering into a contract.

To comply with our legal and regulatory obligations.

For our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about existing orders and new products.

Statutory returns.

To comply with our legal and regulatory obligations.

Ensuring safe working practices, staff administration and assessments.

To comply with our legal and regulatory obligations.

For our legitimate interests or those of a third party, e.g. to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you.

Marketing our services to:

—existing and former customers;

—third parties who have previously expressed an interest in our services;

—third parties with whom we have had no previous dealings.

For our legitimate interests or those of a third party, i.e. to promote our business to existing and former customers.

We may monitor and record communications with you (such as telephone conversations and emails) for the purpose of quality assurance, training, fraud prevention and compliance.

For our legitimate interests or those of a third party, i.e. to ensure our employees are trained to provide you with the best possible service.

To notify you of changes to the Website or to our services or products that may affect you.

For our legitimate interests or those of a third party, i.e. to ensure you’re up to date with our services and to promote any change.

External audits and quality checks, e.g. for ISO or Investors in People accreditation and the audit of our accounts.

For our legitimate interests or a those of a third party, i.e. to maintain our accreditations so we can demonstrate we operate at the highest standards.

To comply with our legal and regulatory obligations.

 

Disclosure of your personal data

We routinely share personal data with:

  • third parties we use to help deliver our products and services to you, e.g. payment service providers and hosting service providers;
  • other third parties we use to help us run our business, e.g. marketing service providers and our professional advisors;
  • our bank.

We only allow our service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers relating to ensure they can only use your personal data to provide services to us and to you. We may also share personal data with external auditors.

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

We may also need to share some personal data with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised but this may not always be possible. The recipient of the personal data will be bound by confidentiality obligations.

Transfer of your information out of the UK

To deliver services to you, it is sometimes necessary for us to share your personal information outside of the UK, e.g.:

  • with your and our service providers located outside of the UK;
  • if you are based outside of the UK;
  • where there is an international dimension to the services we are providing to you.

These transfers are subject to special rules under UK data protection law. We will ensure any transfer complies with relevant data protection law and all personal information will be as secure as possible.

Please contact us if you would like further information on the specific mechanism used by us when transferring your personal data out of the UK.

Marketing

We may use your personal data to send you updates by email about our products and services, including exclusive offers, promotions or new products and services.

We have a legitimate interest in processing your personal data for promotional purposes. This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.

We will always treat your personal data with the utmost respect and never share it with other organisations outside of Cuvama for third-party marketing purposes, without first gaining your explicit consent to do so.

You have the right to opt out of receiving promotional communications at any time by:

We may ask you to confirm or update your marketing preferences if you instruct us to provide further products and/or services in the future, or if there are changes in the law, regulation, or the structure of our business.

Your Rights

You have a number of rights under data protection laws in relation to your personal data.

  • You have the right to be informed about the collection and use of your personal data.
  • You have the right to request access to your personal data or other records that we hold about you. Normally we will not charge you for providing you with these records, but we reserve the right to charge a reasonable fee involved with providing you with access if we receive a request which is manifestly unfounded or excessive to access personal records. Alternatively, we may refuse to comply with your request in these circumstances. We may also charge a reasonable fee, if further copies of your data is requested following your initial request.
  • You have the right to request correction of the personal data that we hold about you. If any data or information we hold about you is inaccurate, or out of date, please contact us and we will correct this, though we may need to verify the accuracy of the new personal data you provide to us.
  • You have the right to 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. Please 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.
  • You have the right to request the restriction or suppression of processing your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
    • If you want us to establish the personal data’s accuracy.
    • Where our use of the personal data is unlawful but you do not want us to erase it.
    • Where you need us to hold the personal data even if we no longer require it as you need it to establish, exercise or defend legal claims.
    • You have objected to our use of your personal data but we need to verify whether we have overriding legitimate grounds to use it.
  • You have the right to object to processing of your personal data where we use it for our legitimate interests, including for direct marketing purposes. You also have the right to object where we are processing your personal data for direct marketing purposes, in particular channels such as email or telephone. If this is the case, please specify the channels you are objecting to in your communications with us. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • You have the right to 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. Please 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. We reserve the right to charge a reasonable fee for complying with any requests that are manifestly unfounded or excessive.
  • You have the right to 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 wish to exercise any of the rights set out above, please contact us.

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 could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

How long we will store your data

We will keep your personal information for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect of our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

When it is no longer necessary to retain your personal information, we will delete or anonymise it.

Children

This Website, our products and our services are not intended for children and we do not knowingly collect data relating to children.

Keeping your personal information secure

We have appropriate security measures in place to prevent your personal data from being accidentally lost, altered or disclosed, or otherwise used or accessed in an unauthorised way. We limit access to your personal data to those who have a genuine business need to know it. Those processing your personal data will do so only in an authorised manner and are subject to a duty of confidentiality. We also confirm that your personal data will be stored on secure servers.

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

Use of cookies

A cookie is a small text file which is placed onto your computer (or other electronic device) when you access the Website or utilise any of our digital products and tools. We use cookies and other online tracking devices on to:

  • obtain information about your website preferences and tailor its operations to your needs;
  • identify which pages are being used, helping us to analyse data about web page traffic and ways to improve our Website in order to tailor it better to our customer needs.

The information we obtain from the use of cookies will not usually contain your personal data. Although we may obtain information about your device such as your IP address, your browser and/or other internet log information, this will not usually identify you personally. In certain circumstances we may collect personal data about you, but only where you voluntarily provide it.

In most cases we will need your consent in order to use cookies on this Website. The exception is where the cookie is essential in order for us to provide you with a service you have requested.

Description of cookies

The cookies that we utilise on our Website are placed to fulfil such functions as analysing how you use the Website to give you a better and more personalised experience, generate statistical data and allow visitors to share content with a range of networking and sharing platforms.

Some of the cookies we utilise on our Website include:

Cookie Name

Cookie Description

_gat

Google Analytics: used to throttle request rate

_gid

Google Analytics: used to distinguish users

_ga

Google Analytics: used to distinguish users

CognitoIdentityServiceProvider.<sessionid>.LastAuthUser

Email of last user logged into the site

CognitoIdentityServiceProvider.<sessionid>.refreshToken

Token used to redeem new access token

CognitoIdentityServiceProvider.<sessionid>.accessToken

Session access token

CognitoIdentityServiceProvider.<sessionid>.idToken

Session id token

CognitoIdentityServiceProvider.<sessionid>.userData

Cognito user data

CognitoIdentityServiceProvider.<sessionid>.clockDrift

Cognito cookie to track clock drft

amplify-signin-with-hostedUI

Used to track login page hosting option

Pendo

Pendo Services use browser cookies to temporarily store visitor information which is used to ensure correct delivery of information and other operations of the Pendo Services

Linkedin

LinkedIn Conversion Tracking and Insight Tag

 

How to turn off cookies

If you do not want to accept cookies, you can change your browser settings so that cookies are not accepted. If you do this, please be aware that you may lose some of the functionality of the Website.

Changes to this privacy policy

We keep our privacy policy under regular review. This privacy policy was last updated on 7th July 2023.

We may change this privacy policy from time to time. You should check this policy frequently to ensure you are aware of the most recent version that will apply each time you use the Website.

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.

How to contact us

If you have any questions about this privacy policy or our privacy practices, please contact us in the following ways:

Email address: info@cuvama.com

Postal address: 35 Westgate, Huddersfield, United Kingdom, HD1 1PA

Concerns and Questions

We hope that we can resolve any query or concern you might raise about our use of your personal data.

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

 

 

 

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