Privacy Policy

Last updated November 24, 2021

Why you should read this policy

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 MG Pricing Consultancy 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’ or ‘us’).

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

Our collection and use of your personal information

Information that you provide

We will obtain personal information 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 do not collect, store or process data that is defined as sensitive or as special category data under applicable data protections laws.

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

The personal information we collect about you depends on the particular activities carried out and the reason for the processing. Such information includes, but is not limited to:

  • your name, address and contact details;
  • details of any contact with us by phone, email, post or via social media; and
  • information about the services we provide to you.

When using our Website, for any data you submit onto our Website that is personal information about a third party individual, for example for the purpose of collaborating and sharing information with that third party individual, you must ensure you have permission from that third party individual in advance.

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 will be used

Under relevant data protection laws, we can 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 when 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 what we use (process) your personal information for and our reasons for doing so:

What we use your personal information forOur reasons
To provide our services and products to youFor 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 CuvamaFor 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 useFor 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 controlFor 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 measuresFor 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 returnsTo 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 youFor 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 information 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 information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you. We may also share personal information 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 information 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 information will be bound by confidentiality obligations.

Transfer of your information out of the EEA

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 European and 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.

Marketing

We may use your personal information 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 information 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 information 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:

  • contacting us at info@cuvama.com
  • using the ‘unsubscribe’ link in emails

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

Under the General Data Protection Regulations (GDPR), you have the following rights:

  • You have the right to be informed about the collection and use of your personal data.
  • You have the right of access to your personal records or other information that we hold about you. We reserve the right to charge a reasonable fee for our administrative costs 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 this circumstance. We may also charge a reasonable fee, in relation to administrative costs, if further copies of your data is requested following your initial request.
  • You have the right to rectify any errors in the data 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 immediately.
  • You may have the right to have the data we hold about you erased. 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 may have the right to request the restriction or suppression of processing. 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 data’s accuracy.
    • Where our use of the data is unlawful but you do not want us to erase it.
    • 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.
    • You have objected to our use of your 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 may also specify that you object to direct marketing by particular channels such as by email or telephone. If this is the case, please specify the channels you are objecting to in your communications with us.
  • You have the right to data portability. 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. We reserve the right to charge a reasonable fee for the administrative costs of 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.

To revise your consent, request access, amend or remove your records or assert any of your rights set out above, you should send your request in writing to us at info @ cuvama.com

You may need to provide proof of identity and address (e.g. a copy of your driving licence or passport, and a recent utility or credit card bill); and specify the personal data you want access to, amended or removed.

How long we will store your data

We will keep your personal information while you have an account with us or we are providing products and services to you. Thereafter, we will keep your personal information for as long as is necessary:

  • to respond to any questions, complaints or claims made by you or on your behalf;
  • to show that we treated you fairly;
  • to keep records required by law.

We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information.

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

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 information 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 NameCookie Description
_gatGoogle Analytics: used to throttle request rate
_gidGoogle Analytics: used to distinguish users
_gaGoogle Analytics: used to distinguish users
CognitoIdentityServiceProvider.<sessionid>.LastAuthUserEmail of last user logged into the site
CognitoIdentityServiceProvider.<sessionid>.refreshTokenToken used to redeem new access token
CognitoIdentityServiceProvider.<sessionid>.accessTokenSession access token
CognitoIdentityServiceProvider.<sessionid>.idTokenSession id token
CognitoIdentityServiceProvider.<sessionid>.userDataCognito user data
CognitoIdentityServiceProvider.<sessionid>.clockDriftCognito 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

 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 Policy

This privacy notice was last updated o November 24th, 2021.

We may change this 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.

How to contact us

Please contact us if you have any questions about this privacy notice or the information we hold about you.

If you wish to contact us, please send an email to info@cuvama.com.

Concerns and Questions

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

However, you have the right to lodge a complaint with a supervisory authority in the territory where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone: 0303 123 1113.