Privacy Policy: Broadsail Website

This is the Privacy Policy for the Broadsail Website, owned and maintained by Broadsail Ltd.

Broadsail is dedicated to safeguarding personal data subject to processing, as well as to developing and applying data protection solutions that are effective, fit for purpose and demonstrate an understanding of, and appreciation for the Data Protection Act 2018 (UK GDPR).

The Data Protection Act 2018 is the UK’s implementation of the General Data Protection Regulation (GDPR).

We are committed to ensuring ongoing and continued compliance with data protection legislation and guidance provided by the supervisor of our general work and practices and all of our service offerings, to protecting any personal data, limiting any collection to what is strictly necessary by legitimate interest and consent and complying with the UK GDPR and national legislation.

This Privacy Policy concerns the processing of your personal data for which Broadsail is the Data Controller or Data Processor, in other words, Broadsail Ltd collects personal data directly or indirectly from you and describes personal data that is needed to provide you with the service, the purposes for which your personal data is being collected, how it is stored, shared and how long it will be retained.

Considering the significance of this responsibility, Broadsail works daily to put in place adequate measures and controls to protect your personal data and ensure that you can exercise your rights at any time.

Personal identification information from the users is collected through:

• Main service
• Data from identity providers
• Web analytics
• Cookies
• Forms
• Email marketing communications

Reasons for data collection

Reasons for collection of your personal data are:

• Service operation or usage monitoring
• Enhancement of service experience
• Service usage statistics
• Targeted marketing communications

Methods of data collection

The following tools are used to collect user and usage data:

1. Web analytics

Insights from web analytics tools help us improve content and user experience.

Google Analytics is used to analyze the use of this service. Google’s privacy policy is available at: http://www.google.com/privacypolicy.html.

• We use Google Analytics to track how often people access or read our content. We use this information in the aggregate form to understand what content our members find useful or interesting, so we can produce the most valuable content to meet your needs.
• We use Google Analytics to track the number of visitors to our site but do not collect any personal information or store IP addresses locally on our site. This is only used to monitor the number of hits on our pages and the coarse location; therefore we cannot track or trace individual users or their physical addresses. If you would like to opt-out, please use the Google Analytics Opt-out Browser Add-on https://tools.google.com/dlpage/gaoptout.

2. Cookies

We use cookies (small text files written by your browser to your device) to track returning visits and navigation through the website. Cookies are required to use the website.

By using our service’s website, you agree that we can place these types of cookies on your device. However, you can block these cookies using your browser settings (there are instructions in the Cookie Policy on how to do this) or via the Consent Management Platform (CMP) pop-up banner.

Broadsail recommends you to accept and use cookies.

A full Cookie Policy can be seen by clicking the Broadsail Website Cookie Policy (https://www.broadsail.co.uk/cookie-policy), which will provide further details on:

• how we use cookies
• how to enable/disable cookies
• how to change cookie settings
• the cookies used on the websites

3. Web forms

When you submit a form, Broadsail stores the data you provide including email address, name and any other fields requested. This data is stored in the United Kingdom. The data processor for this service is Broadsail.

4. Email marketing communications

When you submit a form and check the opt-in checkbox, you are giving consent to record and use your email address to send you regular newsletters. You may also submit a form that is specifically used to register for email marketing communications, in this case submitting the form will provide the same level of consent. If you provide a country within the Opt-out country list below then you will be giving implied opt-in consent even if you do not check the opt-in checkbox. You may withdraw your consent and unsubscribe at any time by clicking the unsubscribe link in any received newsletter.

Double Opt-in: If you provide your location as Germany, Austria, Greece, Luxembourg, Norway or Switzerland then you will receive a double opt-in email with a confirmation link. You will not be fully signed-up for email marketing communications until you click this link. We may send you reminder email(s) if you do not respond. You will only be required to provide double opt-in confirmation once.

Opt-out countries: If you provide your location United Kingdom or United States then implied email consent will be recorded with any form submission. You may opt-out at any time by following the unsubscribe link in the footer of a received email.

Data storage and retention periods

All data is stored in United Kingdom. The website and services are running on a server in United Kingdom. Data stored by third parties is covered by appropriate data processing agreements.

Your personal information is stored for the duration of your use of the service provided. We keep this data to deal with any queries that may arise following your use of our service.

Personal data is only stored as long as it is necessary to provide a requested service dependent on this data.

IP addresses may be stored. Broadsail does not have legal means of obtaining sufficient additional data to link an IP address to a person’s real-world identity.

In certain circumstances, data may be retained longer for archiving in the public interest, scientific or historical research and other similar purposes.

Security of personal data

Broadsail Ltd takes the confidentiality, integrity and availability of your personal data very seriously. We take appropriate security precautions to protect your personal data from loss, misuse or unauthorised access, disclosure, alteration and destruction. When you access the Broadsail Website, Broadsail Ltd will provide adequate security controls to keep your personal data safe depending on the type of data collected from you.

Although we endeavour to ensure your personal data remains secure, there is no absolute guarantee of security when using services online. While we strive to protect your personal data, you acknowledge that:

• There are security and privacy limitations on the Internet which are beyond our control.
• The confidentiality, integrity and availability of any information exchanged using these services cannot be 100% guaranteed.
• We cannot be held accountable for activities that result from your own neglect to safeguard the security of your login credentials and equipment that may lead to compromising your personal data.

If you feel this is not sufficient, then please do not provide any personal data.

Data subject rights

The UK GDPR gives individuals specific rights over their personal data. For general data processing under the UK GDPR, in summary these are:

• the right to access personal data held about them (the right of subject access);
• the right to be informed about how and why their data is used – and you must give them privacy information;
• the rights to have their data rectified, erased or restricted;
• the right to object;
• the right to portability of their data; and
• the right not to be subject to a decision based solely on automated processing.

You also have the right to inquire what personal data we hold about you, and to present a complaint to the relevant Supervisory Authority about our personal data processing activities if you feel your personal data is not being managed as described here.

Please note that submitting a Data Subject Access Request might be connected with providing information confirming your identity and the legal basis for this processing is compliance with a legal obligation (ensuring data subject access request).

The erasure of personal information or termination of your data processing by us may limit service, access to it or the results or outcomes of previous use of the service, especially if these results are inherently related to the presence of personal information.

1. Access to personal data

You may submit a Subject Access Request to Broadsail. The response will include a description of your data, any recipients of it, as well as a copy of your data. Any request regarding Data Subject Rights will be responded to within 90 days.

2. Right to rectification and erasure

You have the right to correct any inaccurate personal data held by Broadsail. You also have the right to request the erasure of any data that is no longer necessary for the purpose for which it was collected.

3. Right to restriction of processing and withdrawal of consent

You have the right to restrict the processing of your personal data or object to the processing of your data. You also have the right to withdraw previously given consent to process personal data.

4. Rights to data portability

You have the right to receive your personal data that Broadsail holds by consent in a structured, commonly used and machine-readable format. You also have the right to transmit that data to another controller without hindrance from Broadsail.

Automated processing

Our services use automated processing to detect and respond to problems more efficiently. If you feel any decision made by any automated process has affected you in a way that is not acceptable, you can contact the Data Protection Officer to ask us to review the results manually.

Contacts

Broadsail Ltd, as the owner and data controller of the Broadsail Website, has appointed a Data Protection Officer (DPO), for you to contact if you have any questions or concerns about the way Broadsail is processing your personal data. Together, the DPO and the Broadsail Website service team are working to provide you with accurate information and implement measures to protect your privacy.

For questions, comments or complaints regarding personal data and privacy, this Privacy Policy and how Broadsail processes your personal data, and to exercise data subject rights, please contact the Data Protection Officer: (dpo [at] broadsail.co.uk).

Changes and updates to the Privacy Policy

This service may change from time to time and this Privacy Policy will be updated appropriately. We reserve the right to amend the Privacy Policy at any time – in such case, an updated version of the Privacy Policy will be posted at this location and we encourage you to check it from time to time.

Created by RePol (https://repol.ni4os.eu) version 4.0, source code at GitHub under EUPL-1.2-or-later, with subsequent modifications made for UK GDPR.