Our privacy promise

 

Who we are

“We” are Trace Data Ltd, headquartered in the UK; our registered office address is Ground Floor, 11-15 Thistle Street, Edinburgh, Scotland, EH2 1DF. We are registered with the Information Commissioner's Office (ICO); our registration number is ZB031089.

Our PRIVACY ETHOS

We will always protect and respect your privacy, and we are committed to security when it comes to your information, and we are driven by Privacy by Design in everything we do with personal data. We promise that if we ever collect, process, store and share your data we will do so safely and securely. Our approach to data collection and retention is grounded in a clear purpose and data minimisation.

WHAT PERSONAL DATA DO WE COLLECT, AND HOW DO WE USE IT?

When you contact us via our website, our diary booking page or sign up to our updates, we may use personal information (such as your name and email address) to enable us to respond to you using and keep in touch with you about relevant promotions, updates on Trace and services based on consent or legitimate interests (to enable us to legitimately communicate with you about relevant offers) using HubSpot or Gmail. You can unsubscribe to marketing or events at any time.

When you sign up for a Trace account or to our Academy, we will securely process you name and email address to enable us deliver the services to you, based on contract as our legal basis. You can delete your account at any time. If you are a Trace customer or user of our app or online learning Academy, please see our Terms of Service for details of data protection, compliance and sub-processors, which include Thinkific as our Learning Management System and Microsoft Azure as our application infrastructure provider.

When communicating with our clients or suppliers or handling operations, we use Google, Microsoft, Calendly, Canva and FreeAgent as our security assured data processors, on the basis of contract or Legitimate Interests. Additionally, we use Squarespace Analytics to review how visitors use our site, but we do not retain data logs.

All of our processors and cloud services are carefully vetted and assured where personal data is handled; at Trace we take compliance and data protection seriously and only work with trusted services and third parties.

Retention, Storage & Transfers

We only store your data for as long as is necessary for the purposes of processing that are set out in this policy and according to our retention schedules, after which it is deleted according to our data management processes. We have taken appropriate safeguards to require that the personal information we process will remain protected in accordance with this Privacy Notice when transferred internationally, including when processed internationally by our third-party service providers and partners.

At Trace® we model all our data categories and track adequate locations for any data we process via our platform.

How to access and control your personal data

You have certain rights in relation to personal information we hold about you; details of these rights and how to exercise them are set out below. We will require evidence of your identity before we are able to act on your request.

  1. Right of Access: You have the right at any time to ask us for a copy of the Information about you that we hold, and to confirm the nature of the Information and how it is used.
  2. Right of Correction or Completion: If Information we hold about you is not accurate, or is out of date or incomplete, and requires amendment or correction you have a right to have the data rectified, updated or completed.
  3. Right of Erasure In certain circumstances, you have the right to request that Information we hold about you is erased e.g. if the Information is no longer necessary for the purposes for which it was collected or processed or our processing of the Information is based on your consent and there are no other legal grounds on which we may process the Information.
  4. Right to Object to or Restrict Processing: In certain circumstances, you have the right to object to our processing of your Information by contacting us at the address or email address set out below. For example, if we are processing your Information on the basis of our legitimate interests and there are no compelling legitimate grounds for our processing which override your rights and interests. You also have the right to object to use of your Information for direct marketing purposes.
  5. Right of Data Portability: In certain instances, you have a right to receive any Information that we hold about you in a structured, commonly used and machine-readable format.

We are also unable to comply with requests that relate to Information of others without their consent. You can exercise any of the above rights by contacting us at the address or email address set out below. Most of the above rights are subject to limitations and exceptions; we will provide reasons if we are unable to comply with any request for the exercise of your rights.

All your personal Information shall be held and used in accordance with the UK General Data Protection Regulation 2016/679 (" UK GDPR") and national laws implementing UK GDPR and any legislation that replaces it in whole or in part and any other legislation relating to the protection of personal data.

How to get in touch

If you want to know what information we collect and hold about you, or to exercise any of your rights as set out in section, please write to us at our company address or via email at info@tracedata.co.uk.

You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO), who are the UK’s supervisory authority; their address is: Wycliffe House, Water Lane, Wilmslow SK9 5AF.

This policy was last updated on 05/10/2022.