1. Who we are
We are Tadpole Cottage Ltd, trading as ONRECORD (“we”, “us” and “our”). We are registered in England and Wales under company register number 7463715. Our registered office address is Tadpole Cottage, Tadpole Lane SN25 2DZ. For the purposes of the retained EU law version of the General Data Protection Regulation (Regulation (EU) 2016/679) (UK GDPR), the data controller is Tadpole Cottage Ltd and our Data Protection Manager is Dr George Hibbert. Please note that if you are a Professional, you will be the data controller of any personal data that you upload to the Platform and we will be the data processor (as set out in our Conditions of Use).
2. What personal information is and what this policy is about
Personal information is information that can be used to identify you, such as your name, address, phone number or email address.
This policy describes what information we collect, why we collect it, what we do with it, what we don’t do with it and what rights you have.
3. The personal information we collect
In order for us to provide the Services, we need to gather a limited amount of personal information about users of our Sites. This information enables us to provide users with the Services and information they want, such as the ability to login securely and link accounts.
We collect the following kinds of personal information:
- Account Information – this includes the information that you provide to us when you set up an account, upgrade your account or link your account to another user, such as your name, email address, username, phone number, address, job title (if you are a Professional), payment information and billing address.
- Your Records – we store, process and transmit the records that you upload to the Platform, as well as information related to your records, in order to provide you with the Services. Related information includes things like the size of each file that you upload, the time it was uploaded and who you share records with.
- Usage Data – this includes details of your use of the Services and your visits to any of our Sites including actions you take in your account such as uploading, sharing, and messaging.
- Device Information – this includes information about the devices you use to access the Services, such as IP addresses, the type of browser you use and identifiers associated with your devices.
- Location Data – some features enable you to record your location by GPS. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling Location Data in your settings.
- Marketing and Communications Data – this includes your preferences in receiving marketing from us and your communication preferences.
4. How we collect personal information
We will collect and process the following data about you:
- Information you give us. This is information (including Account Information, Your Records, and Marketing and Communications Data) you consent to giving us about you by filling in forms on the Sites, or by corresponding with us (for example, by email). It includes information you provide when you create an account, subscribe to any of our Services, share records or message other users via the Services and when you report a problem with our Services, or any of our Sites. If you contact us, we will keep a record of that correspondence.
- Information we receive from other sources including third parties and publicly available sources. We will receive personal data about you from various third parties as set out below:
– Device Information and Usage Data from Google Analytics and Google Ads
– Account Information from our payment provider Stripe
6. What we do with your personal information
We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:
- Where you have consented before the processing.
- Where we need to perform a contract we are about to enter or have entered with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below. We will use your personal data to:
|Purpose/activity||Type of data||Lawful basis for processing|
|To create your account||Account Information||Your consent|
|Deliver the Services to you including managing payments and collecting money owed to us||Account Information
Marketing and Communications Data
Performance of a contract with you
Necessary for our legitimate interest (to recover debts due to us)
|Respond to your enquiries or requests for advice or assistance||Account Information
Performance of a contract with you
|Manage the linking of your account to third parties||Account Information
|Manage our relationship with you including notifying you of changes to the Sites or any Services||Account Information
Marketing and Communications Data
Performance of a contract with you
Necessary for our legitimate interests (to keep records updated and to analyse how the Services and Sites are used)
|To administer and protect our business and the Sites including troubleshooting, data analysis and system testing||Account Information
|Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security)|
|If you have agreed, provide you with information that we think may be of interest to you.||Account Information
Marketing and Communications Data
|To measure and analyse the effectiveness of the advertising we serve you and monitor trends so we can improve the Sites and Services||Usage Data
|Necessary for our legitimate interests (to develop our Sites/Services and grow our business)|
6. Using information about you to contact you
We may send you information about our company and our Services, such as information about changes to our Services or our Sites, subscription information and any new features that become available. You can opt-out of receiving this information at any time.
7. Sharing your personal information
We will share your personal information with third parties if we are legally required to do so by a law enforcement agency legitimately exercising a power, or if compelled by an order of the Court.
We may work with carefully-selected partners who may carry out work on our behalf. These partners may include mailing houses, marketing agencies, professional advisors and IT specialists. The kind of work we may ask them to do includes answering questions about products or services, sending postal mail, emails and text messages, carrying out research, analysis, providing consultancy, banking, legal, insurance and accounting services and processing card payments. We only choose partners we can trust. We will only pass personal data to them if they have signed a contract that requires them to:
- abide by the requirements of the UK GDPR;
- treat your information as carefully as we would;
- only use the information for the purposes it was supplied (and not for their own purposes or the purposes of any other organisation);
- allow us to carry out checks to ensure they are doing all these things.
8. Keeping your personal information secure
A fundamental requirement for maintaining your privacy is that you keep your passwords confidential, renew them regularly and ensure that they are sufficiently complex to prevent hacking. We also urge you not to share records or submit anything via the confidential messaging function that you wouldn’t want the other user to see.
Information is stored by us on computers and servers located in the UK. However some of the partners we work with may be based outside the UK so their processing of your personal data may involve a transfer of data outside the UK.
Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
- Where we use certain service providers, we may use specific contracts approved by the UK which give personal data the same protection it has in the UK.
We place great importance on the security of all personally identifiable information associated with people who use our Services. We have security measures in place to attempt to protect against the loss, misuse and alteration of personal information under our control. While we cannot ensure or guarantee that loss, misuse or alteration of data will not occur while it is under our control, we use our best efforts to try to prevent it.
We use the Secure Sockets Layer (SSL) protocol to protect information being transmitted over the internet. SSL provides communications privacy which allows your computer to communicate with our server in a way that is designed to prevent tampering or message forgery.
We use the automatic encryption of data at rest to encrypt your information in the database.
Unfortunately, the transmission of information across the internet is not completely secure and whilst we do our best to try to protect the security of your information, by encrypting it, we cannot ensure or guarantee that loss, misuse or alteration of data will not occur whilst data is being transferred. We will take all reasonable care to keep the details of your personal information secure but unless we have been negligent, we will not be liable for any losses you may suffer as a result of unauthorised access by a third party to the information transmitted by you when using any of our Services.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.
- We will keep your information only for as long as we need it to provide you with the Services or information you have requested, to administer your relationship with us, to comply with the law, or to ensure we do not communicate with people that have asked us not to.
- We will delete your information, including all of Your Records and messaging, from our database 28 days after your account is closed. You will be notified of impending deletion. Stripe retains information about account transactions, to which we have access, including payee name, address, date and description of the transaction, for 3 years.
- In the event that you do not use the Services for a period of 12 consecutive months then we will treat the account as expired and you will be notified of its impending deletion.
10. What we don’t do with your personal information
We never sell or share your information to other organisations, to use for their own purposes.
11. Your rights
In certain circumstances data protection laws give you rights over your personal information and how we use it. These include the right to:
- Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- 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. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. 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.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
(a) if you want us to establish the data’s accuracy;
(b) where our use of the data is unlawful but you do not want us to erase it;
(c) 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; or
(d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- 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. 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.
- 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 withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
- If you wish to exercise any of these rights please contact our Data Protection Manager, Dr George Hibbert at firstname.lastname@example.org.
- For more information about your rights under the Data Protection Act and GDPR go to the website of the Information Commissioner’s Office at ico.org.uk
13. Changes to this policy
- 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 our relationship with you.
14. If you have a complaint
If you have a complaint regarding our use of your personal information please contact our Data Protection Manager, Dr George Hibbert at email@example.com or you can go to the website of the Information Commissioner!s Office at ico.org.uk or write to them at Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF or phone them on 0303 123 1113.