Important Information and Who We Are
Email address: dpo@Locana.co
Postal address: 1430 Summit Ave Suite 100C, Seattle, WA 98122
Right to Make a Complaint
Individuals in the UK have the right to make a complaint at any time to the Information Commissioner’s Office (“ICO”), the UK supervisory authority 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.
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.
The Data We Collect About You
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:
- Identity Data includes your name and title, the name of your employer, your job title, and the location of your office;
- Contact Data includes your email address and telephone number and the address of your office;
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our website;
- Usage Data includes information about how you use our website and services; and
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
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 a contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.
How is your personal data collected?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity and Contact by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- receive or request services from us;
- subscribe to our service or publications;
- request marketing to be sent to you; and
- give us feedback or contact us;
- Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below.
- Partner organizations
- Publicly Available Social Media Platforms
- Location-enabled (IP Address) web marketing platforms (https://www.hubspot.com)
How We Use Your Personal Data
In situations where UK/EEA Data Protection Laws apply, we will only use your personal data when UK/EU Data Protection Laws allow us to. Most commonly, we will use your personal data where:
- we need to perform a contract we are about to enter into or have entered into with you or the organization you work for;
- it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; and/or
- we need to comply with a legal obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data in the UK or EEA. You may withdraw consent to receiving marketing information from us at any time by contacting us.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use 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.
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.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To provide services to you or the organization you work for||
(a) Performance of a contract with you or the organization you work for
(b) Necessary for our legitimate interests in conducting our business
To manage our relationship with you which will include:
(b) responding to communications with you
(c) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to communicate with our customers and suppliers, keep our records updated and to study how customers use our services)
|To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise)
(b) Necessary to comply with a legal obligation
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||
(d) Marketing and Communications
|Necessary for our legitimate interests (to study how customers use our services, to develop them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences||
|Necessary for our legitimate interests (to define types of customers for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
|To make suggestions and recommendations to you about goods or services that may be of interest to you||
(e) Marketing and Communications
|Necessary for our legitimate interests (to develop our products/services and grow our business)|
We may send marketing communications to you if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.
Where you are based in the UK or EEA, we will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time via firstname.lastname@example.org.
Change of Purpose
Where UK/EEA Data Protection Laws apply:
- we will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us; and
- if we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Disclosures of Your Personal Data
We may share personal data which is covered by UK/EEA Data Protection Laws with the parties set out below for the purposes set out in the table above.
Internal Third Parties: other companies in the Locana Group acting as joint controllers or processors and who are based in the U.S. and UK and provide HR, IT and system administration services and undertake leadership reporting.
- Service providers acting as processors] based in U.S. and UK who provide IT and system administration services.
- Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in United Kingdom and United States who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
- Specific third parties such as https://www.hubspot.com.
Where UK/EEA Data Protection Laws apply, we require all third parties to respect the security of your personal data and to treat it in accordance with the law; and we do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We may share your personal data within the Locana Group. This will involve transferring your data outside the UK.
Many of our external suppliers and third-party business partners are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.
Whenever we transfer personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring that:
- the transfer is to one of the countries that have been deemed to provide an adequate level of protection for personal data by the UK ICO; or
- we use specific contracts approved by the UK ICO (which may be those approved by the European Commission) which give personal data the same protection it has in the UK.
Similarly, we comply with European laws to the extent that they apply in relation to international data transfers. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK or EEA.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
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.
How long will you use my personal data?
We will only retain your personal data 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 to 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 unauthorized 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.
By law we have to keep basic information about our customers (including Contact and Identity Data) for up to seven years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see your legal rights below for further information.
In some circumstances we will anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Your Legal Rights If You Are a UK or EEA Resident
If you are resident in the UK or EEA you have the right, under certain circumstances, 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:
- 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; or
- 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; and
- 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.
Your Legal Rights If You Are a State of California Resident
If you are resident in the State of California you have the right, under certain circumstances, to:
- The right to know The California Consumer Privacy Act (CCPA) grants consumers rights to know what personal information a business sells, discloses or collects about them as well as the categories of third parties who purchased or received their data. Consumers have the right to request a copy of the data that has been collected from them;
- The right to deletion Under the CCPA, consumers can request that a business delete any of the personal information that has been collected from them;
- The right to opt-out Consumers are given the right to opt-out of the sale of their personal information, and the CCPA prohibits businesses from discriminating against consumers that exercise their opt-out rights;
If you wish to exercise any of the rights set out above, please contact us.
No Fee Usually Required
If you are resident in the UK or EEA you will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What We May Need From You
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.
Time Limit to Respond
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.