ITC Service's Privacy Policy

ITC Service Limited (hereon in referred to as “we”, “us” or “our”) are committed to protecting and respecting your privacy. This privacy policy (the “policy”) (together with our terms of use and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

For the purpose of the UK data protection legislation, the data controller is ITC Service LIMITED. Our data protection lead is responsible for overseeing questions in relation to this policy. If you have any questions about this policy, including any requests to exercise your data protection rights, please contact the data protection lead using the details set out below:

• email address: dpo@itcservice.co.uk; and
• postal address: 9 Merchant Court, Monkton Business Park South, Hebburn, NE31 2EX.
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Personal data

Under Article 4 of the UK General Data Protection Regulation (“UK GDPR”) personal data is defined as:

“Any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.

The personal data we collect about you

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data including first name, surname and identification documents (for example passport, driving licence and utility bill);
• Contact Data including email addresses and phone number;
• Technical Data including internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types ad versions, operating system and platform, and other technology on the devices you use to access this website;
• Usage Data including information about how your use our website, products and services;
• Profile Data including job title and relevant place of work; and
• Marketing and Communications Data including your preferences in receiving marketing from us and our third parties and your communication preferences.

We may collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data under the UK data protection legislation as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this policy.

We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

How we collect your information

We collect your personal data in the following ways:

• Information that you provide by filling in forms on our website. This includes information provided at the time of registering to use our website, subscribing to our service, posting material on our social media channels or requesting further services. We may also ask you for information when you enter a competition or promotion sponsored by us, and when you report a problem with our website.

• If you contact us, we may keep a record of that correspondence.

• We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.

• Details of transactions you carry out through our website and of the fulfilment of your orders.

• Details of your visits to our website including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.

• Information collated for your organisation if your access to our training suite or suites has been provided by your employer or a charity who you provide voluntary support for.

We will receive personal data about you from various third parties and public sources as set out below:

• analytics providers, advertising networks and search information providers including, but not limited to, Google based outside the UK;
• social media platform providers such as X, LinkedIn and Facebook; and
• publicly available sources such as Companies House and the Electoral Register based inside the UK.

Cookies

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. For detailed information on the cookies we use and the purposes for which we use them see our Cookie policy which can be found here.

Why do we need to collect and store personal data?

In order for us to provide you with effective services and product administration, we need to collect personal data for the following purposes:

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new customer.	(a) Identity (b) Contact	Performance of a contract with your organisation to which you are a point of contact.
To process and deliver your order including: (a) manage payments, fees and charges; and/or (b) collect and recover money owed to us	(a) Identity (b) Contact (e) Marketing and Communications	(a) Performance of a contract with your organisation to which you are a point of contact. (b) Necessary for our legitimate interests (to recover debts due to us). (c) Consent.
To manage our relationship with you which will include: (a) notifying you about changes to our terms or privacy policy; and/or (b) asking you to leave a review or take a survey.	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications	(a) Performance of a contract with your organisation to which you are a point of contact. (b) Necessary to comply with a legal obligation. (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services). (d) Consent.
To enable you to partake in a prize draw, competition or complete a survey.	(a) Identity (b) Contact (c) Usage (d) Profile (e) Marketing and Communications	(a) Performance of a contract with your organisation to which you are a point of contact. (b) Necessary for our legitimate interests (to study how customers use our goods/services, to develop them and grow our business). (c) Consent.
To administer, operate and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications	(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 sale/disposal, acquisition, reorganisation or group restructuring exercise). (b) Necessary to comply with a legal obligation. (c) Consent.
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications	(a) Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy). (b) Consent.
To use data analytics to improve our website, goods/services, marketing, customer relationships and experiences.	(a) Technical (b) Usage	Necessary for our legitimate interests (to define types of customers for our goods and 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	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications	(a) Necessary for our legitimate interests (to develop our goods and services and grow our business). (b) Consent.

In any event, we are committed to ensuring that the information we collect and use is appropriate for this purpose and does not constitute an invasion of your privacy.

In terms of being contacted for marketing purposes, we will contact you for additional consent.

Where we need to collect personal data by law, or under the terms of a contract we have with  your organisation, and you fail to provide that personal data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example to provide you with goods and services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

Will we share you personal data with anyone else?

We may pass your personal data on to third-party service providers contracted to ITC Service Limited in the course of dealing with you (including but not limited to, Microsoft, Usecure, IT Boost, 3CX and HubSpot, ConnectWise and Xero). Any third parties that we may share your personal data with are obliged to keep your details securely, and to use them only to fulfil a service provision you are subscribed to receive. When they no longer need your personal data to fulfil this service, they will dispose of the details in line with our procedures.

We may also disclose your personal data to third parties:

• in the event that we sell, transfer or merge all or parts of our business or assets, buy any business or assets or where we undertake any internal reorganisation or restructuring, we may disclose your personal data to the prospective seller or buyer of such business or assets; or

• if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect the rights, property, or safety of ITC Service LTD, our customers, employees or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

We may use your personal data, or permit selected third parties to use your data, to provide you with information about goods and services which may be of interest to you and we or they may contact you about these by post, email, telephone or otherwise. If you are an existing customer, we will only contact you by electronic means with information about goods and services similar to those which were the subject of a previous sale to you. If you are a new customer, and where we permit selected third parties to use your personal data, we (or they) will contact you by electronic means only if you have consented to this. If you do not want us to use your personal data in this way, or to share your personal on to third parties for marketing purposes, please tick the relevant box situated on the form on which we collect your personal data (the order form or registration form) or contact us to confirm you have withdrawn your consent to this processing.

How will we store and protect your personal data?

We will process (collect, store and use) the information you provide in a manner compatible with the UK data protection legislation. We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary. We may be required to retain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices. Personal data may be held in addition to these periods depending on individual business needs.

We use information held about you in the following ways:

• To ensure that content from our site is presented in the most effective manner for you and for your computer.

• To provide you with information, products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes.

• To carry out our obligations arising from any contracts entered into between you and us.

• To allow you to participate in interactive features of our service when you choose to do so.

• To notify you about changes to our service.

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised 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.

Under what circumstances will we contact you?

Our aim is not to be intrusive, and we undertake not to ask irrelevant or unnecessary questions. Moreover, the information you provide will be subject to rigorous measures and procedures to minimise the risk of unauthorised access or disclosure.

We may contact you:

• in relation to any service that we deliver to your organisation, in order to ensure that we can deliver the services;
• in relation to any correspondence we receive from you or any comment, feedback or complaint you make about our goods or services;
• to invite you to participate in surveys about our services (participation is always voluntary);
• to update you in any changes to our policies and practices; and
• for marketing purposes relating to services we provide.

Your legal rights

Under certain circumstances, you have rights under the UK data protection legislation in relation to your personal data. These include the right to:

• request access to your personal data;
• request correction of your personal data;
• request erasure of your personal data;
• object to processing of your personal data;
• request restriction of processing your personal data;
• request transfer of your personal data; and
• right to withdraw consent.
  
  

If you wish to exercise any of the rights set out above, please contact us.

You also have the right to make a complaint to us regarding our processing of your personal data. In the event you are not happy with the outcome of the complaint, you have the right to make a complaint to the Information Commission (the UK regulator) for data protection issues.