Curveball Solutions UK Ltd Privacy Policy
1. Introduction
Curveball Solutions offer a wide range of managed technology services which can be found on our Services page. These may include, but not limited to: Mobile Phones, Mobile Device Management, Broadband and Internet Connectivity, Cloud Hosted VoIP, Telecommunications, Data Backup, Cyber Security and Application hosting, which is managed under a support contract.
2. Personal data collected
To provide these services to your business in the best possible way and for us to operate effectively, we need to collect and use certain information about you, or individuals who work within your business. We do not need to gather excessive information, but we will collect:
- Your business name and contact details (address, central telephone number, etc);
- Contact details of the individual/s we are liaising with at your business (name, telephone number, email address);
- Any other information an individual from your business chooses to tell us.
You provide some of this data directly, such as when you create an account, administer your organisation’s account, submit an enquiry via our website, meet with a member of our sales and marketing or engineering teams or contact us for technical support.
We may also get collect data by recording how you interact with our products by, for example, using technologies like cookies (see below regarding cookies).
3. Cookies and IP Address Tracking
Our website uses “cookies”, small text files that can be read by a web server in the domain that put the cookie on your hard drive. We may use cookies to store your preferences, settings and analyse site operations. For further information visit www.aboutcookies.org or www.allaboutcookies.org.
You can set your browser to not accept cookies and the above websites tell you how to remove cookies from your browser. However, a cookie consent notice on the website provides users with the knowledge of active cookies.
We also use IP Tracking to monitor businesses and organisations that visit our website. The information we receive from this service contains no personal information.
4. What we use your personal data for and the legal basis we rely on
Curveball Solutions use the data we collect to operate our business and provide you with the products and services we offer, which includes using data to improve our services and personalise your experiences. We also may use the data to communicate with you, for example, informing you about your account, security updates and new product information. We may also use and retain your data to assist our sales cycle (i.e. Financial Information or Credit Reference Agencies).
The legal basis we rely on are:
Contractual obligation (GDPR Article 6(1)(b))
The services we provide to you are done so under contract. If you are unable to provide us with the required information to fulfil the contract, we may not be able to provide the service to you and the arrangement may be terminated.
Legitimate interests (GDPR Article 6(1)(f)
GDPR allows us to use legitimate interests for direct marketing purposes. We will undertake a legitimate interest assessment, which balances our business purposes for the processing against your right to privacy, and the final outcome justifies our use of legitimate interests for this purpose. For customers who have either enquired about our services with a view to purchasing them, or are existing customers using our services, or are lapsed customers who have used our services, it would not be an unreasonable expectation to receive information from us about our services, new products, events and news, etc.
This also complies with e-Privacy laws, currently the Privacy & Electronic Communication Regulations 2003, (which governs how a business can undertake electronic direct marketing) and allows us to use soft opt-in for email marketing for prospective and existing customers.
We always give you the opportunity to object to receiving marketing communications from us, when we first collect your personal data and with every marketing communication thereafter.
You can change your marketing preferences at any time by:
- Clicking on the unsubscribe button in our marketing emails;
- Completing our online contact form stating your marketing preferences for contact or opt out completely;
- Telephone us on 0151 547 4321;
- Write to us at Curveball Solutions, Unit 8, Deacon Park, Moorgate Road, Knowsley, Merseyside, L33 7RX; or
- Email us at datarights@curveballsolutions.com
5. Who we will share your personal data with
Where necessary we share your personal data:
- to complete any transaction or provide any product you have requested or authorised;
- when required by law or to respond to a legal process;
- to protect our customers;
- to protect lives (in the case of lone worker);
- to proactively communicate via legitimate interest;
- to maintain the security of our products; and
- to protect the rights or property of Curveball Solutions.
We share your personal data with:
- affiliates and subsidiaries controlled or associated with Curveball Solutions;
- vendors contracted correctly to work on our behalf;
Curveball Solutions will not sell your data to an unrelated party.
6. How we keep your personal data safe
Curveball Solutions take the security of any personal data that we hold incredibly seriously. Our measures to safeguard your personal data include:
- Encrypting devices and servers where appropriate
- Password access to computers and mobile devices
- Secure premises
- Restricting access to those staff who need to see the information
- Internal policies and procedures on data protection and information security
- Staff training
Where we use third-party businesses to provide our services to you we undertake relevant assessments of their business to establish their level of compliance with GDPR and only use those that provide sufficient guarantees to implement appropriate technical and organisational measures to safeguard personal data.
7. Transferring personal data outside of the UK and EU
Curveball Solutions will not, unless otherwise specifically agreed in writing, transfer any data outside of the UK. All of our hosting, backup and staging servers are based within the UK.
8. Retention of information
Curveball Solutions will retain information for the period that any valid agreement or contract is in place, or until instructed otherwise by a
customer. All personal data will be destroyed or returned to a customer upon request. Sales cycle information or documents required to be retained for legitimate reasons will be retained for a minimum of six years.
9. Your rights
Unless you are a sole trader or a partnership (in certain cases), it will be the individuals who work for your business that have various rights in relation to how we process their personal data. Individuals can:
- access the personal data we keep about them and be given specific information about the processing.
- ask us to update inaccurate personal data we hold about them.
- ask us to delete their personal data but only when specific grounds apply.
- ask us to restrict the processing of their personal data, for example if they are contesting the accuracy of it.
- object to the processing of their personal data if they do not agree with our legitimate interest grounds and for direct marketing purposes.
- transfer personal data from us to another service provider but only when certain grounds apply.
If you would like to:
- object to the processing of your personal data (where we have relied on legitimate interests as our legal basis for the processing);
- or to unsubscribe from future marketing communications
exercise any of your data rights
please email datarights@curveballsolutions.com and we will resolve your request within 30 days.
We would appreciate being updated if any of your personal data changes, to maintain up to date and accurate records.
We do not undertake any solely automated decision-making, including profiling.
If you are not happy with how we have been processing your personal data, or have not dealt with one of your rights correctly when you have asked us to, you may lodge a complaint with the Information Commissioners Office (ICO). The ICO has several ways in which you can get in touch with them, including post, email, and online forms. To find out how click here.
10. Data Protection Officer
We are not legally obliged to appoint a Data Protection Officer. This will be overseen by several members of the team. If you need to get in touch regarding your data rights please email datarights@curveballsolutions.com or in writing to Curveball Solutions, Unit 8, Deacon Park, Moorgate Road, Knowsley, Merseyside, L33 7RX
11. Notice to End Users
Many products and services supplied and managed by Curveball Solutions are intended for use by organisations correctly contracting with us for service, but may be administered for you by your organisation. Your use of these products and services may be subject to your organisation’s policies, if any. If your organisation is administering your use of these products and services, please direct your privacy enquiries to your administrator. Curveball Solutions is not responsible for the privacy or security practices of our customers, which may differ from those set forth in this privacy statement.
If you use an email address provided by an organisation you are affiliated with, such as an employer or school, to our services, the owner of the domain (e.g. your employer) associated with your email address may: (i) control and administer your online services account and (ii) access and process your data, including the contents of your communications and files.
12. Other websites
Our website contains links to other websites. This privacy policy only applies to our website (www.curveballsolutions.com) so when you leave our website to go to other websites you should read their individual privacy policies.