Effective May 24/05/2018
This policy describes what personal information 20Six Ltd (20SIX LTD) collects, why it is collected, and how it is used. It is applicable to personal data and other information collected by 20SIX LTD from or about prospective clients, current clients, and visitors and users of our Websites.
Information Collected By 20SIX LTD
Personal information provided by you
When engaging with 20SIX LTD either through our website or via other means, you may be invited to provide personal information that you may elect to provide. Examples of these engagements include, but are not limited to, filling out a web form to request additional information about our services, completing a survey, asking a question, contacting us through email, providing feedback, or commenting on a blog post. Personal information may also be collected by us when you send us an email, call us on the telephone, send us a text, message us through social media platforms, or any other means you may choose to communicate with us. If you choose to become a 20SIX LTD customer, you will be required to provide some basic personal information for our records. In these interactions with you, 20SIX LTD may collect the following information about you or other members of your organisation that you elect to provide:
Billing and Payment information
Feedback, testimonials, comments and notes that you may provide
Customer support inquiries
Account login credentials
Website visitor information
When you visit our website, Google analytics automatically log data about your visit, including your browser type, operating system, geographic location, the pages you visited, the website that referred you, the date, time and length of your visit and any other data that your browser may have provided. If you choose to provide additional personal information to 20SIX LTD during a visit to our website or by email, your IP address may be used to link this additional personal information to the website visitor data that we collect, which means your website visits may not be anonymous to us. See the “Cookies” section of this policy for additional methods we use to collect website visitor information.
How we use your information
Personal information collected will only be used in a manner consistent within the context it was collected, unless specific and clear consent is given by you to use the data for purposes beyond the original purpose it was collected for.
To provide Services to Clients
Personal information provided directly by Clients is used to provide Services, provide Client support, bill for Services, provide Clients information on using our Service, notify Clients of issues with our service, improve our Service, and keep Clients informed about our service offerings. If Clients choose to provide additional personal information beyond what is required, this information will only be used to enhance the Client’s experience unless the Client provides consent to use the data for other purposes.
To send communications to our Clients
If you are a 20SIX LTD Client, we may occasionally contact you about billing, issues related to your service, and information about new services we offer. In order to stop receiving these communications, you can either let us know in writing via email or letter or cancel your account with us. You may also send a request to firstname.lastname@example.org to be excluded from specific Client communications. Depending on what types of Client communications you want to stop, it may require us to discontinue all outbound communications with you to accomplish your request.
To communicate with prospective clients
lf you have requested information about our services, we may occasionally contact you about our service offerings. If our communication to you was sent by email and an unsubscribe link is not included, you may simply respond with an opt-out request. You may also opt out of telephone calls or other contacts by simply letting us know that you are no longer interested. You may also send a request to email@example.com to opt-out of these communications. Please allow up to 2 business days for us to remove you from our contact lists.
20SIX LTD uses the following technologies to improve your experience and our business:
Disclosure of personal information
20SIX LTD does not disclose your personal information to third parties except in the following cases:
For legal or safety reasons: We reserve the right to disclose personal information if we have reason to believe, in good faith, that one of the following conditions are met: (1) we have a legal obligation to do so, (2) it is necessary to protect our rights, (3) to investigate fraud, (4) in response to lawful requests by public authorities, including to meet national security or law enforcement requirements or (5) it is in the interest of our safety, your safety, or public safety.
PCI compliant payment processors for processing Client payments.
Email services for CRM use.
Co-location facilities. 20SIX LTD’s server hardware is co-located in secure data centers that have implemented strict access controls. Data center personnel are only authorised to access our servers under our direction.
Outsourced hosting. Most of 20SIX LTD’s Services are hosted on hardware that we own, but we do sometimes outsource the hosting of some Services that we provide to meet the needs of our Clients and our business.
Updating or deleting your personal information
You may send a request to firstname.lastname@example.org to update, change or delete your personal information. Requests will be denied if the data in question is required for 20SIX LTD’s financial accounting or legal purposes or where the burden or expense of providing you access would be disproportionate to your privacy risks, or where the rights of other persons would be violated. In addition, 20SIX LTD’s ability to process your request will be subject to our ability to confirm your identity. Requests that are allowed will be processed in a reasonable amount of time, usually less than 3 business days, but no longer than 30 days. Data that is updated or deleted from 20SIX LTD’s live databases may still exist in its original form in our backups. If your personal information was stored on our servers by one of our Clients, where our Client is the data controller and we are only the data processor, we will forward your request to our Client. Our Client’s handling of your request will be subject to any terms of service or contracts that you have with our Client.
20SIX LTD have implemented reasonable measures to protect against unauthorised access of personal information. Examples of methods 20SIX LTD use are:
The use of strong SSL and TLS encryption for the transmission of personal information.
The use of both hardware and software firewalls to protect our servers from unauthorised access.
Providing ongoing training to any employees on the methods and tools 20SIX LTD use to protect your information.
Encryption: FIPS 140-2 Validated 256 bit AES encryption for assured security
20SIX LTD has implemented technical and organisational measures to protect all customer data and ensured the confidentiality, integrity, availability and capacity of the systems and services. All data held by 20SIX LTD is encrypted in an SSL data centre. 20SIX LTD has, in accordance with the GDPR, implemented a procedure for regularly reviewing the technical and organisational measures designed to ensure the security of data processing.
Protection of children
20SIX LTD Website and Services are all directed to people who are at least 13 years old or older. In compliance with the requirements of COPPA (Children’s Online Privacy Protection Act), 20SIX LTD will not knowingly collect data from anyone under 13 years of age.
Links to Third Party websites
20SIX LTD’s website includes links to third party websites. These third-party sites have separate and independent privacy policies. 20SIX LTD therefore have no responsibility or liability for the content and activities of these linked sites. Nonetheless, 20SIX LTD seek to protect the integrity of our site and welcome any feedback about these sites.
Your personal information will not be shared or sold to third parties except as necessary as described in the “Disclosure of personal information” section of this policy. 20SIX LTD offer individuals the opportunity to choose by either providing consent or opting out before their personal information is disclosed to a third party or used for a purpose that is materially different from the purpose for which it was originally collected. Individuals are given clear, conspicuous, and readily available mechanisms to exercise their choice. 20SIX LTD currently do not collect information considered sensitive but if we later decide to do so, 20SIX LTD will obtain affirmative express consent (opt in) from individuals if such information is to be disclosed to a third party or used for a purpose other than those for which it was originally collected. In addition, 20SIX LTD will treat as sensitive any personal information received from a third party where the third party identifies and treats it as sensitive.
Accountability for Onward Transfer
20SIX LTD remains accountable and liable for all onward transfers of personal information to third parties. The type of third parties to which 20SIX LTD disclose personal information to and the purposes for doing so are listed in the “Disclosure of personal information” section under the “Service providers” subheading of this policy.
20SIX LTD take reasonable and appropriate measures to protect personal information from loss, misuse and unauthorised access, disclosure, alteration and destruction. For more information, see the “Data security” section of this policy.
Data Integrity and Purpose Limitation
20SIX LTD limit the personal information collected to that which is relevant to our business and use personal information in a way that is compatible with the purposes for which it has been collected or subsequently authorised by the individual. To the extent necessary for those purposes, 20SIX LTD take reasonable steps to ensure that personal data is reliable for its intended use, accurate, complete, and current. Personal information is retained only for as long as necessary for processing or for statistical analysis or another approved purpose.
Individuals have the right to know what personal information 20SIX LTD are storing about them and to ensure it is accurate and relevant to the purposes for which it was collected. Upon request, 20SIX LTD can provide access to the personal information that is stored about you and, will take reasonable steps to correct, amend, or delete information that is inaccurate, subject to the limitations outlined in the “Updating or deleting your personal information” section of this policy.
Recourse, Enforcement, and Liability
20SIX LTD are committed to resolve your complaints about your privacy and our collection or use of your personal information. If you have a complaint, please contact 20SIX LTD either by email at email@example.com or one of the following methods:
Units 19 & 20, Henfield Business Park
Shoreham Road, Henfield, BN5 9SL
By speaking with a member of staff:
Other Terms and Conditions
Questions or concerns
If you have questions, comments or concerns regarding this policy, please email firstname.lastname@example.org and you will receive a prompt reply, usually within 2 business days. You may also contact 20SIX LTD using the information below:
Units 19 & 20, Henfield Business Park
Shoreham Road, Henfield, BN5 9SL