Last updated: 2nd July 2020
We, Unilink Software Limited, are committed to safeguarding the privacy of our users; this policy 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. By using our services, you are accepting and consenting to the practices described in this policy. By providing any personal information to us, you fully understand and clearly consent to such use and transfers as set out in this policy. For the purpose of the Data Protection Legislation (which includes the Data Protection Act 1998 or, from the date it comes into force, the General Data Protection Regulation (Regulation (EU) 2016/679))(GDPR), we are the Data Controller and our address is Europoint House, 5 -11 Lavington Street, London, SE1 0NZ. You can contact our Data Protection department at: email@example.com. We will only process your personal data in accordance with this policy and in accordance with the Data Protection Legislation.
1. What information do we collect? We may collect, store and use the following kinds of personal data:
a. Information about your computer and about your visits to and use of our site, such as your IP address, geographical location, browser type, referral source, length of visit and number of page views.
b. Information relating to any transactions carried out between you and us on or in relation to our site, including information relating to any purchases you make of our services.
c. Information that you provide to us for the purpose of registering with us, which may include your name, e-mail address, address, phone number and financial and credit/debit card information.
d. Information that you provide to us by using our services, such as information about your number, location, message content, photographs, face and ID scans for Video Sessions, call logs, length of call and telephone numbers.
e. Any other information that you choose to send to us.
2. How do we use the information we hold about you?
Information you give to us. We will use this information to:
a. Supply the services to you in accordance with any contract which we have with you;
b. Process your transaction and your payment for the services;
c. Provide you with the information and services that you request from us and, if you agreed to this during the order process, to give you information about similar services that we provide;
d. Provide you with information about services we feel may interest you. If you are an existing customer, we will only contact you by e-mail with information about services similar to those which were the subject of a previous sale to you.
e. Notify you about changes to our service; and
f. Ensure that content from our site is presented in the most effective manner for you and for your computer.
g. Fulfil any request by the Prison Service, Justice Department and associated bodies.
Information we collect about you. We will use this information to:
a. Administer our site, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
b. Improve your browsing experience by personalising our site.
c. Enable your use of the services available on our site.
d. Supply to you services purchased via our site.
e. Send statements and invoices to you and, collect payments from you.
f. Send you general commercial communications about goods or services that may interest you.
g. Send you email notifications which you have specifically requested.
h. Provide third parties with statistical information about our users but this information will not be used to identify any individual user.
i. Deal with enquiries and complaints made by or about you relating to our site.
j. Fulfil any request by the Prison Service, Justice Department and associated bodies.
We will not without your express consent provide your personal information to any third parties for the purpose of direct marketing products or services other than ours.
3. Other disclosures
a. To the extent that we are required to do so by law.
b. In connection with any legal proceedings or prospective legal proceedings.
c. In order to establish, exercise or defend our legal rights including but not limited to providing information to others for the purposes of fraud prevention and reducing credit risk.
4. Security of your personal data
We will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information. We will store all the personal information you provide on our secure servers.
5. Do we share your personal data with third parties?
We may share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so. We may transfer your data to third parties operating or managing the website on our behalf, including to countries outside of the EU (see section below). By submitting your personal data, you agree to this processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this policy.
Where we have given you or where you have chosen a password which enables you to access your account, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Transferring information outside the EU
We may transfer the personal information we collect about you outside of the EU. For neatPhone services, we may transfer information to the USA in order to perform our contract with you. The third-party service provider is registered with the US Privacy Shield. This means that the USA has been deemed by the European Commission to provide an adequate level of protection for your personal information.
6. Changes to this policy
This policy may be updated from time to time, so you may wish to check it each time you submit personal information to our site. The date of the most recent revisions will appear on this page. If you do not agree to these changes, please do not continue to use our site to submit personal information. If material changes are made to this policy, we will notify you by placing a prominent notice on our site.
7. Your rights
Under the Data Processing Legislation:
- You have the right to request us to stop processing your personal data in accordance with this policy at any time. If you make such a request, your ability to use the services will cease.
- You have the right to ask us not to process your personal data for marketing purposes (including profiling). We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes.
- If you become aware of any inaccuracies in your personal data which we process on your behalf or such personal data is incomplete, you have a right to request that such inaccuracies are rectified. On receiving your request we will either action such request or explain why we have decided not to action such request.
- If it is no longer necessary for us to retain your personal data (e.g. You no longer require access to our site, or your messages are more than thirteen (13) months old), or if you have withdrawn consent for our processing of your personal data, or where it is established that we did not have the right to process your personal data, in accordance with the GDPR, you may have your personal data erased. As explained above, if your personal data is erased, your ability to place any orders from our site will end.
- You may also have a right under the GDPR to object to us processing your personal data or to request a restriction on the ways in which we may process your personal data in certain circumstances.
- You have the right under the GDPR to request that we provide to you, or to another data controller on your behalf, a copy of any of your personal data which we have received from you so that may reuse such personal data for your own purposes across different services.
- You have the right to complain to the information commissioner (http://www.ico.gov.uk/) if you have any concerns in respect of the handling of your personal data by us.
If you would like to exercise any of the above rights, please contact us at firstname.lastname@example.org.
8. Access to information
The Data Protection Legislation gives you the right to access information held about you. Your right of access can be exercised in accordance with the Data Protection Legislation. You can submit a data access request at any time by contacting us at email@example.com Provision of such information may be subject to the payment of a fee (if we consider your request to be excessive or manifestly unfounded).
9. Third party websites Our site contains links to other sites. These third-party websites have their own privacy policies, including cookies. We do not accept any responsibility or liability for the policies of such third-party websites and your use of such websites is at your own risk. Please check these policies before you submit any personal data to these websites.
10. What is a cookie? A cookie is a text-only file that is placed on your computer by another computer on the internet to enable that computer to know when you are visiting a particular site. They are widely used in order to make sites work, or work more efficiently, as well as to provide information to our site owners. Most web browsers allow some control of most cookies through the browser settings. Please be aware that if you decline to accept cookies, it may prevent you from taking full advantage of our site.
12. What cookies do we use? Our site uses:
Functionality cookies. These cookies are used to recognise you when you return to our site. This enables us to personalise our content for you, greet you by name and remember your preferences.
Strictly necessary cookies. These are cookies that are required for the operation of our site. They include, for example, cookies that enable you to log into secure areas of our site, use a shopping cart or make use of e-billing services.
Google analytics / performance cookies. These allow us to recognise and count the number of visitors, to see how visitors move around our website when they are using it, provides us with information about the type of browser they are using, device and remembers if users have closed our pop-up information. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer.