Privacy Policy

Introduction

This Privacy Policy is provided by Simprints Technology Ltd a company registered in England and Wales under company number: 08835431 with registered office 41 Eden Street, Cambridge, England, CB1 1EL (Simprints, our, we or us) for use of our website www.simprints.com (Website).

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on how and why we collect, store, use and share any information relating to you (your personal data).

It also explains your rights in relation to your personal data and how to contact us or the relevant regulator in the event you have a complaint. Our collection, storage, use and sharing of your personal data is regulated by law, including under the UK General Data Protection Regulation (UK GDPR).

We are the controller of personal data obtained via the Website, meaning we are the organisation legally responsible for deciding how and for what purposes it is used.

What this policy applies to

This privacy policy relates to your use of the Website only.

The Website may link to or rely on other apps, websites, APIs or Website owned and operated by us or by certain trusted third parties to enable us to provide you with the Website. These other apps, websites, APIs or Website may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to these other apps, websites or Website, please consult their privacy policies as appropriate. For more information, see the section ‘Who we share your personal data with’ below.

We may also collect personal data as part of other aspects of our business, including as part of offering products or services, and a separate privacy policy may apply to that collection and use of personal data. Please refer to the terms and conditions at point of service.

Personal data we collect about you

The personal data we collect about you depends on the particular activities carried out through the Website. We will collect and use the following personal data about you:

Category of data: Data collected when you use specific functions on the Website.

In more detail: Data you store online with us using the Website including your usage history or preferences (while such data may not always be personal data as defined in law in all cases we will assume it is and treat it in accordance with this policy as if it were).

Category of data: Data collected when you sign up for our newsletter or marketing emails.

In more detail: Your name and email address.

Category of data: Other data the Website collects automatically when you use it.

In more detail: Your activities on, and use of, the Website which reveal your preferences, interests or manner of use of the Website and the times of use.

Category of data: Data collected when you make an enquiry with us.

In more detail: Your name and email address.

If you do not provide personal data we ask for where it is required it may prevent us from providing parts of the Website and/or our services to you.

We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below.

Sensitive data

Please note that we do not knowingly or intentionally collect sensitive personal data or information about criminal convictions from individuals and that you should not submit sensitive data to us.

Sensitive personal data (also known as special category data) means information related to personal data revealing racial or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; genetic data; biometric data (where used for identification purposes); data concerning health; data concerning a person’s sex life; and data concerning a person’s sexual orientation.

If, however you do submit sensitive data to us, such as if you make this sensitive data available to other users of the Website (such as by publishing it through any comments feature we may make available from time to time) we will assume that you have purposely made any such sensitive data manifestly public.

How your personal data is collected

We collect personal data from you directly when you contact us directly or reach out to us via social media, make submissions via the Website when a forum element is available, or indirectly, such as your activity while using the Website.

We may also collect personal information about you using cookies or similar technologies. You can find more detailed information regarding our use of cookies and similar technologies in our Cookies policy.

How and why we use your personal data

Under data protection law, we can only use your personal data if we have a proper reason, e.g.:

• where you have given consent
• to comply with our legal and regulatory obligations
• for the performance of a contract with you or to take steps at your request before entering into a contract; or
• for our legitimate interests or those of a third party.

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You can obtain details of this assessment by contacting us (see ‘How to contact us’ below).

The information below explains what we use your personal data for and why.

What we use your personal data for: Providing Website and/or the functionalities of the Website to you.

Our reasons:

• for our legitimate interest to provide you with the Website;
• to perform our contract with you or to take steps at your request before entering into a contract.

What we use your personal data for: To provide you with our newsletter.

Our reasons:

• for our legitimate interest to provide you with the newsletter;
• to perform our contract with you or to take steps at your request before entering into a contract.

What we use your personal data for: To enforce legal rights or defend or undertake legal proceedings.

Our reasons:

Depending on the circumstances:

• to comply with our legal and regulatory obligations,
• in other cases, for our legitimate interests or those of a third party, i.e. to protect our business, interests and rights or those of others.

What we use your personal data for: Communications with you not related to marketing, including about changes to our terms or policies or changes to the Website or service or other important notices.

Our reasons:

Depending on the circumstances:

• to comply with our legal and regulatory obligations;
• in other cases, for our legitimate interests or those of a third party, i.e., to provide the best service to you.

What we use your personal data for: Protect the security of systems and data.

Our reasons:

To comply with our legal and regulatory obligations, we may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests or those of a third party, i.e., to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us.

What we use your personal data for: Operational reasons, such as improving efficiency, training, and quality control or to provide support to you.

Our reasons:

For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service to you.

What we use your personal data for: Statistical analysis to help us manage our business, e.g., in relation to our performance, customer base, app and functionalities and offerings or other efficiency measures.

Our reasons:

For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service to you and improve and develop our app.

What we use your personal data for: Updating and enhancing user records.

Our reasons:

Depending on the circumstances:

• to perform our contract with you or to take steps at your request before entering into a contract;
• to comply with our legal and regulatory obligations;
• where neither of the above apply, for our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about their accounts and new products or functionalities related to the Website and our Website.

What we use your personal data for: To comply with our legal and regulatory obligations.

Our reasons:

Depending on the circumstances:

• to perform our contract with you or to take steps at your request before entering into a contract (in this case, the contract means the Terms and Conditions of Use which apply to the Website);
• to comply with our legal and regulatory obligations.

Where neither of the above apply, for our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about their accounts and new products or functionalities related to the Website and our Website.

What we use your personal data for: To share your personal data with members of our group and third parties in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency. In such cases, information will be anonymised where possible and only shared where necessary

Our reasons:

Depending on the circumstances:

• to comply with our legal and regulatory obligations;
• in other cases, for our legitimate interests or those of a third party, i.e., to protect, realise or grow the value in our business and assets.
  

See ‘Who we share your personal data with’ for further information on the steps we will take to protect your personal data where we need to share it with others.

Marketing

We intend to send you email marketing to inform you of our Website such as important updates.

We will always ask you for your consent before sending you marketing communications, except where you have explicitly opted-in to receiving email marketing from us in the past or except where you were given the option to opt out of email marketing when you initially signed up for your account with us, and you did not do so.

You will have the right to opt out of receiving marketing communications at any time by:

• contacting us at [email protected];
• using the ‘unsubscribe’ link included in all marketing emails you may receive from us.

We will always treat your personal data with the utmost respect and never sell or share it with other organisations for marketing purposes.

For more information on your right to object at any time to your personal data being used for marketing purposes, see ‘Your rights’ below.

Who we share your personal data with

We routinely share personal data with service providers we use to help us run our business or provide the Website or functionalities in the Website, including developers, cloud storage providers and Google, Inc. for Google Analytics functionality. We exert no control over Google’s Privacy Policy, and we, therefore, recommend that you consult their privacy policy for further information on how Google protects personal data – https://policies.google.com/privacy?hl=en-US. 

We use the following processors to handle personal data collected through the website:

• Google Workspace to manage customer records and communicate with them;
• Salesforce to manage our customer records – their privacy policy is available here: https://www.salesforce.com/uk/company/privacy/;
• Mailchimp to manage our email communications – their privacy policy is available here: www.mailchimp.com/en/legal/.

We only allow service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers to ensure they can only use your personal data to provide the Website to us and to you. 

We, or the third parties mentioned above, may occasionally also need to share your personal data with:

• other legal entities owned by or working on behalf of Simprints who will have entered into a data processing agreement with us;
• external auditors, e.g. in relation to the audit of our accounts and our company – the recipient of the information will be bound by confidentiality obligations;
• professional advisors (such as lawyers and other advisors) – the recipient of the information will be bound by confidentiality obligations;
• law enforcement agencies, courts or tribunals and regulatory bodies to comply with legal and regulatory obligations;
• other parties in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency – usually, information will be anonymised but this may not always be possible, however, the recipient of the information will be bound by confidentiality obligations.

If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).

We will not share your personal data with any other third party.

How long your personal data will be kept

We will keep your personal data for as long as you have an active account with us and for a period of up to seven years thereafter to comply with any accounting or legal obligations including in the event of the pursuit or defence of legal claims. Once you have closed your account with us, we will move your personal data to a separate database so that only key stakeholders in our business on a ‘need-to-know basis’ have access to such data.

Following the end of the aforementioned retention period, we will delete or anonymise your personal data.

Transferring your personal data out of the UK

Simprints may transfer your data outside of the UK to processors set out in the above section ‘Who we share your personal data with’ including our subsidiaries, or other legal entities owned by or working on behalf of Simprints. Where we do this, we will comply with applicable UK laws designed to ensure the continued protection and privacy of your personal data. Any updated destinations to which we send your personal data, would be indicated in the present section and notified to you in accordance with the section on ‘Changes to this privacy policy’ below.

Furthermore, under UK data protection laws, we can only transfer your personal data to a country outside the UK where: the UK government has decided the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy regulation’) further to Article 45 of the UK GDPR; there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you; or a specific exception applies under relevant data protection law. Accordingly, if we were to start transferring your personal data from the UK to:  

• the EEA: we would rely on the adequacy finding granted by the UK to the EU under the Withdrawal Agreement to do; for any transfers from the EU to the UK, we would rely on the adequacy regulation granted to the UK under the Adequacy Decision; 
• any country located outside the UK/EEA: we would rely on appropriate safeguards under the UK GDPR, such as by including the relevant Standard Contractual Clauses in our data processing agreements.

In the event we could not, or choose not to, continue to rely on either of those mechanisms at any time, we would not transfer your personal data outside the UK unless we could do so on the basis of an alternative mechanism or exception provided by UK data protection law.

Your rights

You generally have the following rights, which you can usually exercise free of charge. For more information regarding these rights, please visit the UK  Information Commissioner’s Office’s (ICO) website here.

Access to a copy of your personal data: The right to be provided with a copy of your personal data.

Correction (also known as rectification): The right to require us to correct any mistakes in your personal data.

Erasure (also known as the right to be forgotten): The right to require us to delete your personal data – in certain situations.

Restriction of use: The right to require us to restrict use of your personal data in certain circumstances, e.g. if you contest the accuracy of the data.

Data portability: The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party – in certain situations.

To object to use: The right to object:

• at any time to your personal data being used for direct marketing (including profiling);
• in certain other situations to our continued use of your personal data, e.g. where we use your personal data for our legitimate interests.

Not to be subject to decisions without human involvement: The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you. Please note that we do not make any such decisions based on data collected by the Website.

For further information on each of those rights, including the circumstances in which they do and do not apply, please contact us (see How to contact us below). You may also find it helpful to refer to the guidance from the UK’s Information Commissioner’s Office on your rights under the UK GDPR. 

If you would like to exercise any of those rights, please email [email protected]. When contacting us, please:

• provide enough information to identify yourself (e.g., your full name and username) and any additional identity information we may reasonably request from you; and
• let us know which right(s) you want to exercise and the information to which your request relates.

Keeping your personal data secure

We have appropriate security measures to prevent personal data from being accidentally lost, used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. 

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

Changes to this privacy policy

We may change this privacy policy from time to time. When we make significant changes, we will take steps to inform you, for example, via the Website or by other means, such as email.

How to contact us

You can contact us by email if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.

Our contact details are:

• [email protected]