1. Introduction

Scion Interactive Limited (referred to as “we”, “our” or “us”) understands that your privacy is important to you and that you care about how your personal data is used and shared. We respect and value the privacy of everyone with whom we have business dealings and will only collect and use personal data in ways that are described here, and in a manner that is consistent with our obligations and your rights under the law.

In this Policy, the following terms shall have the following meanings: “personal data”means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to us in the course of our business dealings with you. This definition shall, where applicable, incorporate the definitions provided in the EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”); and “We/Us/Our” means Scion Interactive Limited, a limited company registered in England, whose registered address is Bowman House, Bowman Court, Whitehill Lane, Royal Wootton Bassett, Wiltshire, SN4 7DB.

  1. What does this Policy cover?

This Data Privacy Policy applies only to data which you have provided, or we have obtained from you, in the course of our business dealings with you.

  1. Your rights

As a data subject, you have the following rights under the under the Data Protection Act 1998 and GDPR regulations, which this Policy and our use of personal data have been designed to uphold:

• to be informed about our collection and use of personal data

• to access the personal data we hold about you

• to rectification if any personal data we hold about you is inaccurate or incomplete (please contact us using the details above)

• to be forgotten, meaning the right to ask us to delete any personal data we hold about you (we only hold your personal data for a limited time, but if you would like us to delete it sooner, please contact us using the details above)

• to restrict (i.e. prevent) the processing of your personal data

• to data portability (obtaining a copy of your personal data to re-use with another service or organisation)

• to object to us using your personal data for particular purposes. If you have any cause for complaint about our use of your personal data, please contact Ian Hudson, Managing Director, at the address given above. We will do our best to solve the problem for you. If we are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.

  1. What data do we collect?

We may collect some or all of the following personal data:

• name

• business/company name

• business/company address

• job title

• email address

• telephone numbers including mobile.

  1. How do we use your data?

We use the data for corresponding with you in relation to the provision of our products and services to you. Specifically, we may use your data for the following purposes:

• managing your account with us

• supplying our services to you

• meeting our obligations under the contracts we have with you

• personalising and tailoring our services for you

• replying to emails, phone calls, texts or other electronic communications from you.

We will not send you any unsolicited marketing or spam and will ensure that we fully protect your rights and comply with our obligations under the Privacy and Electronic Communications (EC Directive) Regulations 2003. You have the right to withdraw your consent to us using your personal data at any time, and to request that we delete it. All personal data is processed and stored securely, for no longer than is necessary taking into account the reasons for which it was first collected. We will comply with our obligations and safeguard your rights under the Data Protection Act 1998 and GDPR regulations at all times.

  1. What is our legal basis for processing your data?

Our use of your personal data will always have a lawful basis, either because it is necessary for our performance of a contract with you, because you have consented to our use of your personal data (e.g. by subscribing to emails), or because it is in our legitimate interests.

  1. How and where do we store your data?

To protect your personal data, we take reasonable precautions to make sure it is not inappropriately lost, misused, accessed, disclosed, altered or destroyed. Your data is stored securely on third party servers, including OneDrive and SharePoint, which we access via cloud enabled services. Synchronised copies of these data files are stored on the laptops and mobile devices of our staff. These devices are password protected and staff are made fully aware that personal data must be treated confidentially.

  1. Do we share your data?

We will not share any of your data with any third parties for any purposes, except in so far as third parties are providing data storage, as outlined above. In certain circumstances, we may be legally required to share data held by us, which may include your personal data, if for example we were involved in legal proceedings, or were complying with legal obligations, a court order or a governmental authority.