Privacy Policy

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This document is the privacy notice for the Uhura Solutions website and user portal that can be accessed through a web or mobile browser.
We use the capitalised term “Uhura Solutions” to refer to this service in our privacy notice.
The privacy notice sets out the details relating to the processing of personal data via Uhura Solutions.
This privacy notice forms a part of and should be read in conjunction with our Terms of Use, which can be found on our website https://uhurasolutions.com
This Privacy Notice (together with the documents referred to in it) sets out the basis on which any personal data we collect from you, or that you provide to us through Uhura Solutions, 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.

About this notice

We respect your privacy and we are committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website and use Uhura Solutions (regardless of where you are a registered account user or not) and tells you about your privacy rights and how the law protects you.
This notice applies to all users of Uhura Solutions and visitors to our website https://uhurasolutions.com. By using Uhura Solutions or visiting our website, you will be deemed to have agreed to the terms set out in the privacy notice.
In this policy, we set out the details of:
• When we act as a data processor and when we act as a data controller;
• The basis upon which we process your personal data
• Your data rights if your personal data is processed via the service;
• Details of third-party services which may also process Personal Data. We regularly review and where necessary update this Privacy Notice. We will inform you of updates with either an email to you or notification on Uhura Solutions website before we start processing personal information for any new purpose.

About us

Uhura Solutions is owned by Uhura Solutions Limited. We are a company registered in England with the company number 11411236 and our registered office is at Devonshire House, 60 Goswell Rd, London EC1M 7AD, United Kingdom. When this Privacy notice refers to “we” or “us” or “our”, it is referring to Uhura Solutions Limited.

Data controller

For the purposes of data protection Uhura Solutions Limited is designated Data Controller.
Devonshire House, 60 Goswell Rd, London EC1M 7AD, United Kingdom.
Contact email: info@uhurasolutions.com

What is personal information?

Personal data relates to a living individual who can be identified from that data. Identification can be by the information alone or in conjunction with any other information in our possession or likely to come into such possession. The processing of personal data is governed by the General Data Protection Regulation 2016/679 (the “GDPR”).

How do we collect personal information?

We collect personal information when you use Uhura Solutions, visit our website, access our user portal or contact us for information about Uhura Solutions.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us. We use different methods to collect data from and about you including through:
Direct interactions. You may give us your identity and contact information by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
• apply for our products or services;
• create an user account via our website;
• subscribe to our service or publications;
• request marketing to be sent to you; or
• give us some feedback.
Automated technologies or interactions. As you interact with Uhura Solutions, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy below for further details.

What categories of information is collected from you?

We collect personal information that you give us. Personal information means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
This is information that you provide when you fill out webforms, set up an account, or otherwise communicate with us. The Personal Information we collect from you can include your name, email address and/or mobile number.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
• Contact Data includes address, email address and telephone numbers.
• Profile Data includes your username and password, feedback and survey responses.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
We also collect personal information from you. When you use Uhura Solutions we collect personal information from you that is required by us to provide security measures. Without this information we cannot provide the security controls that may be required to protect our intellectual property.
We track when you access content and depending on the security controls used by you or the person sending you the Content includes:
• Technical Data includes internet protocol (IP) address, your unique media access control address (MAC Address), your login data, browser type and version, time zone setting and location data, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website, unique device identifiers.
• Usage Data includes information about how you use our website, products and services.
Aggregated Data:
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you such as Uhura Solutions Terms of Use and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services) or provide the Push for Service. In this case, we may have to cancel Uhura Solutions service you have with us but we will notify you if this is the case at the time.

What is the purpose and lawful basis for processing personal data?

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
• Where we need to perform the contract we are about to enter into or have entered into with you in relation to providing Uhura Solutions to you under the Terms of Use.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new customer	(a) Identity (b) Contact	Performance of a contract with you
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to partake in a prize draw, competition or complete a survey	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and Uhura Solutions (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, provision of Uhura Solutions, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	(a) Technical (b) Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website and Uhura Solutions updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile	Necessary for our legitimate interests (to develop our products/services and grow our business)

Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have filled in a webform on our website i.e. requested/subscribed to information from us or if you provided us with your details when you entered a competition or registered for a promotion. In each case, you have not opted out of receiving that marketing.
Third-party marketing
We will get your express opt-in consent before we share your personal data with any company outside of Uhura Solutions for marketing purposes.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions. Recipients of personal data We may share your personal data with third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We do not share your Personal Data that we collect from your use of Uhura Solutions with any third parties except where required under court order. We will notify you of the instances where your personal data may be shared with third parties under a court order unless we are not permitted from doing so.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. Retention period of personal information We hold your personal data for the duration that you hold and use an account on Uhura Solutions unless you delete that information using your account dashboard.
Where you hold an account but subsequently stop using Uhura Solutions, we will continue to hold your personal data for a period of 24 months. We will notify you by email that we hold your personal information and if you do not notify us that you wish to retain your account, then your personal information and account will be deleted within 2 months from our notification to you.
Where you are a paid user of Uhura Solutions, then we will continue to hold your personal information on Uhura Solutions until you end your license period, following which we will provide you with an opportunity to either delete your account, or to become a free user, in which case we will continue to hold your personal information until the instances set out above.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
We keep basic information about our paid users after their cease being paid users for the purposes of our financial records and tax purposes where required by law. Your data subject rights Unless an exemption applies under applicable law, you have the following rights with respect your personal information.
1. RIGHT TO BE INFORMED
This Privacy Notice sets out the information relating to our processing of Personal Information. We make this notice available to all users of Uhura Solutions and require users to acknowledge that they have read the Privacy Notice before they set up a use an account or before the access the User Portal if they are a not a registered user.
2. RIGHT OF ACCESS
You have the right to obtain confirmation that your personal data is being processed and access to your personal information so that you can be aware of and verify the lawfulness of the processing. We also provide you with access to this Privacy Notice via our website.
The information will be provided free of charge unless we consider a request to be manifestly unfounded, excessive or if it is repetitive and in which cases we may charge a reasonable fee. We may also charge a reasonable fee to comply with requests for any further copies of the same information.
Our fee will be based on the administrative cost of providing the information.
3. RIGHT OF RECTIFICATION
If you require your personal information that we hold on you to be corrected or completed (if it is incomplete) then you can do so via [detail needs to be set out].
If we consider that a requires is manifestly unfounded or excessive, then we reserve the right to request a reasonable fee to deal with your request or we may refuse to deal with the request. We will provide you with a justification of our decision in these circumstances.
4. RIGHT TO ERASURE
In certain circumstances you have the right to have your personal data erased. These rights exist where:
• Your personal data is no longer necessary for the purpose which we originally collected or processed it for;
• You withdraw your consent where your consent is the lawful basis for our holding the personal data;
• If we rely on a legitimate interest to process your personal data but you subsequently object to that basis and there is no overriding legitimate interest to continue the processing;
• You object to the processing of your personal data for direct marketing by us;
• We process your personal data unlawfully; or
• We are required to delete the data to comply with a legal obligation
The right to have your personal data erased is subject to:
• to exercise the right of freedom of expression and information;
• to comply with a legal obligation;
• for the performance of a task carried out in the public interest or in the exercise of official authority;
• for archiving purposes in the public interest, scientific research historical research or statistical purposes where erasure is likely to render impossible or seriously impair the achievement of that processing; or
• for the establishment, exercise or defence of legal claims.
We reserve the right to not comply with a request if we consider it manifestly unfounded or excessive or to request a reasonable fee to deal with the request.
5. RIGHT TO RESTRICT PROCESSING
If you challenge the accuracy of the personal information we hold on you and you have asked us to rectify it, then you may also request us to restrict the processing whilst we consider your rectification request.
If you object to the processing of your personal data by us, then you may also request us to restrict the processing whilst we consider your objection request.
6. RIGHT TO DATA PORTABILITY
The right to data portability applies:
• to personal data an individual has provided;
• where the processing is based on the individual’s consent or for the performance of a contract; and
• when processing is carried out by automated means.
7. RIGHT TO OBJECT
You have the right to object to:
• processing based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling);
• direct marketing (including profiling); and
• processing for purposes of scientific/historical research and statistics.
8. YOUR RIGHT TO LODGE A COMPLAINT WITH A SUPERVISORY AUTHORITY
You have the right to issue a complaint regarding our processing of your personal information at the UK Information Commissioners Office on 0303 123 1113 or online via https://ico.org.uk/concerns/ or in writing to Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.
We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Cookie policy

Like many websites, we use “cookies” when you visit our Website. For details of cookies we use and how they are used, see our Cookies Policy.

Definitions and legal references

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Personal Data (or Data)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.

User
The individual using this Application who, unless otherwise specified, coincides with the Data Subject.

Data Subject
The natural person to whom the Personal Data refers.

Data Processor (or Data Supervisor)
The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.

Data Controller (or Owner)
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Application. The Data Controller, unless otherwise specified, is the Owner of this Application.

This Application
The means by which the Personal Data of the User is collected and processed.

Service
The service provided by this Application as described in the relative terms (if available) and on this site/application.

European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.

Cookies
Small sets of data stored in the User’s device.

Last update: 8. June 2020.