Privacy Policy

Customers or visitors to this website are referred to as “you” or “your”. Set3 Solutions Ltd. trading as brand “Set3” is referred to as “us” or “we”.

Set3 Solutions respects your privacy and is committed to protecting your personal data. This Policy will inform you as to how we look after your personal data, including when you visit our website (regardless of where you visit it from), or when you order or use our services, and tells you about your privacy rights and how the law protects you.

Important information and who we are
The data we collect about you
How is your personal data collected
How we use your personal data
Disclosures of your personal data
International transfers
Data security
Data retention
Your legal rights
Glossary

1. Important information, and who we are

Purpose of this policy

This Policy aims to give you information on how Set3 Solutions collects and processes your personal data, including through your use of this website, and any data you may provide through this website, or when you contact us or sign up to our newsletters, commission or order a product or service, or take part in a survey.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this Policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Policy supplements the other notices and is not intended to override them.

Controller

set3 Solutions Limited is the controller and responsible for your personal data (collectively referred to as “Set3”, “Set3 Solutions”, “we”, “us” or “our” in this Policy).

If you have any questions about this Policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

Contact details

Our full details are:

Set3 Solutions Limited

Postal address: 4 Kings Court, Harwood Road, Horsham, West Sussex. RH13 5UR

Email address: info@set3.co.uk

Telephone number: 01403 588898

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the policy and your duty to inform us on changes

This version was last updated on 20th November 2020 and may be subject to further revisions.

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.

Third party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

2. The personal data we collect and use

Personal data, or 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).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data includes
First name, maiden name, last name, username or similar identifier, marital status, title and gender.
Contact Data includes
A billing address, delivery address, email address and telephone numbers, and any social media accounts used to contact us.
Financial Data includes
Bank account details.
Transaction Data includes
Details about payments to and from you and other details of products and services you have ordered or commissioned from us.
Technical Data includes
Internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website or use one of our services.
Profile Data includes
Any username and password to access our systems, commissions or orders made by you, your interests, preferences, feedback and survey responses.
Usage Data includes
Information about how you use our website, products and services.
Marketing and Communications Data includes
Your preferences in receiving marketing from us and our third parties made known to you and your communication preferences.

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 Policy.

Except in limited circumstances, for example where it is volunteered by set3 employees or sub-contractors, 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.

If you give us information about another person, you confirm that the other person has consented to the processing of their personal data, receipt of any data protection notices and consent to the transfer of personal data outside the UK and EEA on their behalf.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions
You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email, social media or otherwise.

Commission or order for our products or services
For example, by telephone, email or via our websites;
- Create an account on our website or on one of our systems;
- Subscribe to our publications;
- Request marketing to be sent to you;
- Enter a competition, promotion or survey;
- Make a general enquiry about our products or services; or
- Give us feedback.

Automated technologies or interactions
As you interact with our website or social media accounts, 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. Please see our Cookie Policy for further details.

Third parties or publicly available sources
We may receive personal data about you from various third parties and public sources.

Personal Data from our suppliers, distributors and vendors

Technical Data
From the following parties:
- analytics providers such as Google;
- advertising networks, such as GoogleAds or Facebook; and
- search information providers, such as Google.

Contact, Financial and Transaction Data from providers of technical, payment and delivery services
Such as Creditsafe, based inside or outside the EU, and HM Revenue & Customs (HMRC).

Identity and Contact Data from publicly available sources
Such as Companies House and the Electoral Register based inside the EU.

4. How we use your 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.

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 you marketing or third-party direct marketing communications via email or text message. You have the right to withdraw consent to marketing at any time by Contacting us or by clicking ‘unsubscribe’ in any communication you receive from us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity	Type of data	Lawful basis for processing including the basis of legitimate interest
To register you as a new customer or account holder	(a) Identity (b) Contact	Performance of a contract with you
To process and deliver a service or order including: (a) Manage payments, fees and charges (b) Pass your details to suppliers or government bodies which is necessary to perform our services. (c) Collect and recover money owed to us. (d) Perform a credit check	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (for tax and legal liability purposes, or to recover debts due to us) (c) Necessary to comply with a legal obligation.
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) If you are an employee of or sub-contractor to set3 Solutions, or a supplier to us, or have some other form of contractual relationship with us (c) Asking you to leave a review or take a survey	(a) Identity (b) Contact (c) Profile (d) Financial (e) Transaction (f) 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, to comply with our legal and tax obligations, or to study how customers use our products/services)
To enable you to partake in a prize draw, competition or complete a survey	(a) Identit (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 this website, including: (a) troubleshooting (b) data analysis (c) testing (d) system maintenance (e) support (f) reporting (g) 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, 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 deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
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 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	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. We have established the following personal data control mechanisms.

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).

We may send you renewal reminders close to the anniversary of taking up a service or product, and other communications we are obliged to send under a legal or contractual obligation.

You may receive marketing communications from us if you have expressly requested information from us about our services, or purchased goods or services, or made a product or service enquiry or if you provided us with your details when you entered a competition or registered for a promotion. We will not, however, send you generic marketing about set3 Solutions unless you have expressly consented to receive it.

Third party marketing

We will seek your express opt-in consent before we share your personal data with any company outside of the set3 Solutions group 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 or unsubscribe links in any marketing message sent to you or by contacting us.

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 order, warranty registration, product/service experience or other transactions, or where we need to keep your contact details or make contact with you for contractual performance or legitimate interest purposes.

Cookies

You can set your browser to refuse all or some browser cookies or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.

Change of purpose

We will only use your personal data for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

Internal Third Parties as set out in the Glossary.
External Third Parties as set out in the Glossary.
Specific third parties listed in the Glossary.
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 Policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law.

6. International transfers

We may transfer the personal information that we collect from you to a destination outside of the European Economic Area (EEA) if necessary for the processing purposes we have described (including where we transfer your personal information to third parties). In these cases, one of our suppliers may process your personal information. By submitting your personal information, you agree to this transfer, storing or processing.

Such countries may not have the same data protection laws as the UK and EEA. Where your personal information is transferred to third parties or outside of the EEA we will put in place appropriate protection to make sure your personal data remains adequately protected and that it is processed in accordance with this policy (as permitted in accordance with Article 46 of the General Data Protection Regulations).

7. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

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

8. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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.

By law we have to keep basic information about our customers and employees (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers or employees for tax and legal liability purpose, but we will also keep this information to make it easier for customers to make new, follow-on or repeat bookings.

We will seek to renew consent for marketing communications every two years. In some circumstances you can ask us to delete your data: see Request erasure below for further information.

In some circumstances, we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please review the Glossary to find out more about these rights listed below:

Request access to your personal data.
Request correction of your personal data.
Request erasure of your personal data.
Object to the processing of your personal data.
Request restriction of processing your personal data.
Request transfer of your personal data.
Right to withdraw consent.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. Glossary

Lawful basis

Consent
means the unambiguous approval to use data in a specific way, it must involve a clear affirmative action (an opt-in). In relation to the use of Special Personal Data, the consent must be given expressly in relation to this use. We seek consent in relation to marketing permissions and in relation to our own employees or sub-contractors.

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.

Third parties

Internal third parties

Other companies in the set3 Solutions group acting as joint controllers or processors and which provide IT and system administration services and undertake leadership reporting.

External third parties

We may disclose your personal data to third parties, located both inside and outside the EEA, who provide a service to us, including:

providers of cloud-based CRM software in relation to customer account maintenance;
providers of cloud-based marketing software in relation to prospective customer information management;
providers who collect information on our behalf, including as necessary to operate features of the Website, such as customer satisfaction surveys.
providers of cloud-based accounting software in relation to the management of accounting.
third-party service providers that help us operate and manage our Website, process orders, and fulfil and deliver products and services that you purchase from us.
Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based within the EU who provide consultancy, banking, legal, insurance and accounting services to us.
HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom or EU who require reporting of processing activities in certain circumstances.

Your legal rights

Under the General Data Protection Regulation you have a number of important rights free of charge. In summary you have the right to:

Request access
to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction
of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure
of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to the processing
of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing
of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer
of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time
where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Making a Data Subject Access Request (DSAR)

If you would like to exercise any of your legal rights regarding your personal data please:

email, call our write to us
let us have enough information to identify you
let us have proof of your identity (e.g. a copy of your driving license or passport)
let us know the information to which your request relates