This webpage sets out when
and how we use your Personal Data that you or others provide to us. Your
privacy is of the utmost importance to us. We want to make sure you fully
understand the terms and conditions surrounding the capture and use of that
information, whether we receive it directly from you, a third party or via the Packetly
software platform (“Platform”) or the Packetly website (“Website”).
This Privacy Notice describes what information we collect about you, how we use
it, and the rights you have in relation to that collection and usage.
If you have any questions
about this Privacy Notice, please contact us at support@packetly.com.
WHO WE ARE
We are PACKETLY LIMITED,
a company incorporated and registered in England and Wales with company number 14120157,
whose registered office is at Dencora Court 2 Meridian Way, Meridian Business
Park, Norwich, England, NR7 0TA (“Packetly”).
For the purposes of the Data
Protection Act 2018, the UK General Data Protection Regulation and any other applicable
data protection and privacy laws and regulations (“Data Protection
Legislation”), Packetly will be the ‘data controller’ for all Personal Data
we determine the means and purpose of processing.
By “Personal Data” we
refer to information collected or held by Packetly, that identifies and relates
to you as an individual.
INFORMATION WE COLLECT AND
USE AT PACKETLY
We gather and use Personal
Data in the following circumstances.
When you register an account with
us on the Platform:
As a user of Packetly, we gather
your Personal Data in the following circumstances:
By registering your account on
our Platform and using the Platform functions we will collect the following
Personal Data:
Data Type
|
Mandatory
/ Optional
|
Reason for Collection
|
Full name
|
Mandatory
|
Required to identify the user creating the account.
|
Email
address
|
Mandatory
|
Required to contact and verify the user. It may also be used for marketing and
account recovery purposes.
|
Address
|
Mandatory
|
Required for client verification and billing
purposes.
|
Files,
content, documents, records, information, data, text, images, videos and
materials
|
Optional
|
The user can upload content to be assessed within the
Platform as part of our Services which may contain personal data.
|
To ensure that your credit,
debit or charge card is not being used without your consent, we may validate
name, address and other personal information supplied by you during the Order
process against appropriate third party databases.
There is a possibility we may
contact you to make additional security checks and we ask for your co-operation
to enable us to complete them. We will not tolerate fraudulent transactions and
such transactions will be reported to the relevant authorities.
In performing these checks
personal information provided by you may be disclosed to a registered Credit
Reference Agency which may keep a record of that information. You can rest
assured that this is done only to confirm your identity, that a credit check is
not performed and that your credit rating will be unaffected.
When using the Platform, we
collect the following Personal Data on your phone / device:
Data Type
|
Mandatory
/ Optional
|
Reason for Collection
|
Time and date of your Platform usage
|
Mandatory
|
The Packetly Platform automatically collects this information for diagnostic and
analytical purposes.
|
Data and statistics on Platform usage
|
Mandatory
|
The Packetly Platform automatically collects this information for diagnostic and
analytical purposes.
|
Client-side errors
|
Mandatory
|
The Packetly Platform automatically collects this information for diagnostic and
analytical purposes.
|
Internet protocol (IP) address
|
Mandatory
|
The Packetly Platform automatically collects this information for diagnostic and
analytical purposes.
|
Where we do not require this
information as a necessity of providing our service, we collect and use this
information under our legitimate interest to provide a secure and consistent
product by ensuring we can identify and correct any errors that may occur by
incorrect data being passed to us.
If you contact our helpdesk
service as a user, we will collect your name, contact details, nature of your
request and any supplementary information you choose to provide us. We will
only retain the Personal Data pertinent to resolving your issue.
When you have expressed an
interest in our services:
If you have opted in via our Website
or other form of media to receive marketing communications from us, we will
handle your Personal Data for example (your name, email address and telephone
number) to provide you with marketing communications in line with any
preferences you have told us about.
You are not under any
obligation to provide us with your Personal Data for marketing purposes.
When we send marketing emails to
our clients and service users, we rely on consent to contact you for marketing
purposes. If we consider that you may genuinely have an interest in benefitting
from our service, we may make business to business approaches under our
legitimate interests. Every email we send to you for marketing purposes will
also contain instructions on how to unsubscribe from receiving them. You always
reserve the right to object to our processing under legitimate interests,
please see the “Your rights under Data Protection Legislation” section
below.
When you visit the Website:
We use tools to collect standard
internet log information and details of visitor’s behaviour patterns. We do
this to help identify the number of visitors to the site and the pages they
visit. We do not record, and we do not allow third parties to make any attempt
to identify the individual identities of those who visit our pages.
This information is stored and
used for aggregated and statistical reporting. The collected information is
used to provide an overview of how people are accessing and using the Website.
Any Personal Data gathered from first-party essential cookies on our Website is
processed under our legitimate interest to promote the success of the business
and ensure the security of the Website or to perform a contract with you.
You can prevent us from using
your Personal Data in this way by using the 'do not track' functionality in
your internet browser or withholding your consent for the installation of
non-essential cookies on your computer. If you enable do not track functionality,
our site may be less tailored to your needs and preferences.
What we don’t collect:
Card payment details taken for
our services are processed and managed via a third party payment provider
(Stripe). Packetly does not hold any card detail information as part of the
Personal Data we handle on your behalf.
IF YOU FAIL TO PROVIDE US WITH
PERSONAL DATA
You always reserve the right to
withhold your Personal Data, but this may affect how we provide our services.
Where we need to collect
Personal Data by law, or under the terms of a contract we have with you 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. In this case, we may
have to cancel a service you have with us but we will notify you if this is the
case at the time.
LAWFUL BASIS OF PROCESSING
We will only process your
information for as long as we have a relevant legal basis to do so. This is
usually in order to provide you with the goods and/or services that you have
requested from Packetly and unless stated, all of the above processing is
conducted under the legal basis of performance of a contract.
If we have collected sensitive
personal data as part of our service provision, we will always ensure that we
either request explicit consent from you or document the appropriate exemption
to allow the processing of this data.
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 we consider the new purpose to be incompatible with
the original purpose of collection, we will conduct a privacy impact assessment
or contact you to request your consent for further processing. 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 at support@packetly.com.
STORING YOUR DATA
The data that we collect from
you will primarily be stored in a location within the United Kingdom and/or the
European Economic Area (EEA). In the event that we need to transfer your
Personal Data outside of the United Kingdom and/or the EEA, we will ensure that
there is an appropriate legal transfer mechanism in place.
All information you provide to
us is stored on our secure servers or those of our third party sub-contractors.
Where we have given you (or where you have chosen) a password which enables you
to access certain parts of our Platform, you are responsible for keeping this
password confidential. You must not share your password with anyone.
SHARING YOUR INFORMATION WITH
OTHERS
If and when we share your data,
we always do so under a written agreement governing how your data must be
protected.
We may be required to share your
Personal Data with third parties to adequately provide our services. Please be
assured that we will not share your information for any other reason unless we
are required by law or permitted to do so under this Privacy Notice. The main
circumstances in which we will be permitted or required to disclose this is by
law will be by court order, to government bodies and law enforcement agencies.
However, sometimes we may share
your information with third parties in the following ways:
a)
we may share standard user’s
information with a corporate account that funds their subscription to the
Platform;
b)
we may use carefully selected
sub-processors to help us collect, store or manage your information. This will
always be managed under the terms of a written data processing agreement;
c)
analytics and search engine providers
that assist us in the improvement and optimisation of the Website; and
d)
we will
transfer your Personal Data to a third party if:
i. we sell or buy any business or assets, we will provide
your Personal Data to the seller or buyer (but only to the extent we need to,
and always in accordance with Data Protection Legislation); or
ii. if Packetly or the majority of its assets are acquired
by somebody else, in which case the Personal Data held by Packetly will be
transferred to the buyer.
We process your Personal Data
for this purpose because we have a legitimate interest to ensure our business
can be continued by the buyer. If you object to our use of your Personal Data
in this way, the relevant seller or buyer of our business may not be able to
provide services to you.
RETAINING DATA
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.
PROTECTING YOUR DATA
We take our security obligations
very seriously and constantly monitor for breaches and potential weaknesses.
Packetly is committed to
ensuring that data is stored, archived or disposed of in a safe and secure
manner. We have procedures in place to try and prevent any unauthorised access
or disclosures and to safeguard and keep secure the information that we
collect.
We use computer safeguards such
as firewalls and data encryption, we enforce physical access controls to our
buildings and files, and we authorise access to Personal Data only for those
employees who require it to fulfil their job responsibilities. All data at rest
and in transit is encrypted and we employ TLS encryption for data transferring
between our Platform and servers. We maintain detailed breach identification
and mitigation plans and all staff are trained in managing potential compromise
scenarios.
However, you should be aware
that providing information over the internet can never be guaranteed as being
completely safe and if you choose to send such information to us via the
internet, you do so at your own risk.
COOKIES
Please see app.packetly.com for
further information on the cookies we use to record information about your use
on the Platform.
YOUR RIGHTS UNDER DATA
PROTECTION LEGISLATION
You have access to the following
rights under Data Protection Legislation:
Right to object
You have the right to object to
us handling your Personal Data when:
a)
we are handling your Personal Data
based on our legitimate interests (as described in the “Information We
Collect and Use at Packetly” section above). If you ask us to stop handling
your Personal Data in this way, we will stop unless we can show you that we
have compelling grounds as to why our use of your Personal Data should
continue; or
b)
for marketing purposes. If you ask
us to stop handling your Personal Data on this basis, we will stop.
Right of access
You are entitled to receive
confirmation as to whether your Personal Data is being processed by us, as well
as various other information relating to our use of your Personal Data.
You also have the right to
access your Personal Data which we are handling.
Right to rectification
You have the right to require us
to rectify any inaccurate Personal Data we hold about you. You also have the
right to have incomplete Personal Data we hold about you completed, by
providing a supplementary statement to us.
Right
to restriction
You can restrict our processing
of your Personal Data where:
a)
you think we hold inaccurate
Personal Data about you;
b)
our handling of your Personal Data
breaks the law, but you do not want us to delete it;
c)
we no longer need to process your
Personal Data, but you want us to keep it for legal reasons; or
d)
we are handling your Personal Data
because we have a legitimate interest, and are in the process of objecting to
this use of your Personal Data.
Where you exercise your right to
restrict us from using your Personal Data, we will then only process your
Personal Data when you agree, except for storage purposes and to handle legal
claims.
Right to data portability
You have the right to receive
the Personal Data we hold about you in a structured, standard machine readable format
and to send this to another organisation controlling your Personal Data.
Right to erasure
You have the right to require us
to erase your Personal Data which we are handling in the following circumstances:
a)
we no longer need to use your
Personal Data for the reasons we told you we collected it for;
b)
where we needed your consent to use
your Personal Data and you have withdrawn your consent;
c)
you object to our use of your
Personal Data and we have no compelling reason to carry on handling your
Personal Data;
d)
our handling of your Personal Data
has broken the law; or
e)
we must erase your Personal Data to
comply with a law we are subject to.
Right to complain
You have the right to lodge a
complaint with the Information Commissioner's Office, the supervisory authority
for data protection issues in England and Wales.
CHANGES TO THIS PRIVACY NOTICE
Any changes we make to our
Privacy Notice in the future will be posted on this page and, where
appropriate, notified to you by e-mail or notification within the Platform.
Please check back frequently
to see any updates or changes to our Privacy Notice.
ENQUIRIES
Questions, comments and
requests regarding this Privacy Notice are welcomed and should be addressed to
support@packetly.com.
This Privacy Notice was
last updated January 2025