Privacy Policy

1.1 Important information and who we are

Welcome to the UNDO Privacy and Data Protection Policy (“Privacy Policy”).

At UNDO (“we”, “us”, or “our”) we are committed to protecting and respecting your privacy and Personal Data in compliance with the law and guidelines of the UK General Data Protection Regulation (“GDPR”).

This Privacy Policy explains how we collect, process and keep your data safe. The Privacy Policy will tell you about your privacy rights, and how the law protects you, and inform our employees and staff members of all their obligations and protocols when processing data.

It is important that you read this privacy policy together with the website’s Cookies Policy so that you are fully aware of how and why we are using your data.

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 the Cookie policy.

The individuals from which we may gather and use data can include:

Customers
Suppliers
Business contacts
Candidates for jobs
Third parties connected to your customers, and any other people that the organisation has a relationship with or may need to contact.

This Privacy Policy applies to all our employees and staff members and all Personal Data processed at any time by us.

Please use the Glossary at the bottom of this policy to understand the meaning of some of the terms used in this Privacy Policy.

1.2 Who is Your Data Controller

The Data Controller for the purposes of UK GDPR is UNDO and it is responsible for your Personal Data. We are not obliged by the UK GDPR to appoint a data protection officer but have voluntarily appointed one. Therefore, any inquiries about your data should be sent to Mr Timothy Cooke at [email protected].

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.

1.3 Processing Data on Behalf of a Controller and Processors’ responsibility to you

In discharging our responsibilities as a Data Controller we have employees who will deal with your data on our behalf (known as “Processors”). Therefore, the responsibilities described below may be assigned to an individual, or may be taken to apply to the organisation as a whole. The Data Controller and our Processors have the following responsibilities:

Ensure that all processing of Personal Data is governed by one of the legal bases laid out in the UK GDPR (see 2.2 below for more information on those bases);
Ensure that Processors authorised to process Personal Data have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality;
Implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk associated with the processing of Personal Data;
Obtain the prior specific or general authorisation of the Controller before engaging another Processor;
Assist the Controller in the fulfilment of the Controller’s obligation to respond to requests for exercising the data subject’s rights;
Make available to the Controller all information necessary to demonstrate compliance with the obligations laid down in the UK GDPR and allow for and contribute to audits, including inspections, conducted by the Controller or another auditor mandated by the Controller;
Maintain a record of all categories of processing activities carried out on behalf of a Controller;
Cooperate, on request, with the supervisory authority in the performance of its tasks;
Ensure that any person acting under the authority of the Processor who has access to Personal Data does not process Personal Data except on instructions from the Controller; and
Notify the Controller without undue delay after becoming aware of a Personal Data Breach;

2 LEGAL BASIS FOR DATA COLLECTION

2.1 Types of Data / Privacy Policy Scope

“Personal Data” 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 below. Not all of the following types of data will necessarily be collected from you but this is the full scope of data that we collect and when we collect it from you:

Profile/Identity Data: This is data relating to your first name, last name, gender, date of birth.
Contact Data: This is data relating to your phone number, addresses, email addresses, and phone numbers.
Marketing and Communications Data: This is your preference in receiving marketing information and other information from us.
Technical Data: Includes internet protocol (IP) address, 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.
Usage Data: Includes information about how you use our website.
Billing Data: This is information relating to your debit and credit card information such as the name attached to your payment details and your billing address.
Financial Data: These are your banking details e.g. your account number and sort code.
Transactional Data: This is information on details and records of all payments you have made for our services or products.
Customer Support Data: This includes feedback and survey responses.

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.

2.2 The Legal Basis for Collecting That Data

There are a number of justifiable reasons under the UK GDPR that allow the collection and processing of Personal Data. The main avenues we rely on are:

“Consent”: Certain situations allow us to collect your Personal Data, such as when you tick a box that confirms you are happy to receive email newsletters from us, or ‘opt-in’ to a service.
“Contractual Obligations”: We may require certain information from you in order to fulfil our contractual obligations and provide you with the promised service.
“Legal Compliance”: We’re required by law to collect and process certain types of data, such as fraudulent activity or other illegal actions.
“Legitimate Interest”: We might need to collect certain information from you to be able to meet our legitimate interests – this covers aspects that can be reasonably expected as part of running our business, that will not have a material impact on your rights, freedom or interests. Examples could be your address, so that we know where to deliver something to, or your name so that we have a record of who to contact moving forward.

3 HOW WE USE YOUR PERSONAL DATA

3.1 Our Uses

We will only use your Personal Data when the law allows us to. Set out below is a table containing the different types of Personal Data we collect and the lawful basis for processing that data. Please refer to section 2.2 for more information on the lawful basis listed in the table below.

Examples provided in the table below are indicative in nature and the purposes for which we use your data may be broader than described but we will never process your data without a legal basis for doing so and it is for a related purpose. For further inquiries please contact us.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To manage our relationship with you	(a) Identity (b) Contact (c) Communication	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to keep our records updated and to study how customers use our website)
To provide you with updates and communications about our business	(a) Identity (b) Contact (c) Communication	(a) Performance of a contract with you (b) Necessary for our legitimate interests
To administer and improve this website and our business more generally	(a) Identity (b) Usage (c) Technical data	(a) Necessary for our legitimate interests (b) To comply with a legal obligation

3.2 Marketing and Content Updates

You will receive marketing and new content communications from us if you have created an account and chosen to opt into receiving those communications. From time to time we may make suggestions and recommendations to you about goods or services that may be of interest to you.

3.3 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.

4 YOUR RIGHTS AND HOW YOU ARE PROTECTED BY US

4.1 How Does UNDO Protect Customers’ Personal Data?

We are concerned with keeping your data secure and protecting it from inappropriate disclosure. Any Personal Data collected by us is only accessible by a limited number of employees who have special access rights to such systems and are bound by obligations of confidentiality. If and when we use subcontractors to store your data, we will not relinquish control of your Personal Data or expose it to security risks that would not have arisen had the data remained in our possession. However, unfortunately, no transmission of data over the internet is guaranteed to be completely secure. It may be possible for third parties not under the control of UNDO to intercept or access transmissions or private communications unlawfully. While we strive to protect your Personal Data, we cannot ensure or warrant the security of any Personal Data you transmit to us. Any such transmission is done at your own risk. If you believe that your interaction with us is no longer secure, please contact us.

4.2 Opting Out Of Marketing Promotions

You can ask us to stop sending you marketing messages at any time by sending an email to [email protected].

Where you opt out of receiving these marketing messages, we will continue to retain other Personal Data provided to us as a result of interactions with us not related to your marketing preferences.

4.3 How to Request your Data and the Process for Obtaining it

Under certain circumstances, you have rights under data protection laws in relation to your personal data:

The right to access personal data we hold about you: You can contact us to request a copy of the data we hold about you, as well as why we process that data, who has access to it, and where we got it.
The right to correct and update the personal data we hold about you: If the data we hold about you is out of date, incomplete or incorrect, please let us know and we will ensure that it is updated.
The right to have your personal data erased: In some circumstances, if you no longer wish us to process your data, you can request that we erase it. When we receive your request, we will confirm whether the data has been deleted, or tell you the reason why it cannot be deleted.
The right to object to the processing of your personal data: You have the right to request that we stop processing your data. Upon receiving the request, we will contact you to tell you if we are able to comply or if we have lawful grounds to continue, for example, if the data is required to allow us to provide you access to the Platform and the Services. If data is no longer processed, we may continue to hold your data to comply with your other rights.
The right to data portability: You have the right to request that we transfer your data to another controller. Once we have received your request, we will comply where it is feasible to do so.
The right to complain: You can make a complaint to us by contacting us or to the data protection supervisory authority – in the UK, this is the Information Commissioner’s Office, at https://ico.org.uk/.
Consent: If you have given us your consent to use your personal data, you can withdraw your consent at any time. This will not affect the lawfulness of our use of your information before you withdrew your consent.

If you wish to exercise any of the rights set out above, please contact us at the details set out above.

What we may need from you: We may need to request specific information from you to help us confirm your identity and ensure you have the 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.

5 YOUR DATA AND THIRD PARTIES

5.1 Will We Share Your Data With Third Parties?

We may share non-personal Data with third parties. We may share your Personal Data with subcontractors (only when necessary and with your consent) or affiliates (subject to confidentiality obligations to use it only for the purposes for which we disclose it to them and pursuant to our instructions).

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 policy of every website you visit.

Digital Marketing Service Providers: We periodically appoint digital marketing agents to conduct marketing activity on our behalf. Such activity may result in the compliant processing of personal information. Our appointed data processors include:

Prospect Global Ltd (trading as Sopro) Reg. UK Co. 09648733. You can contact Sopro and view their privacy policy here: https://sopro.io. Sopro is registered with the ICO Reg: ZA346877. Their Data Protection Officer can be emailed at: [email protected].

We may also share Personal Data with interested parties in the event that UNDO anticipates a change in control or the acquisition of all or part of our business or assets or with interested parties in connection with the licensing of our technology.

If UNDO is sold or makes a sale or transfer, we may, in our sole discretion, transfer, sell, or assign your Personal Data to a third party as part of or in connection with that transaction. Upon such transfer, the Privacy Policy of the acquiring entity may govern the further use of your Personal Data. In all other situations, your data will still remain protected in accordance with this Privacy Policy (as amended from time to time).

We may share your Personal Data at any time if required for legal reasons or in order to enforce our terms or this Privacy Policy.

6 HOW LONG WILL WE RETAIN YOUR DATA FOR?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation with respect to our relationship with you.

In some circumstances, we will 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.

7 AGE LIMIT FOR OUR USERS

Use of our organisation has an age limit of 16 or older.

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

8 INTERNATIONAL TRANSFER OF DATA

Your information may be stored and processed in the UK, US, EU, or other countries or jurisdictions outside of these where UNDO has facilities. By using UNDO, you are permitting and consenting to the transfer of your information, including Personal Data in the UK, US, EU, or other countries or jurisdictions outside of these where UNDO has facilities.

9 NOTIFICATION OF CHANGES AND ACCEPTANCE OF POLICY

We keep our Privacy Policy under review and will place any updates on this webpage. This version is dated 12th October 2023. By using UNDO, you consent to the collection and use of data by us as set out in this Privacy Policy. Continued access or use of UNDO shall constitute your express acceptance of any modifications to this Privacy Policy.

10 INTERPRETATION

All uses of the word “including” mean “including but not limited to” and the enumerated examples are not intended to in any way limit the term which they serve to illustrate. Any email addresses set out in this policy may be used solely for the purpose for which they are stated to be provided, and any unrelated correspondence will be ignored. Unless otherwise required by law, we reserve the right to not respond to emails, even if they relate to a legitimate subject matter for which we have provided an email address. As a matter of common sense, you are more likely to get a reply if your request or question is polite, and reasonable and there is no relatively obvious other way to deal with or answer your concern or question (e.g. FAQs, other areas of our website etc.).

Our staff are not authorised to contract on behalf of UNDO, waive rights or make representations (whether contractual or otherwise). If anything contained in an email from an UNDO email address contradicts anything in this policy, our terms or any official public announcement on our website, or is inconsistent with or amounts to a waiver of any of UNDO’s rights, the email content shall be read down to grant precedence to the latter. The only exception to this is genuine correspondence expressed to be from the UNDO legal department.