Privacy Policy

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 Privacy Policy and Your Duty to Inform Us of Changes

This version was last updated on 21 May 2018 and historic versions can be obtained by contacting us. 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.

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 follows:

• Identity Data - includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
  

• Contact Data - includes address, email address and telephone numbers.
  

• 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.
  

• Profile Data - includes 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 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 Privacy Policy.

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 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 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). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

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

• Direct interactions. You may give us your Identity and Contact Data 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;
    

  • subscribe to our service or mailing lists
    

  • request marketing to be sent to you;
    

  • enter a survey; or
    

  • give us some feedback.
    

• Automated technologies or interactions. As you interact with our website, 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 for further details..
  

• Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
  

  • Technical Data from analytics providers such as Google based outside the EU;
    

  • Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.
    

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.
  

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.

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:

• 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 requested information from us or purchased services from us or if you provided us with your details when you entered a survey, 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 Node 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 service, service experience or other transactions.
  

• 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.
  

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.
  

• 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 Policy.
  

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.

We do not transfer your personal data outside the European Economic Area (EEA).

We apply appropriate technical and organisational measures in order to protect data, computing devices and the network from accidental/ malicious activities or theft. Where appropriate, we encrypt our data and devices with confidential information securely destroyed when no longer required.

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.

Data Protection Laws, describe individuals who have provided their Personal Data to an organisation (either directly or indirectly) as “Data Subjects”. As a Data Subject, you have a number of rights with respect to how organisations process your Personal Data. If you wish to exercise any of your rights, please contact us:

• Right to be Informed
  

  As a Data Subject, you have the right to be informed of the use that your Personal Data will be put to, along with details of the Data Controller and your rights. Where you provide your Personal Data directly to Node, these details will be made available at the time your data is obtained. Where Node obtains your Personal Data from a third party, these details will be made available within a reasonable period of having obtained the data. If your Personal Data is to be used to communicate with you, these details will be provided at the latest, when the first communication takes place. If disclosure to another recipient is envisaged, these details will be provided at the latest, before the data is disclosed. In all cases, notification will take place, within one month of receipt of your Personal Data.
  

• Right to Access
  

  Data Subjects have the right to access and obtain a copy of your Personal Data held and processed by Node, on request. You exercise this right through the submission of a formal, written Subject Access Request to the Data Privacy Manager (email: steph@thisisnode.com or Data Privacy Manager, Node, Imperial & Whitehall, 23 Colmore Row, Birmingham, B3 2BS).
  

• Right to Rectification
  

  You have the right to request Node to correct inaccurate or incomplete Personal Data.
  

• Right to Erasure (to be Forgotten)
  

  You have the right to request Node to erase your Personal Data from its systems and records. This is not an absolute right however and does not normally apply to purposes covered by Legal Obligation or which is necessary for the performance of a Contract.
  

• Right to Restrict Processing
  

  Data Subjects have the right to request Node to stop or restrict the processing of your Personal Data. This could be for example, if your Personal Data is no longer necessary for the purpose of processing.
  

• Right to data portability
  

  You have the right to request a copy of the Personal Data which you have provided directly to Node which is automatically processed in a portable format.
  

• Right to object
  

  As a Data Subject, you have the right to object to the processing of your Personal Data, where Node relies upon Legitimate Interest as the lawful basis for processing.
  

• Rights related to automated decision making including profiling
  

  You have the right not to be subject to a decision based solely on automated processing (including profiling), which may significantly affect you.