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Privacy Policy

Adventoris Ltd is committed to protecting and preserving your privacy.

This policy (together with our Terms and Conditions) and any other documents referred to on it) sets

out the basis on which any personal data we collect from you, or that you provide to us online or on

our mobile service, will be processed by us. Please read the following privacy policy to understand

how we use and protect the information you provide to us. This Policy applies as between you, the

User of this Website and Adventoris Ltd the owner and provider of this Website. This Policy applies to our use of any and all Data collected by us in relation to your use of the Website.

 

  1. Definitions and Interpretation

In this Policy the following terms shall have the following meanings:

“Adventoris Ltd” means Adventoris Ltd of 3M Buckley Innovation Centre, Firth

Street Huddersfield. HD1 3BD; “Cookie” means a small text file placed on your computer by this Website when you visit certain parts of the Website and/or when you use certain features of the Website. Details of the cookies used by this Website are set out in Clause 12; “Data” means collectively all information that you submit to the SwiftCloud Application via the Website. This definition shall, where applicable, incorporate the definitions provided in the

Data Protection Act 1998;

“SwiftCloud” means the SwiftCloud application (or app) which is the cloud based platform which will allow the User to receive sales orders directly from its customers via a mobile sales application;

“UK and EU Cookie Law” means the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended by the Privacy and Electronic Communications (EC Directive) (Amendment)

Regulations 2011;

“Website” means the website that you are currently using (www.swiftcloud.co.uk, www.swiftserver.co.uk; www.adventoris.com) and any sub-domains of this site unless expressly excluded by their own terms and conditions.

 

  1. Scope of this Policy

 

This Policy applies only to the actions of Adventoris Ltd and Users with respect to this Website.

It does not extend to any websites that can be accessed from this Website including, but not

limited to, any links we may provide to social media websites.

 

  1. Data Collected

 

Without limitation, any of the following Data may be collected by this Website from time to

time:

3.1 name;

3.2 gender;

3.3 job title;

3.4 profession;

3.5 contact information such as email addresses and telephone numbers;

3.6 demographic information such as post code, preferences and interests;

3.7 IP address (automatically collected);

3.8 web browser type and version (automatically collected);

3.9 operating system (automatically collected);

3.10 a list of URLs starting with a referring site, your activity on this Website, and the site

you exit to (automatically collected); and

  1. Our Use of Data

4.1 Any personal Data you submit will be retained by Adventoris Ltd.

4.2 Unless we are obliged or permitted by law to do so, and subject to Clause 5, your Data

will not normally be disclosed to third parties. This does not include our affiliates and

/ or other companies within our group. Data may be disclosed to 3rd parties in the

following circumstances:

4.2.1 to provide or to help us improve the services you have asked for or subscribed to;

4.2.2 to provide information for legal or regulatory purposes;

4.2.3 as part of current or future legal proceedings; or

4.2.4 to enable us to manage your account.

4.3 All personal Data is stored securely in accordance with the principles of the Data

Protection Act 1998. For more details on security see Clause 11 below.

4.4 Any or all of the above Data may be required by us from time to time in order to

provide you with the best possible service and experience when using our Website.

Specifically, Data may be used by us for the following reasons:

4.4.1 internal record keeping;

4.4.2 improvement of our products / services;

4.4.3 transmission by email of promotional materials that may be of interest to you;

4.4.4 contact for market research purposes which may be done using email,

telephone, fax or mail. Such information may be used to customise or update the Website.

4.4.5 for processing your enquiries, orders or applications;

4.4.6 for credit checks and to manage your accounts;

4.4.7 to provide you with other services which you could have from time to time.

(We will only contact you in this way if you have previously shown your

consent);

4.4.8 to help to run any accounts, services and products which we provide now or in

the future (or have previously provided);

4.4.9 to carry out any marketing analysis, profiling or create statistical or testing

information

4.4.10 to recover debts

4.4.11 to prevent and detect fraud or loss

4.4.12 to update our records about you;

4.4.13 to prevent money laundering; and

4.4.14 to identify you when you contact us.

  1. Third Party Websites and Services

5.1 Adventoris Ltd may, from time to time, employ the services of other parties for dealing

with matters that may include, but are not limited to, payment processing, search engine facilities, advertising and marketing. The providers of such services may have access to certain personal Data provided by Users of this Website.

5.2 Any Data used by such parties is used only to the extent required by them to perform

the services that Adventoris Ltd requests. Any use for other purposes is strictly

prohibited. Furthermore, any Data that is processed by third parties shall be processed

within the terms of this Policy and in accordance with the Data Protection Act 1998.

  1. Links to Other Websites

This Website may, from time to time, provide links to other websites. Adventoris Ltd has no

control over such websites and is in no way responsible for the content. This Policy does not

extend to your use of such websites. Users are advised to read the privacy policy or statement

of other websites prior to using them.

  1. Changes of Business Ownership and Control

7.1 Adventoris Ltd may, from time to time, expand or reduce our business and this may

involve the sale and/or the transfer of control of all or part of Adventoris Ltd. Data

provided by Users will, where it is relevant to any part of our business so transferred,

be transferred along with that part and the new owner or newly controlling party will,

under the terms of this Policy, be permitted to use the Data for the purposes for which

it was originally supplied to us.

7.2 In the event that any Data submitted by Users is to be transferred in such a manner,

you will not be contacted in advance and informed of the changes.

  1. Controlling Use of Your Data

8.1 Wherever you are required to submit Data, you will be given options to restrict our use

of that Data. This may include the following:

8.1.1 use of Data for direct marketing purposes; and

8.1.2 sharing Data with third parties.

  1. Your Right to Withhold Information

You may access certain areas of the Website without providing any Data at all. However, to

use all features and functions available on the Website you may be required to submit certain

Data.

  1. Accessing your own Data

You have the right to ask for a copy of any of your personal Data held by Adventoris Ltd (where

such data is held) on payment of a small fee which is currently £15.

  1. Security

11.1 Data security is of great importance to Adventoris Ltd and to protect your Data we

have put in place suitable physical, electronic and managerial procedures to safeguard

and secure Data collected via this Website.

11.2 Specifically we use the following systems:

11.2.1 Cisco Firewall technology; or

11.2.2 SonicWall Firewall technology; and

11.2.3 At least 128 Bit Advanced Encryption Standard (AES)

  1. Cookies

12.1 This Website may place and access certain Cookies on your computer. Adventoris Ltd

uses Cookies to improve your experience of using the Website and to improve our

range of products and services. Adventoris Ltd has carefully chosen these Cookies

and has taken steps to ensure that your privacy is protected and respected at all times.

12.2 All Cookies used by this Website are used in accordance with current UK and EU Cookie

Law.

 

12.3 Before the Website places on your computer, subject to sub-Clause 12.4, you will be presented with a pop-up message requesting your consent to set those Cookies. By

giving your consent to the placing of Cookies you are enabling Adventoris Ltd to

provide the best possible experience and service to you. You may, if you wish, deny

consent to the placing of Cookies; however certain features of the Website may not

function fully or as intended.

 

12.4 Certain features of the Website depend upon Cookies to function. UK and EU Cookie

Law deems these Cookies to be “strictly necessary”. These Cookies are shown below.

Your consent will not be sought to place these Cookies. You may still block these

cookies by changing your internet browser’s settings as detailed below.

 

12.5 This Website places the following Cookies:

 

Name of Cookie Purpose Strictly Necessary

Send_login_username To capture the users login details No

12.6 You can choose to enable or disable Cookies in your internet browser. By default, most

internet browsers accept Cookies but this can be changed. For further details, please

consult the help menu in your internet browser.

 

12.7 You can choose to delete Cookies at any time however you may lose any information

that enables you to access the Website more quickly and efficiently including, but not

limited to, personalisation settings.

 

12.8 It is recommended that you ensure that your internet browser is up-to-date and that

you consult the help and guidance provided by the developer of your internet browser

if you are unsure about adjusting your privacy settings.

 

  1. Consent and Changes to Privacy Policy

Adventoris Ltd reserves the right to change this Policy as we may deem necessary from time

to time or as may be required by law. Any changes will be immediately posted on the Website

and you are deemed to have accepted the terms of the Policy on your first use of the Website

following the alterations. By using this website or our mobile applications you are consenting

to this privacy policy.

Please note that this policy will be reviewed and may change from time to time. The revised

policy will be posted to this page so that you are always aware of the information we collect,

how we use it and under what circumstances we disclose it.

 

  1. Decision Making

Any decision made by us in relation to the services provided to you shall be final

 

  1. GDPR

 

1.9 Policies and procedures (Article 5)

 

In order to ensure that Adventoris has considered its privacy obligations and implements the 7 GDPR protection principles, Adventoris has implemented clear and concise data protection policies.

Article 5 of the GDPR sets out seven key principles which lie at the heart of the general data protection regime.

Article 5(1) requires that personal data shall be:

“(a) processed lawfully, fairly and in a transparent manner in relation to individuals (‘lawfulness, fairness and transparency’);

Adventoris acquires its data legally from the MINT Database, which is part of Bureau van Dijk (BvD), one of the world’s leading business information publishers, as an opted in account willing to receive marketing emails of relevance and interest. Adventoris aims to teach and inform businesses about how implementing an app into their already existing web ordering system can enhance sales and cut costs. Adventoris are completely transparent about this within all forms of marketing. Adventoris do not aim to mislead in anyway about the product they are offering, and the option to unsubscribe to all marketing channels is clear within email marketing, telesales and personal emails. If any person wishes to request their data be removed this will be done immediately, or subsequently if they wish to know what data Adventoris hold on them.

(b) collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes (‘purpose limitation’);

Adventoris state that, the data is collected and stored, as there is a legitimate interest for the companies (within the categories outlined in section 1.3) to have knowledge and understanding of the benefits of the SwiftCloud application, which is the interest of their company can help operations, increase sales and cut costs. 

(c) adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (‘data minimisation’);

The data collected and stored by Adventoris is selectively chosen via SIC code to ensure that only the data of companies who meet the needs of their product will be contacted. Market research has been undertaken to understand which companies would have legitimate interest and would highly benefit from the SwiftCloud application, these company SIC codes are outlined in section 1.3. 

(d) accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay (‘accuracy’);

The data subjects that Adventoris holds comes from the MINT database which states their data is accurate and up to date and cleansed on a regular basis, furthermore, Adventoris takes all necessary steps to ensure that the data held within Salesforce is regularly updated and maintained.  How is it updated and maintained? The best way to obtain information about a business is to phone up and ask which Adventoris BDMs all day, every day as they work through the data. BDMs check the name and address, number of staffs, what sort of premises and even the web site address. Every business gets a call from Adventoris at least once a year and more often if they suspect something has changed.

 (e) kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals (‘storage limitation’);

The data is reviewed after 1 year to establish whether the company has an interest in the SwiftCloud application. Due to the nature of the business, many companies will request a call back after long periods of time which can be up to one year, therefore, large amounts of data will remain in the database for significant periods of time. If a request to opt out of any of the marketing processes occurs, Adventoris will hold onto that data for one year, (which is be marked off as not to contact) to ensure that the company is aware this contact does not wish to be contacted via email for example, and this will ensure that the recipient is not contacted by Adventoris.

(f) processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures (‘integrity and confidentiality’).”

The data is processes within accordance of GDPR. The data is held within a secure data base, and the employees of Adventoris have been trained in the necessary data handling procedures.

 (g) The controller shall be responsible for, and able to demonstrate, compliance with the GDPR (‘accountability’).”

Joe Tully, the acting Adventoris Data Protection Officer will be responsible for maintain the data, staff training, and ensuring the company is GDPR compliant.

  1. Privacy Notice

 

All marketing information sent to the data subjects have the opportunity to opt-out, clearly displayed. Adventoris’s privacy policy is clearly displayed on the Adventoris and Swiftcloud website. The policy includes information regarding:

  1. IMPORTANT INFORMATION AND WHO WE ARE
  2. THE DATA WE COLLECT ABOUT YOU
  3. HOW IS YOUR PERSONAL DATA COLLECTED
  4. HOW WE USE YOUR PERSONAL DATA
  5. DISCLOSURES OF YOUR PERSONAL DATA
  6. INTERNATIONAL TRANSFERS
  7. DATA SECURITY
  8. DATA RETENTION
  9. YOUR LEGAL RIGHTS

 

The privacy policy has been updated to include:

  • The identity of the DPO.
  • The categories of recipients of the personal data.
  • The period for which the personal data will be stored.
  • The existence of the right to request from the controller access to and rectification, or erasure, of personal data, or a restriction of processing concerning the data subject or, to object to, processing as well as the right to data portability.
  • The right to lodge a complaint with the ICO.

 

  1. Lawfulness of data processing

 

Adventoris has established the legal basis on which grounds it processes all the direct personal data it holds.

“Processing is necessary for the purposes of the legitimate interests perused by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data”.

Adventoris relies on legitimate interests for the storing of data and marketing activities as data is proportionate, has a minimal privacy impact, and businesses would not be surprised or likely to object to the activity.

Adventoris acquires its data legally from the MINT Database, which is part of Bureau van Dijk (BvD), one of the world’s leading business information publishers, as an opted in account willing to receive marketing emails of relevance and interest.

Adventoris aims to teach and inform businesses about how implementing an app into their already existing web ordering system can enhance sales and cut costs.

Adventoris are completely transparent about this within all forms of marketing.

Adventoris do not aim to mislead in anyway about the product they are offering, and the option to unsubscribe to all marketing channels is clear within email marketing, telesales and personal emails. If any person wishes to request their data be removed this will be done immediately, or subsequently if they wish to know what data Adventoris hold on them.

Adventoris state that, the data is collected and stored, as there is a legitimate interest for the companies (within the categories outlined in section 1.3) to have knowledge and understanding of the benefits of the SwiftCloud application, which is the interest of their company can help operations, increase sales and cut costs. 

The data collected and stored by Adventoris is selectively chosen via SIC code to ensure that only the data of companies who meet the needs of their product will be contacted. Market research has been undertaken to understand which companies would have legitimate interest and would highly benefit from the SwiftCloud application, these company SIC codes are outlined in section 1.3. 

The data that Adventoris holds comes from the MINT database which states their data is accurate and up to date and cleansed on a regular basis, furthermore, Adventoris takes all necessary steps to ensure that the data held within Salesforce is regularly updated and maintained.

The data is reviewed after 1 year to establish whether the company has an interest in the SwiftCloud application. Due to the nature of the business, many companies will request a call back after long periods of time which can be up to one year, therefore, large amounts of data will remain in the database for significant periods of time.

If a request to opt out of any of the marketing processes occurs, Adventoris will hold onto that data for one year, (which is be marked off as not to contact) to ensure that the company is aware this contact does not wish to be contacted via email for example, and this will ensure that the recipient is not contacted by Adventoris.

3.1. Consent

 

All data subjects have the right to opt out of any marketing activity, this is clearly stated on all marketing materials. Once a data subject has opted out, this will be marked across their data file within Salesforce. Data subjects also have the right to be removed from the data base, and forgotten, this is outlined within the privacy policy.

Profiling and automated decision making is not currently being used by Adventoris. Adventoris, to the best of their knowledge, do not process personal or any data of Children, or anyone under the age of 18.

  1. Rights of the data subject

 

Data subjects, and employees have the right request their personal data processed by Adventoris. Adventoris have an outlined response below and usually reply within 24 hours. In the event of the DPO being away, Senior Business Development Manager, Jayne Hustwick, has a template of the response and has been trained to deal with such matters.

Adventoris have processes in place which enable data subjects to exercise their rights. Any unlawful use, or incorrect information stored will be rectified, and data subjects have the right to inform Adventoris of any issues.

 

  1. Contact Us

 

If you feel we have breached your privacy, then please write to:

Adventoris Ltd

3M Buckley Innovation Centre

Firth Street

Huddersfield

HD1 3BD

Or call customer services on 03333 447 557.