Strillobyte Ltd (“we”, “our”, “us” or “Strillobyte”) is committed to protecting the privacy of all users of our website Strillobyte.com, newsletter and social media channels, (the "Sites"). Please read the following privacy policy that explains how we use and protect your information.
1. Contact details
If you have any queries or requests concerning this privacy policy or how we handle your data more generally, please get in touch at hello@strillobyte.com.
2. How we collect your information
We collect your personal information when you interact with us. We also look at how visitors use our Sites, to help us improve our services and optimise customer experience.
We collect information about our users for four main reasons:
To provide a personalised experience unique to individual users;
To help us monitor and improve our services;
To send them direct correspondence we think might be relevant to their interests.
To serve users with relevant ads about Strillobyte on our websites and on third-party websites, including Google and its partners.
We collect information:
when you contact us directly via email, phone, or post;
when you sign up for our newsletters; and
when you browse and use our Sites.
We also collect information from third party sites, such as advertising platforms.
3. Information that we collect from you
As part of our commitment to the privacy of our customers and visitors to our Sites more generally, we want to be clear about the sorts of information we will collect from you.
We collect information about your usage of the Sites and information about you from any messages you post to the Sites or when you contact us or provide us with feedback, including via e-mail, letter, phone or any other feedback form.
We collect technical information from your mobile device or computer, such as its operating system, the device and connection type and the IP address from which you are accessing our Sites.
We also collect technical information about your use of our services through a mobile device, for example, carrier, location data and performance data. Unless you have elected to remain anonymous through your device and/or platform settings, this information may be collected and used by us automatically if you visit our website through your mobile’s browser or otherwise.
4. Use of your information
We will only process the data we collect about you if there is a reason for doing so, and if that reason is permitted under data protection law. We will have a lawful basis for processing your information: if we need to process your information in order to provide you with the service you have requested or to enter into a contract; we have your consent; we have a justifiable reason for processing your data; or we are under a legal obligation to do so.
Where we need to in order to provide you with the service you have requested or to enter into a contract, we use your information:
to supply the services you have requested;
to contact you where necessary concerning our services, such as to resolve issues you may have with your purchase.
We also process your data where we have a justifiable reason for doing so — for example personalisation of our service. We have listed these reasons below:
to improve the effectiveness and quality of service that our customers can expect from us in the future;
to tailor content that we or our third party advertising partners display to you, for example to make sure you see the advertising which is most relevant to you, based on characteristics determined by us;
to enable our customer support team to help you with any enquiries or complaints in the most efficient way possible;
to contact you for your views and feedback on our services and to notify you if there are any important changes or developments to the Sites or our services;
to analyse your activity on the Sites so that we can administer, support, improve and develop our services and for statistical and analytical purposes; and
if you submit comments and feedback regarding the Sites and the services, we may use such comments and feedback on the Sites and in any marketing or advertising materials. We will seek your permission before we do this.
Where we rely on legitimate interest as a basis for processing your personal information, we carry out a ‘balancing test’ to ensure that our processing is necessary and that your fundamental rights of privacy are not outweighed by our legitimate interests. You can find out more information about these balancing tests by contacting us using the details above.
Where we are under a legal obligation to do so we may use your information to:
create a record of your order(s);
comply with any legal obligation to which we are subject.
5. Cookies
6. Direct Marketing
Where you have given your consent or where we have a justifiable reason for doing so (and are permitted to do so by law) we will use your information to let you know about our new services and other information that may be of interest to you. You can control your email marketing preferences through the “Unsubscribe” link at the bottom of all emails sent out by us.
7. Retention of your information
We will not retain your information for any longer than we think is necessary.
Information that we collect will be retained for as long as needed to fulfil the purposes outlined in the ‘Use of your information’ section above, in line with our legitimate interest or for a period specifically required by applicable regulations or laws.
When determining the relevant retention periods, we will take into account factors including:
our contractual obligations and rights in relation to the information involved;
legal obligation(s) under applicable law to retain data for a certain period of time;
statute of limitations under applicable law(s);
our legitimate interests where we have carried out balancing tests (see section on ‘Use your personal information’ above);
(potential) disputes; and
guidelines issued by relevant data protection authorities.
Otherwise, we securely erase your information where we no longer require your information for the purposes collected.
8. Disclosure of your information
The information we collect about you will be transferred to and stored on our servers, which may be at a destination outside the European Economic Area (“EEA”), such as the United States, depending on where our suppliers are based. Information may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the fulfilment of an order placed by you via the Sites, the processing of your payment details and the provision of support services. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy and, to the extent that such transfer is within our control, with the relevant data protection laws.
Sharing your information with third parties
We share your information with third party service providers. The types of third party service providers whom we share your information with includes:
IT service providers (including cloud providers): for the purposes of data storage and analysis;
Customer support partners: who will help us to resolve any issues you may have with our services; and
Marketing and advertising partners: so that they can ensure that you see advertising which is more relevant to you and send you email marketing on our behalf.
If Strillobyte Limited enters into a joint venture with, purchases or is sold to or merged with another business entity, your information may be disclosed or transferred to the target company, our new business partners or owners or their advisors.
We may also share your information:
if we are under a duty to disclose or share your information in order to comply with (and/or where we believe we are under a duty to comply with) any legal obligation or regulatory requirement. This includes exchanging information with other companies and other organisations for the purposes of fraud protection and prevention;
in order to enforce our contractual terms with you and any other agreement; and
with such third parties as we reasonably consider necessary in order to prevent crime, e.g. the police.
Please contact us using the contact details above if you want further information on the countries to which personal data may be transferred and the specific mechanism used by us when transferring your personal data out of the EEA.
9. Security
We adopt robust technologies and policies to ensure the personal information we hold about you is suitably protected.
We take steps to protect your information from unauthorised access and against unlawful processing, accidental loss, destruction and damage.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will take steps to protect your information, we cannot guarantee the security of your data transmitted to the Sites; any transmission is at your own risk.
Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
10. Your rights
Under data protection law, you may have a number of rights concerning the data we hold about you. If you wish to exercise any of these rights, please contact us using the contact details above.
For additional information on your rights please contact your data protection authority and see below.
The right to be informed. You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we’re providing you with the information in this policy.
The right of access. You have the right to obtain access to your information (if we’re processing it). This will enable you, for example, to check that we’re using your information in accordance with data protection law. If you wish to access the information we hold about you in this way, please get in touch (see Contact Details).
The right to rectification. You are entitled to have your information corrected if it is inaccurate or incomplete. You can request that we rectify any errors in information that we hold by contacting us (see Contact Details).
The right to erasure. This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of certain of the information that we hold about you by contacting us (see Contact Details).
The right to restrict processing. You have rights to ‘block’ or ‘suppress’ further use of your information. When processing is restricted, we can still store your information, but will not use it further.
The right to data portability. You have the right to obtain your personal information in an accessible and transferrable format so that you can re-use it for your own purposes across different service providers. This is not a general right however and there are exceptions. To learn more please get in touch (see Contact Details).
The right to lodge a complaint. You have the right to lodge a complaint about the way we handle or process your information with the national data protection authority.
The right to withdraw consent. If you have given your consent to anything we do with your information (i.e. we rely on consent as a legal basis for processing your information), you have the right to withdraw that consent at any time. You can do this by contacting us (see Contact Details). Withdrawing consent will not however make unlawful our use of your information while consent had been apparent.
The right to object to processing. You have the right to object to certain types of processing, including processing for direct marketing. You can object by changing your marketing preferences or disabling cookies as set out in sections 5 and 6 above.
11. Changes to our privacy policy
Any changes to our privacy policy will be posted to the Sites and, where appropriate, we will notify you of the changes by email.
This privacy policy was last updated: 25/05/2018
12. Complaints
If you’re not satisfied with our response to any complaint or believe our processing of your information does not comply with data protection law, you can make a complaint to the Information Commissioner’s Office (ICO) using the following details:
Address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF
Telephone number: 0303 123 1113
Website: www.ico.org.uk
