Privacy Policy

1. Purpose

myConsole has prepared this Privacy Policy to outline our practices regarding the collection, use, disclosure, transfer and other processing of individually identifiable information about you (“Personal Information”) collected when you use the myConsole software or myConsole’s website. myConsole will process any Personal Information fairly and lawfully, in accordance with this Privacy Policy and in accordance with the General Data Protection Regulation (“GDPR”).

1.1 Who we are

myConsole Limited, (referred to below as “myConsole ”, “we”, “our”, “us”), believe your privacy is fundamental human right and central to good governance. This Privacy Notice covers all activities of our organisation.

Operating as a limited company registered in England and Wales (reg. 09772083), our registered office address is C/O Naylor Accountancy Services, Unit B12, Pine Grove Enterprise Centre, Crowborough, TN6 1DN United Kingdom.

 myConsole has designated Philip Collard, CEO, the person responsible for Data Protection matters at myConsole. His contact details can be found at the end of this document.

1.2 Legal basis for using your information

 All organisations need a legal reason to use your personal information, if they don’t have one, they can’t use it. There are a number of legal grounds that enable data processing. It’s quite complicated but below are the most relevant grounds you should be aware of:

2. Information collection and use

While using our software or website, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you. Personally identifiable information may include, but is not limited to your name and contact details (“Personal Information”).

 A. Personal Information Collection

Subject to this Policy, myConsole will treat as confidential the Personal Information that it collects about you. myConsole may collect the following categories of Personal Information:

(1) For users: Your name, contact information, employment information.

(2) For clients and stakeholders of myConsole users: Your name, contact information, employment information, information relating to your or your employees’ relationship with the user.

B. Purposes of Use of Personal Information

myConsole may use the Personal Information listed above for the following purposes:

(1) For users: For the purpose of managing your account on myConsole for the duration of your employment with myConsole’s client organization.

(2) For clients and stakeholders of myConsole users: For the purpose of our users following up on projects, across workflow stages or during execution. You will not receive any messaging from myConsole directly.

3. Disclosure and international transfers of personal information

(1) For subscribers/users: For the purposes of sending you our updates your Personal Information will be stored on our CRM system, the service we use to maintain our distribution lists.  We will only do this if you have given us permission to do so.

(2) For supporters, including clients and partners: We will only disclose your information internally. Disclosure externally will only be with your prior agreement or your consent via an individual user agreement or contract.

The recipients of the Personal Information that myConsole collects from you will be located in the United Kingdom or Europe, except in exceptional and temporary circumstances such as server maintenance. myConsole has taken steps to establish appropriate data protection and information security requirements with such recipients to confirm that Personal Information is properly protected in accordance with this Policy and applicable laws. If necessary and in accordance with applicable laws, myConsole may disclose Personal Information to our outside professional advisers and to other third parties that provide products or services to myConsole, such as IT systems providers.

Where the processing of Personal Information is delegated to a third-party data processor, such as that listed above, myConsole will delegate such processing in writing, will choose a data processor that provides sufficient guarantees with respect to technical and organisational security measures governing the relevant processing and will ensure that the processor acts on our behalf and under our instructions. In addition, myConsole will impose in writing appropriate data protection and information security requirements on such third-party data processors.

4. Log Data

Like many site operators, we collect information that your browser sends whenever you visit our website (“Log Data”).

This Log Data may include information such as your computer’s Internet Protocol (“IP”) address, browser type, browser version, the pages of our website that you visit, the time and date of your visit, the time spent on those pages and other statistics. This helps us to improve the site by monitoring how you use it.

We may use third-party services such as Lead Forensics to collect, monitor and analyze this in order to help us measure traffic and usage trends for the website. We collect and use this analytics information in aggregate form such that it cannot reasonably be manipulated to identify any particular individual user.

5. Changes to the policy

Should myConsole decide to substantially modify the manner in which it collects or uses Personal Information, the type of Personal Information that it collects or any other aspect of this Policy, myConsole will notify you as soon as possible of such changes by re-issuing a revised Policy on our website (http://www.myconsole.co.uk ) and on the software.

6. Accuracy of and access to your personal information

You are entitled to request and access the information that myConsole holds about you (subject to limited exceptions), as stated in General Data Protection Regulation (GDPR). In addition, you have the right to have inaccurate Personal Information corrected or removed and to object to the processing of your Personal Information. If you wish to access such Personal Information, you should apply in writing to the Operations Manager of myConsole via the details below or at the email address set out on our website (http://www.myconsole.co.uk ).

To assist us in maintaining accurate Personal Information, you must advise us of any changes to your Personal Information. In the event that myConsole becomes aware of any inaccuracy in the Personal Information that it has recorded, myConsole will correct that inaccuracy at the earliest practical opportunity.

7. Retention of Data

myConsole will maintain Personal Information for only as long as it is required to do so by or for as long as necessary for the purpose(s) for which it was collected. myConsole will remove all identifiable Personal Information when it is no longer needed for myConsole to deliver their services and fulfil its reporting obligations.  More detail about retention is included in individual service user agreements.

8. Security

myConsole maintains appropriate technical and organisational security measures including staff training to protect Personal Information against accidental or unlawful destruction, or accidental loss, alteration, unauthorised disclosure or access, in compliance with applicable laws.

9. Links to Other Websites and Services

myConsole is not responsible for the practices employed by websites or services linked to or from its website (http://http://www.myconsole.co.uk ), including the information or content contained therein. Please remember that when you use a link to go from this site to another website, our Privacy Policy does not apply to third-party websites or services. Your browsing and interaction on any third-party website or service, including those that have a link or advertisement on our website, are subject to that third-party’s own rules and policies.

10. Questions?

Please address all questions to Philip Collard, CEO of myConsole at pcollard@myConsole.co.uk or via the contact email address set out on our website (http://www.myConsole.co.uk).

 Glossary of Terms

1.     1.  Consent

GDPR defines this as any freely given specific and informed indication of wishes by which the data subject signifies their agreement to personal data relating to themselves being processed. Consent can be withdrawn after it has been given.

Where data is “sensitive”, express consent is always sought from the data subject before the data can be given to a third-party.

2. Data

Any information which will be processed, or, used on or by a computerised system, additionally it also includes information contained within a “relevant filing system” of information. Data can therefore be written, tape, photographic or digital.

3. Personal Data

Personal data means any information relating to a living individual who can be identified:

Examples of data which would fall into this category include:

• Names
• Gender
• Date of birth
• Office details
• Emails, phone number and personal address
• IP address from where registration forms are sent
• Postcode

3.     4.   Sensitive Data (termed Special Category under GDPR)

This means data which relates to sensitive aspects of a living and identifiable individual’s life, for example

• ·    when you tell us about dietary requirements, or disabilities, such as when you attend an event,
• ·    Information about your use of our products or services,
• ·    Conversations you have when you call our sales or customer support teams,
• ·    Information about the devices you use to interact with us.
• ·    Where you provide information to us about other people, you need to make sure you have their permission to do so.

4.     5.  Data Subject 

The person who is the subject of the “personal data”.

5.     6.    Data Controller

A person who determines the purposes for which, and the manner in which, any personal data are, or are to be, processed.

6.     7.   Data Processor

Any person (other than an employee of the data controller) who processes data on behalf of the data controller. The data controller retains responsibility for the actions of the data processor.

Limited Exceptions

Processing of personal and sensitive data including responding to a Subject Access Request may, in rare circumstances, be restricted when personal data is subject to situations involving “crime and taxation purposes” which include:

• the prevention or detection of crime;
• the capture or prosecution of offenders; and
• the assessment or collection of tax or duty.

7. 8.    Processing

Covers almost anything which is done with or to the data, including:

• obtaining data
• recording or entering data onto the files
• holding data, or keeping it on file without doing anything to it or with it
• organising, altering or adapting data in any way
• retrieving, consulting or otherwise using the data
• disclosing data either by giving it out, by sending it on email, or simply by making it available
• combining data with other information
• erasing or destroying data
• using the data within research

8.     9.  Recipient 

Any person to whom the data are disclosed, including any person to whom they are disclosed in the course of processing the data for the Data Controller (e.g. an employee of the data controller, a data processor or employee of the data processor).

9. 10.  Subject Access Request

The process by which individuals can find out what personal or sensitive data an organisation holds about them, why they hold it and who they disclose it to.

10.   11. Third Party

A natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor are authorised to process personal data.

11.   12. How we share your personal information

Where you provide your information to us we do not share it with any third parties except in the performance of a contract or in anticipation of a contract. Your information will only be shared and used in accordance with this notice, and where an agreement is in place to ensure that your information is protected. We won’t sell your personal information without your consent.

 For example, we will share your information with a finance company for the administrative purposes of providing you or your organisation credit facilities, as well as making sure information is accurate, up to date and to enable business planning and continuity.

12.   13. Sharing with our processors

 There may be situations where we use data processors – companies who act on our behalf – to process your information for us. These processors can only use your information in accordance with our instructions and for the purposes in this Policy.

13.   14. Sale of our business

 If we restructure or sell all or part of our business or business operations, we may transfer your information as part of that activity. Where this is the case your information will be used in accordance with this Notice unless you are notified otherwise.

14. 15.  Access and Control

Controlling direct marketing

 You can change your mind about receiving direct marketing from us or change your preferences by logging into your account, if you have one. Opting-out in any marketing or product communication you have received from us or emailing us using the contact details below.

15. 16.  Controlling other communications

 You can control the communications you receive from us, such as product related communications, by logging into your account, by following the instructions in any relevant communication.

16.   17. Requesting copies of your information

You may request a copy of your personal information, which we may hold about you. You may also ask us to correct any inaccuracies in your personal information. This right may be restricted by law where disclosing information may result in the personal information of other individuals being disclosed, and it would be unreasonable to do so.

17.   18. Withdrawing consent

Where we may rely on consent to use your information, you have the right to withdraw that consent for that processing activity at any time. However, we may have the right to rely on an alternative legal basis for the processing activity and will inform you of that.

 If you do withdraw consent, we may not be able to provide you with the product or service you have requested.

18. 19.  Other rights

You may have the right to object, erase, or restrict our processing of your information – for example, where we process your personal information because this is in our legitimate interests, you may object to this. We will carefully consider your request as there may be circumstances which require us to, or allow us to, continue processing your data.

19. 20.  Complaining to the regulator

If you have any comments, concerns or complaints about our use of your information, we would ask that you contact us first, so that we can try and resolve any matter.

 However, where we are unable to help, you are able to complain to the Information Commissioner’s Office in the United Kingdom or the data protection regulator in your country of residence, who will be able to liaise with the UK Information Commissioner in the UK.

20.   21.  Retention of your information

We shall retain your information in accordance with our records retention policy, or for as long as necessary for the uses set out in this notice or while there is a legitimate business reason for doing so.

 If you ask us to delete your information before this time, we may not be able to do so for technical, legal, regulatory or contractual constraints. For example, where you wish to be suppressed from direct marketing, we would need to retain your information for this purpose.

 Where you ask for your account to be closed, we will do this as soon as possible, subject to any terms and conditions relating to the account. Your information will be retained in order to comply with legal and regulatory obligations as well as for analysis, to prevent fraud, collect any monies owed, and to resolve disputes.

Complaints, Questions and Assistance

You are encouraged to raise any issues with our Data Protection Office by sending an email to pcollard@myConsole.co.uk, or by post addressed to:

 The Data Protection Officer, myConsole Ltd C/O Naylor Accountancy Services, Unit B12, Pine Grove Enterprise Centre, Crowborough, TN6 1DN United Kingdom

 Alternatively, you may raise your queries or concerns with the Supervisory Authority. In the United Kingdom, this is the Information Commissioner’s Office:

 by Email: casework@ico.org.uk

by telephone: 0303 123 1113 (local rate) or 01625 545 745 (national rate)

by post: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF