PRIVACY POLICY

APPLICATION

We ask that you read this application privacy policy (“Policy“) carefully as it contains important information on who we are, how and why we collect, store, use and share personal information, your rights in relation to your personal information and on how to contact us and supervisory authorities in the event you have a complaint.

  1. OVERVIEWThis Policy governs the manner in which Changeway Group Limited, a company registered in Scotland under company number SC630615 with its registered office at 6th Floor Gordon Chambers, 90 Mitchell Street, Glasgow, Scotland, G1 3NQ (“we“, “us” and “our“) collects, uses, maintains and discloses information collected from users (“you” or “your“) of our application: Changeway (including its associated software modules) (“Application“). As a “data controller” we are responsible for deciding how we hold and use personal information about you.
  2. OUR COLLECTION AND USE OF YOUR PERSONAL INFORMATION
    We collect personal information about you when you access our Application, use our products and/services which are available through the Application and contact us. We collect this personal information from you directly, such as when you sign up to the Application.We also collect personal information about you from other sources as follows:

    • through email enquiries to any of the email addresses used by @changeway.co that may be submitted by your employer.

    The personal information we collect about you depends on the particular activities carried out through the Application. This information includes:

    • your full name;
    • company that you work for;
    • business address and postcode; and
    • contact details (including company email address and company telephone number).

    We use this personal information to:

    • make the Application available to you;
    • make available our products and/or services to you through the Application;
    • conduct internal analytics for the development and improvement of the Application and our products and services;
    • conduct analytics to provide you with insight and inference to help inform you how to achieve improved changed outcomes;
    • respond to queries on social media platforms (e.g. LinkedIn, Twitter or WhatsApp) that you choose to contact us on and respond to email queries submitted to any of the email addresses used by @changeway.co;
    • market our products and services;
    • maintain security in the Application; and
    • notify you of any changes to the Application that may affect you.
  3. OUR LEGAL BASIS FOR PROCESSING YOUR PERSONAL INFORMATION
    When we use your personal information, we are required to have a legal basis for doing so. There are various different legal bases on which we may rely, depending on what personal information we process and why. Most commonly, we will use your personal information in the following circumstances:

    • 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; or
    • where we need to comply with a legal obligation.

    Where appropriate, we may rely on the following legitimate interests as our lawful basis for processing:

    • to provide our products and/or services to you through the Application;
    • to develop our services and grow our business;
    • provide you with demos of our products and/or services;
    • to address and resolve any questions or complaints that you may have about us or our products and/or services; and/or
    • for running our business and to maintain our Application.
  4. WHO WE SHARE YOUR PERSONAL INFORMATION WITHIn our Application, we may link to other websites or applications owned and operated by certain trusted third parties. These other third party websites or applications may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to these other third party websites or applications, please consult their privacy policies as appropriate.We will share personal information with law enforcement, regulators and/or other authorities if required by applicable law. We will not share your personal information with any other third party.
  1. TRANSFER OF YOUR INFORMATION OUT OF THE UK AND EEA
    We store your personal information in the European Economic Area.
  2. HOW LONG WE KEEP YOUR PERSONAL INFORMATION
    We will only retain your personal information for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
  3. KEEPING YOUR PERSONAL INFORMATION SECURE
    We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
  4. YOUR RIGHTS
    You may contact us using any of our details below (see “How to Contact Us“) to:

    • request a copy of your personal information;
    • request for your personal information to be removed (and we are not otherwise entitled to retain that information);
    • request for your personal information to be corrected, if it is inaccurate;
    • object to the processing of your personal information;
    • request the restriction of processing of your personal information;
    • request the transfer of your personal information in a readable format (where applicable); or
    • withdraw your consent at any time in relation to any activity for which you have provided your consent.

    For further information on each of these rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation

  5. HOW TO COMPLAIN
    We hope that we can resolve any queries or concerns you raise about our use of your personal information. If you have a complaint, please contact us in the first instance in accordance with section 11 below and we will do our best to resolve your complaint.However, you do have the right to lodge a complaint with a supervisory authority where you have concerns regarding how we use your personal information.The supervisory authority in the United Kingdom is the Information Commissioner’s Office who may be contacted at https://ico.org.uk/make-a-complaint/ or by telephone: 0303 123 1113.
  1. CHANGES TO THIS APPLICATION PRIVACY POLICY
    This Policy was first published on 10th June 2020 and last updated on N/A. We may change this Policy from time to time, when we do we will inform you via an email to the email address you used to access the Application.
  1. HOW TO CONTACT US
    Please contact us, if you have any questions about this Policy or the information we hold about you or wish to exercise any of your rights under section 8 above. If you wish to contact us, please send an email to admin@changeway.co write to: Changeway Group Limited, 6th Floor, Gordon Chambers, 90 Mitchell St, Glasgow G1 3NQ.