PRIVACY POLICY

WEBSITE

We ask that you read this website 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. OVERVIEW
    This 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 website: https://www.changeway.co/ (“our website“). As a “data controller” we are responsible for deciding how we hold and use personal information about you.Throughout our website, we may link to other websites owned and operated by certain trusted third parties. These other third party websites may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to these other third party websites, please consult their privacy policies as appropriate.
  1. OUR COLLECTION AND USE OF YOUR PERSONAL INFORMATION
    We collect personal information about you when you access our website, contact us, request a demo of our products and/or services, request a call back, send us feedback, post material to our website and complete customer surveys or purchase software via our website. We collect this personal information from you directly, such as when you complete the contact form on the “Contact Us” page of our website.The personal information we collect about you depends on the particular activities carried out through our website. This information includes:

    • your name, company that you work for, your position and contact details (including email address and telephone number); and
    • the contents of any messages that you provide to us when completing the contact form on the “Contact Us”, “Request Demo” or “Request Enterprise Solutions” pages of our website.

    We use this personal information to:

    • respond to any messages that you may leave on our “Contact Us” page of our website (including where you request a call back);
    • to arrange a demo of our products and/or services with you;
    • notify you of any changes to our website that may affect you; and
    • add your details to our CRM system to allow us to manage our communications and sales cycle with you.
  1. 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 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 maintaining our website.
  1. WHO WE SHARE YOUR PERSONAL INFORMATION WITH
    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.
  1. 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.
  1. 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.
  1. 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

  1. 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 WEBSITE PRIVACY POLICY
    This Policy was published on 19th May 2019 and last updated on 10th June 2020]. We may change this Policy from time to time. When we make these changes we will publish the updated Policy on our website. If we make any significant changes, we will take additional steps to inform you of these via email to the email address that you provide when you accessed our website..
  1. HOW TO CONTACT US
    Please contact us, if you have any questions about this Policy or the information we hold about you or you 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 or write to
    Changeway Group Limited,
    6th Floor, Gordon Chambers,
    90 Mitchell St,
    Glasgow
    G1 3NQ.