Who we are:

This privacy policy tells you what to expect when we collect and process your personal information through your use of coalescent.uk (the ‘Site’ or ‘Coalescent’).

coalescent.uk is provided by Coalescent (‘We’, ‘Us’, ‘Our’) of Lorentz Botley road, Curbridge, Southampton. SO30 2HB.

Coalescent is the data controller and responsible for your personal information provided to or gathered by the site.

What this policy does not apply to:

This privacy policy does not apply to any data collected, processed or otherwise dealt with in accordance with the End User Licence Agreement (EULA). The EULA applies when you use our cloud Digital DPIA case management software solution.

What this policy applies to:

Where we refer to Data Protection Law below this means;

• unless and until the GDPR is no longer directly applicable in the UK, the General Data Protection Regulation ((EU) 2016/679) and any national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK, and then
• any successor legislation to the GDPR or the Data Protection Act 2018.

Your privacy is important to us and we will process your data in accordance with Data Protection Law. This says that the personal information we hold about you must be:

• Used lawfully, fairly and in a transparent way.
• Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
• Relevant to the purposes we have told you about and limited only to those purposes.
• Accurate and kept up to date.
• Kept only as long as necessary for the purposes we have told you about.
• Kept securely.

In the event that you believe that there has been a personal data breach, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.

Information we hold about you:

Personal data, or personal information, means any information that relates to an identified or identifiable individual. It does not include data where the identity has been removed (anonymous data). We will collect, store, and use the following categories of personal information about you:

• Identity data such as first name, last name and organisation.
• Contact data such as addresses, telephone numbers, and email addresses.

If you fail to provide personal information:

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

How we use your information:

We will only use your personal information when the law allows us to.

To administer and protect our business and site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) we will use your personal information where it is necessary to comply with a legal obligation or for our legitimate interests (running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise), or those of a third party, but only where your interests and fundamental rights do not override our interests.

To use data analytics to improve our site, services, marketing, customer relationships and experiences where it is necessary to comply with a legal obligation or for our legitimate interests (to define types of customers for our products and services, to keep our site updated and relevant, to develop our business and to inform our marketing strategy), but only where your interests and fundamental rights do not override our interests.

To make suggestions and recommendations to you about services that may be of interest to you where it is necessary for our legitimate interests (to develop our products/services and grow our business), but only where your interests and fundamental rights do not override our interests.

We may also use your personal information in the following situations, which are likely to be rare:

• where we need to protect your interests (or someone else’s interests); or
• where it is needed in the public interest.

Situations in which we will use your personal information:

We need all the categories of information we keep about you primarily to allow us to use your personal information to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests. The situations in which we will process your personal information are listed below:

• To provide the relevant service or feature that you have requested.
• To manage your preferences.
• To gather statistics around email opening and clicks using industry standard technologies to help us monitor and improve our newsletters and email subscriptions.
• To ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution.

Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.

You will have the ability to unsubscribe from any repeat communications at any time.

Change of purpose:

We need all the categories of information we keep about you primarily to allow us to use your personal information to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests. The situations in which we will process your personal information are listed below:

• To provide the relevant service or feature that you have requested.
• To manage your preferences.
• To gather statistics around email opening and clicks using industry standard technologies to help us monitor and improve our newsletters and email subscriptions.
• To ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution.

Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.

You will have the ability to unsubscribe from any repeat communications at any time.

Data sharing

We may have to share your data with third parties, including third-party service providers. We require third parties to respect the security of your data and to treat it in accordance with the law. We may transfer your personal information outside the EU, as set out in  “Transferring information outside the EU” below. If we do, you can expect a similar degree of protection in respect of your personal information.

Why might you share my personal information with third parties?

We will share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so.

Which third-party service providers process my personal information?

“Third parties” includes third-party service providers (including contractors and designated agents). The following categories of third-party service providers process personal information about you for the following purposes:

• Service providers acting as processors based in the UK who provide IT, development and system administration services.
• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.
• Regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

How secure is my information with third-party service providers?

All our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

What about other third parties?

We may share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal information with a regulator or to otherwise comply with the law.

Transferring information outside the EU

As our customer relationship software provider (ActiveCampaign) is based in the United States we may have to transfer your personal data out of the EEA. As our provider is part of the Privacy Shield framework it is required to provide your personal data with similar protection as it would receive inside the EEA. See further details here.

Data security

We have put in place measures to protect the security of your information. Details of these measures are available upon request. 

Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. Details of these measures may be obtained from our Data Protection Officer.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

Duration

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. We will retain and securely destroy your personal information in accordance with our data retention rules that are available on request.