Complitas™ Privacy Policy

Privacy Policy

This privacy policy sets out how Complitas Technology Limited ( “Complitas” ) uses and protects your personal data. This privacy policy is provided in a layered format so you can click through to the specific areas set out below.

IMPORTANT INFORMATION AND WHO WE ARE ( paragraph 1 )
TYPES OF PERSONAL DATA WE COLLECT ABOUT YOU ( paragraph 2 )
HOW IS YOUR PERSONAL DATA COLLECTED AND USED? ( paragraph 3 )
DISCLOSURES OF YOUR PERSONAL DATA ( paragraph 4 )
INTERNATIONAL TRANSFERS ( paragraph 5 )
DATA SECURITY ( paragraph 6 )
DATA RETENTION ( paragraph 7 )
YOUR LEGAL RIGHTS ( paragraph 8 )
CONTACT DETAILS ( paragraph 9 )
COMPLAINTS ( paragraph 10 )
CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES ( paragraph 11 )
THIRD PARTY LINKS ( paragraph 12 )

IMPORTANT INFORMATION AND WHO WE ARE

This privacy policy gives you information about how Complitas collects and uses your personal data through your use of this website, including any data you may provide when you contact us, engage with us or use our Complitas digital platform ( “Complitas Platform” )

Complitas Technology Limited is the controller and responsible for your personal data (collectively referred to as “Complitas”, “we”, “us” or “our” in this privacy policy).

THE TYPES OF PERSONAL DATA WE COLLECT ABOUT YOU

Personal data means any information about an individual from which that person can be identified.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data includes title, first name, last name, username or similar identifier.
Contact Data includes email address and telephone numbers.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access this website and the Complitas Platform.
Profile Data includes your username and password, details of buildings under your management and/or control, preferences, feedback and survey responses.
Usage Data includes information about how you interact with and use our website and the Complitas Platform.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity.

For example, we may aggregate individuals’ Usage Data to calculate the percentage of users accessing a specific feature on our website or Complitas Platform in order to analyse general trends in how users are interacting with our website and the Complitas Platform to help improve the website and our service offering.

HOW IS YOUR PERSONAL DATA is COLLECTED and used

How do we collect your data?

We use different methods to collect data from and about you including through:

Your interactions with us.

when you fill in online forms such as that on our Contact Us page: https://www.complitas.co.uk/contact-us.
by corresponding with us by email or phone.
creating an account on the Complitas Platform.
utilising the services available through the Complitas Platform.
request marketing to be sent to you.
give us feedback or contact us.

Automated technologies or interactions.

As you interact with our website and the Complitas Platform, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy [https://www.complitas.co.uk/complitas-cookie-policy/] for further details.

Third parties

If your employer has signed up with us, we may receive your personal data through them in order to set up your account.

What is our legal basis for processing your personal data?

The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example to allow cookies or if you subscribe to an email newsletter.

Purposes for which we will use your personal data

Delivering the Complitas Platform

Purpose/Use	Type of data	Legal basis
To set up an account on the Complitas Platform so you can access the features and services provided.	Identity, Contact	Performance of a contract with you
To manage your account with us including: Notifying you about changes to our terms or privacy policy; Providing support desk services; Responding to your queries and complaints.	Identity, Contact, Profile, Marketing and Communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and manage our relationship with you)

For the operations of Complitas’ business

Purpose/Use	Type of data	Legal basis
To administer and protect our business and this website including troubleshooting, data analysis and system testing.	Identity, Contact, Technical	(a) Necessary for our legitimate interests (for 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) (b) Necessary to comply with a legal obligation
Applying security measures to our processing of your personal data, including processing in connection with the Complitas Platform.	Identity, Contact, Technical, Usage, Profile, Marketing and Communications.	Legal obligation (applying appropriate technical and organisational measures to prevent unlawful or unauthorised access to the Complitas Platform and our website)
Sending you service messages about changes, updates and downtimes of the Complitas Platform or our website.	Identity, Contact	Performance of a contract with you
To deliver relevant website content and online advertisements to you and measure or understand the effectiveness of the advertising we serve to you	Identity, Contact, Profile, Usage, Marketing and Communications, Technical	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website and the Complitas Platform.	Technical, Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To send you relevant marketing communications and make personalised suggestions and recommendations to you about services that may be of interest to you based on your Profile Data	Identity, Contact, Technical, Usage, Profile, Marketing and Communications	Necessary for our legitimate interests (to carry out direct marketing, develop our products/services and grow our business).
To comply with our other legal obligations, including compliance with tax legislation, judicial, law enforcement and government authorities’ requests	Identity, Contact, Technical, Usage, Profile, Marketing and Communications	Necessary to comply with a legal obligation

COOKIES AND PERSONALISATION

Purpose or activity	Type of personal data	Lawful basis for processing
To deploy and process personal data collected via Cookies that are strictly necessary as set out in the cookies notice [https://www.complitas.co.uk/complitas-cookie-policy/]	Cookies	Legitimate interests (delivering and securing our website and the Complitas Platform).
To deploy and process personal data collected via Cookies that are not strictly necessary, as set out in the cookies notice [https://www.complitas.co.uk/complitas-cookie-policy/]	Cookies	Consent

Direct marketing
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving the marketing. We may also analyse your Identity, Contact, Technical, Usage and Profile Data to form a view which products, services and offers may be of interest to you so that we can then send you relevant marketing communications.

Third-party marketing
We will get your express consent before we share your personal data with any third party for their own direct marketing purposes.

Opting out of marketing
You can ask to stop sending you marketing communications at any time by following the opt-out links within any marketing communication sent to you, amending your preferences to opt-out of marketing on your account or by contacting us on support@complitas.co.uk. If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes. For example relating to updates to our terms and conditions, this privacy policy, checking that your contact details are correct.

Cookies
For more information about the cookies we use and how to change your cookie preferences, please see [https://www.complitas.co.uk/complitas-cookie-policy/].

DISCLOSURES OF YOUR PERSONAL DATA

We may share your personal data where necessary with the parties set out below:

Service providers who provide IT and system administration services, hosting services for the Complitas Platform, security monitoring, service support, email delivery and administration, and data storage and analysis.
Our partners and resellers of the Complitas Platform (where applicable) for the purposes of delivering the Complitas Platform and services to you.
Our professional advisors including lawyers, auditors, insurers, and consultants who provide legal, accounting, insurance and other services to us.
Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
HM Revenue and Customs, regulators, law enforcement, public authorities or other third parties where necessary to exercise our rights or comply with a legal obligation.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

INTERNATIONAL TRANSFERS

We do not transfer your personal data outside the UK or EU.

DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

DATA RETENTION

How long will you use my personal data for?

We retain personal data only as long as necessary for the purposes described above, including to meet legal, accounting, or reporting requirements. Typical periods include:

Type of data	Retention Periods	Reason
Contact Data, Identity Data, and Profile Data	10 years after you cease to be a customer	Tax, complying with legal or regulatory requirements including security and fraud prevention
Technical Data and Usage Data	Two years after you cease to be a customer.	Complying with legal and financial requirements and to ensure our website and the Complitas Platform’s security and prevent abuse.
Cookies Data	90 days	To retain your user preferences (such as log in details) for future sessions on our website and/or the Complitas Platform.

In some circumstances you can ask us to delete your data: see your legal rights below for further information. Once we no longer have a legal right to hold your personal data, we will delete or, in some circumstances, we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

We will only retain your personal data 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 data 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.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

YOUR LEGAL RIGHTS

You have a number of rights under data protection laws in relation to your personal data. You have the right to:

Request access to your personal data (commonly known as a “subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object. You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes (see Opting out of marketing in paragraph 3 for details of how to object to receiving direct marketing communications).
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data (see the table in section 3 for details of when we rely on your consent as the legal basis for using your data). However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
- If you want us to establish the data’s accuracy;
- Where our use of the data is unlawful but you do not want us to erase it;
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

If you wish to exercise any of the rights set out above, please contact us see Contact details (paragraph 9).

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

CONTACT DETAILS

If you have any questions about this privacy policy or about the use of your personal data or you want to exercise your privacy rights, please contact us by email at support@complitas.co.uk.

COMPLAINTS

You have the right to make a complaint to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues ( www.ico.org.uk ). However, before doing so please make sure you have first made your complaint to us or asked us for clarification if there is something you do not understand. The ICO will expect you to have done this before reviewing your complaint. Please contact us at support@complitas.co.uk.

CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

We keep our privacy policy under regular review. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address.

THIRD-PARTY LINKS

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.