At Silver Cloud Technologies we take your privacy very seriously and Silver Cloud Technologies will comply with the obligations imposed on us by the UK Data Protection Legislation.

Silver Cloud Technologies is formed of Silver Cloud Technologies Limited. This privacy policy is issued on behalf of Silver Cloud Technologies, so when Silver Cloud Technologies is mentioned (“we”, “us”, or “our”), within this privacy policy, we are referring to Silver Cloud Technologies who are responsible for processing your data.

The UK Data protection Legislation includes the UK Data Protection Act 2018, the retained EU law version of the General Data Protection Regulation ((EU) 2016/679) (UK GDPR) and any national laws, regulations and secondary legislation, as amended or updated from time to time, and any subsequent legislation to the UK GDPR or the Data Protection Act 2018.

We will only use personal information provided by you in accordance with the provisions of our Terms Of Use and in accordance with this Privacy Policy. This Privacy Policy will be reviewed at times to take account of new laws and technology and any changes to our operational processes. Any amendments to this policy will be incorporated in an updated version. Any information we hold will be governed by our most recent Privacy Policy.

Silver Cloud Technologies is registered with the Information Commissioner’s Office:

Registration number for Silver Cloud Technologies Limited: ZA696986

SCOPE:

This policy applies to anyone who uses our website (including our portal) or who purchases or uses any of the services provided by Silver Cloud Technologies

USE OF YOUR PERSONAL INFORMATION:

Silver Cloud Technologies will need to collect and use certain personal information to be able to offer its range of products and services.

We will only use your personal information inline with the law. Most commonly, we will use your personal information in the following circumstances:

• Where we need to answer your enquiries

• Where we need to perform the contract we enter into with you and to process payments.

• Where we need to comply with a legal or regulatory obligation.

• Where it is necessary for our legitimate interests (or those of a third party) and when your interests and fundamental rights do not override those interests.

With your consent, we may also use your information:

• To advertise our products and services to you,

• To optimise your experience on our website and portal


PROMOTIONAL OFFERS FROM SILVER CLOUD TECHNOLOGIES:

We may use your information to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant to you (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 chosen to opt out of receiving that marketing.

THIRD-PARTY MARKETING:

We will always get your express opt-in consent before we share your personal data with any third party for marketing purposes.

OPTING OUT:

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you OR by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.

THE INFORMATION WE COLLECT:

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

The type of information we may collect, use, store and transfer may include (but is not limited to):

• Contact information: your name, address, telephone numbers, email addresses and other contact information

• Payment information

• Date of birth

• Video Images

• IP addresses

• IT Account information including login details

• Areas of the website used and visited, details of transactions you carry out through Silver Cloud Technologies website and the fulfilment of those transactions and links to and from third party websites.

• Information from external sources such as credit reference and identity verification agencies.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). We also do not collect any information about criminal convictions and offences.

From time to time we may ask you to voluntarily complete surveys to provide us with information for our marketing or research purposes. You do not have to respond to them and can opt out of receiving such communications at any time.

WHY WE COLLECT INFORMATION:

Silver Cloud Technologies will use your information for the following purposes:

• To provide technical support

• To open and maintain your customer account/s with us

• To install products and services remotely or on premises

• To purchase products as part of our service

• To maintain your equipment

• To confirm your identity and credit worthiness

• To answer queries

• To provide data storage including cloud storage

• To provide domains and licenses

• To provide consultancy services

• To provide security certificates

• To provide security of our staff and business

• to provide you with information, products or services that you request from us or which we feel may be of interest to you, where you have consented to be contacted for such purposes;

• To ensure that content from us is presented in the most effective manner for you and for your computer;

• To enable us to provide you with the products and services that you have requested from us and otherwise to perform our legal obligations to you;

• To manage your customer portal;

• To satisfy and meet our legal and regulatory requirements;

• To assist us for training purposes, quality assurance or to record details about the products and services you order from us;

• To allow you to take part in interactive features of our services, when you wish to do so

• To inform you of changes to our products and services.

HOW WE COLLECT INFORMATION:

We will collect information from you in the following ways:

• When making an enquiry for our services through filling in the website form, calling us or emailing us

• When using our website, through completing forms and registering to use our website and/or the customer portal and through active use of the customer portal. This includes reporting any issues with our website.

• When discussing or placing an order to subscribe to our products and services

• When we take over services from a previous provider you transfer from

• When making use of our services

• When you visit our offices (CCTV)

• Via recorded calls

• Via third party suppliers

• Via customer satisfaction surveys

INFORMATION SHARING:

In the standard operation of our business and to enable us to provide products and services to our customers, we may disclose your personal information to the following (who may be within or outside the UK):

• Successors in title to our business;

• Our third party service providers

• Professional advisors;

• Credit agencies;

• Any relevant regulatory, governmental or law enforcement authority as required by law;

• An organisation or person expressly instructed by you;

• Third parties that are necessary to provide the products and services requested by you or necessary to protect the rights, property, or safety of our other customers, agents, our employees, contractors, consultants, or others. This also includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

We require that organisations outside of Silver Cloud Technologies who handle or obtain personal information as service providers acknowledge the confidentiality and sensitivity of this information and undertake to respect any individual’s right to privacy and comply with the UK Data Protection Legislation and this policy.

SECURITY OF INFORMATION:

The safeguarding of your data is of paramount importance to us. All personal information in our possession is held securely. 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.

Additionally, 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 [email protected]

When we need to store or transfer your personal data outside of the UK, we will ensure at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that are deemed to provide a suitable level of protection for personal data.

• Where we use service providers, we may use specific contracts approved for use in the UK that offer personal data the same level of protection it has in the UK.

By providing us with your data, you agree to this transfer and storage. We will ensure that reasonable steps are taken to protect your data in accordance with this privacy notice.

In line with UK Data Protection Legislation, we have put in place processes and procedures to tackle any suspected data security breach and we will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

YOUR DUTY TO INFORM US OF CHANGES:

It is important that the personal information we hold about you is accurate and current.

It is your duty to keep us informed if your personal information changes during your working relationship with us.

DATA RETENTION:

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, this includes for the purposes of satisfying any legal, accounting, or reporting requirements.

In order to determine the appropriate retention period for personal data, we will consider the size, nature, and sensitivity of the personal data. We will also consider the potential risk of harm from unauthorised use or disclosure of your personal data, the reasons that we process your personal data and if we are able to achieve them through other means, and the applicable legal requirements.

There may be circumstances where we may anonymise your personal information so that it can no longer be associated with you. In such cases we may use the information without further notice to you. Once you are no longer a customer of Silver Cloud Technologies we will securely destroy your personal information in accordance with applicable laws and regulations.

YOUR RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RESTRICTION:

Under certain events, by law you have the right to:

• Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.

• Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no adequate reason for us continuing to process it. You will also have the right to request us to delete or remove your personal information where you have exercised your right to object to processing (see below).

• Request correction of the personal information that we hold about you. This allows you to have any incomplete or inaccurate information we hold about you corrected.

• Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your situation that makes you want to object to processing on this ground. You will also have the right to object if we are improperly processing your personal information for direct marketing purposes.

• Request the restriction of the processing of your personal information. This allows you to ask us to suspend the processing of personal information about you, for example if you wanted us to establish the reason for processing it.

• Request the transfer of your personal information to another party.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact [email protected]

FEE:

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly without grounds or is deemed excessive. Alternatively, we may refuse to comply with the request in such circumstances.

WHAT WE NEED FROM YOU:

We may require specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that your personal information is not disclosed to any person who has no right to receive it.

TIME LIMIT TO REPLY:

We try to respond to all requests within 4 weeks. On occasion, it may take us longer than this if your request is particularly intricate or you have made a large number of requests. However, we will notify you and keep you updated.

RIGHT TO WITHDRAW CONSENT:

In the situation where you have provided your consent to the collection,

processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific situation at any time. To withdraw your consent, please contact

[email protected] Once we have received communication that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another lawful reason for doing so.

QUESTIONS AND COMPLAINTS:

All questions concerning our Privacy Policy, or you would like to change your personal

information, or would you would like to make a complaint around any of our actions, which you consider to be in breach of our policy please contact our Compliance Manager directly at [email protected]

We would hope to be able to deal with any complaint you may have quickly, efficiently and to your satisfaction. You also have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.
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