- 1. Introduction
- 1.1 We are committed to safeguarding the privacy of our website visitors, service users, individual
customers and customer personnel.
- 1.2 This policy applies where we are acting as a data controller with respect to the personal data of such
persons; in other words, where we determine the purposes and means of the processing of that personal data.
- 1.3 Our website incorporates privacy controls which affect how we will process your personal data. By using
the privacy controls, you can specify whether you would like to receive direct marketing communications and
limit the collection, sharing and publication of your personal data. You can access the privacy controls
- 1.5 In this policy, "we", "us" and "our" refer to Proteus-Cyber Ltd. For more information about us, see
- 2. The personal data that we collect
- 2.1 In this Section 2 we have set out the general categories of personal data that we process and, in the
case of personal data that we did not obtain directly from you, information about the source and specific
categories of that data.
- 2.2 We may process data enabling us to get in touch with you ("contact data"). The contact
data may include your name, email address, telephone number, postal address and/or social media account
identifiers. The source of the contact data is you and/or your employer.
- 2.3 We may process your website user account data ("account data"). The account data may
include your account identifier, name, email address, business name, account creation and modification
dates, website settings and marketing preferences. The primary source of the account data is you and/or your
employer, although some elements of the account data may be generated by our website. If you log into our
website using a social media account, we will obtain elements of the account data from the relevant social
media account provider.
- 2.4 We may process information relating to our customer relationships ("customer relationship
data"). The customer relationship data may include your name, the name of your business or
employer, your job title or role, your contact details, your classification / categorisation within our
customer relationship management system and information contained in or relating to communications between
us and you, or between us and your employer. The source of the customer relationship data is you and/or your
- 2.5 We may process your personal data that are provided in the course of the use of our services and
generated by our services in the course of such use ("service data"). The service data may
include email address, services used, renewal date and search preferences. The source of the service data is
you and/or your employer and/or our services.
- 2.6 We may process information relating to transactions, including purchases of goods and/or services, that
you enter into with us and/or through our website ("transaction data"). The transaction
data may include your name, company name, your contact details, your payment card details (or other payment
details) and the transaction details. The source of the transaction data is you and/or our payment services
- 2.7 We may process information contained in or relating to any communication that you send to us or that we
send to you ("communication data"). The communication data may include the communication
content and metadata associated with the communication. Our website will generate the metadata associated
with communications made using the website contact forms.
- 2.8 We may process data about your use of our website and services ("usage data"). The
usage data may include your IP address, geographical location, browser type and version, operating system,
referral source, length of visit, page views and website navigation paths, as well as information about the
timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking
- 2.9 Please do not supply any other person's personal data to us, unless we prompt you to do so.
- 3. Purposes of processing and legal bases
- 3.1 In this Section 3, we have set out the purposes for which we may process personal data and the legal
bases of the processing.
- 3.2 Operations - We may process your personal data for the purposes of operating our
website, providing our services, supplying our goods, generating invoices, bills and other payment-related
documentation, and credit control. The legal basis for this processing is our legitimate interests, namely
the proper administration of our website, services and business.
- 3.3 Relationships and communications - We may process contact data, account data, customer
relationship data, transaction data and/or communication data for the purposes of managing our
relationships, communicating with you (excluding communicating for the purposes of direct marketing) by
email, SMS, post, fax and/or telephone, providing support services and compliant handling. The legal basis
for this processing is our legitimate interests, namely communications with our website visitors, service
users, individual customers and customer personnel, the maintenance of our relationships, enabling the use
of our services, and the proper administration of our website, services and business.
- 3.5 Personalisation - We may process account data, service data and/or usage data for the
purposes of personalising the content and advertisements that you see on our website and through our
services to ensure that you only see material that is relevant to you. The legal basis for this processing
- 3.6 Direct marketing - We may process contact data, account data, profile data, customer
relationship data and/or transaction data for the purposes of creating, targeting and sending direct
marketing communications by email, SMS, post and/or fax and making contact by telephone for
marketing-related purposes. The legal basis for this processing is consent.
- 3.7 Research and analysis - We may process usage data, service data and/or transaction data
for the purposes of researching and analysing the use of our website and services, as well as researching
and analysing other interactions with our business. The legal basis for this processing is consent.
- 3.8 Record keeping - We may process your personal data for the purposes of creating and
maintaining our databases, back-up copies of our databases and our business records generally. The legal
basis for this processing is our legitimate interests, namely ensuring that we have access to all the
information we need to properly and efficiently run our business in accordance with this policy.
- 3.9 Security - We may process your personal data for the purposes of security and the
prevention of fraud and other criminal activity. The legal basis of this processing is our legitimate
interests, namely the protection of our website, services and business, and the protection of others.
- 3.10 Insurance and risk management - We may process your personal data where necessary for
the purposes of obtaining or maintaining insurance coverage, managing risks and/or obtaining professional
advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our
business against risks.
- 3.11 Legal claims - We may process your personal data where necessary for the
establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or
out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the
protection and assertion of our legal rights, your legal rights and the legal rights of others.
- 3.12 Legal compliance and vital interests - We may also process your personal data where
such processing is necessary for compliance with a legal obligation to which we are subject or in order to
protect your vital interests or the vital interests of another natural person.
- 4. Providing your personal data to others
- 4.1 We may disclose your personal data to any member of our group of companies (this means our subsidiaries,
our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and
on the legal bases, set out in this policy.
- 4.2 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably
necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining
- 4.3 Your personal data held in our website database
- 4.4 We may disclose contact details and enquiry details to our suppliers or subcontractors insofar as
reasonably necessary to respond to your enquiries.
- 4.5 Financial transactions relating to our website and services may be handled by our payment services
providers, Stripe. We will share transaction data with our payment services providers only to the extent
necessary for the purposes of processing your payments, refunding such payments and dealing with complaints
and queries relating to such payments and refunds. You can find information about the payment services
providers' privacy policies and practices at https://stripe.com/gb/privacy.
- 4.6 We may disclose contact data along with any other personal data contained in enquiries made through our
website or services to one or more of those selected third party suppliers of goods and/or services
identified on our website for the purpose of enabling them to contact you so that they can offer, market and
sell to you relevant goods and/or services. Each such third party will act as a data controller in relation
to the personal data that we supply to it; and upon contacting you, each such third party will supply to you
- 4.7 In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your
personal data where such disclosure is necessary for compliance with a legal obligation to which we are
subject, or in order to protect your vital interests or the vital interests of another natural person. We
may also disclose your personal data where such disclosure is necessary for the establishment, exercise, or
defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
- 5. International transfers of your personal data
- 5.1 In this Section 5, we provide information about the circumstances in which your personal data may be
transferred to countries outside the United Kingdom and the European Economic Area (EEA).
- 5.2 The hosting facilities for our website are situated in Germany and Ireland. Transfers to each of these
countries will be protected by appropriate safeguards, namely the use of standard data protection clauses
adopted or approved by the competent data protection authorities.
- 5.3 Software development and support subcontractors are situated in Hungary and the UK. The competent data
protection authorities have made an "adequacy decision" with respect to the data protection laws of each of
these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely
the use of standard data protection clauses adopted or approved by the competent data protection
- 5.4 You acknowledge that personal data that you submit for publication through our website or services may
be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal
data by others.
- 6. Retaining and deleting personal data
- 6.1 This Section 6 sets out our data retention policies and procedures, which are designed to help ensure
that we comply with our legal obligations in relation to the retention and deletion of personal data.
- 6.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary
for that purpose or those purposes.
- 6.3 We will retain your personal data as follows:
- (a) contact data will be retained for a minimum period of 12 months following the date of the most
recent contact between you and us, and for a maximum period of 60 months following that date;
- (b) account data will be retained for a period of 1 month following the date of closure of the
- (c) customer relationship data will be retained for a minimum period of 12 months following the date
of termination of the relevant customer relationship and for a maximum period of 60 months following
- (d) service data will be retained for a minimum period of 12 months following the date of
termination of the relevant contract, and for a maximum period of 60 months following that date;
- (e) transaction data will be retained for a minimum period of 12 months following the date of the
transaction, and for a maximum period of 60 months following that date;
- (f) communication data will be retained for a minimum period of 12 months following the date of the
communication in question, and for a maximum period of 74 months following that date;
- (g) usage data will be retained for 60 months following the date of collection.
- 6.4 In some cases it is not possible for us to specify in advance the periods for which your personal data
will be retained. In such cases, we will determine the period of retention based on the following criteria:
- (a) the period of retention of transaction data will be determined based on current legislation.
- 6.5 If you grant to us a licence to publish any of your personal data, we may continue to retain and publish
that personal data after the end of the relevant retention period specified in this Section 6 in accordance
with the applicable licence terms, subject to your data subject rights. If we cease to publish such personal
data after the end of the relevant retention period specified in this Section 6, that personal data will be
retained for minimum period of 1 month and a maximum period of 60 months following the date that publication
- 6.6 Notwithstanding the other provisions of this Section 6, we may retain your personal data where such
retention is necessary for compliance with a legal obligation to which we are subject, or in order to
protect your vital interests or the vital interests of another natural person.
- 7. Security of personal data
- 7.1 We will take appropriate technical and organisational precautions to secure your personal data and to
prevent the loss, misuse or alteration of your personal data.
- 7.2 We will store your personal data on secure servers, personal computers and mobile devices, and in secure
manual record-keeping systems.
- 7.3 The following personal data will be stored by us in encrypted form: your name, contact information,
password(s) and cardholder data.
- 7.4 Data relating to your enquiries and financial transactions that is sent from your web browser to our web
server, or from our web server to your web browser, will be protected using encryption technology.
- 7.5 You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet
is inherently insecure, and we cannot guarantee the security of data sent over the internet.
- 7.6 You should ensure that your password is not susceptible to being guessed, whether by a person or a
computer program. You are responsible for keeping the password you use for accessing our website
confidential and we will not ask you for your password (except when you log in to our website).
- 8. Your rights
- 8.1 In this Section 8, we have listed the rights that you have under data protection law.
- 8.2 Your principal rights under data protection law are:
- (a) the right to access - you can ask for copies of your personal data;
- (b) the right to rectification - you can ask us to rectify inaccurate personal data
and to complete incomplete personal data;
- (c) the right to erasure - you can ask us to erase your personal data;
- (d) the right to restrict processing - you can ask us to restrict the processing of
your personal data;
- (e) the right to object to processing - you can object to the processing of your
- (f) the right to data portability - you can ask that we transfer your personal data
to another organisation or to you;
- (g) the right to complain to a supervisory authority - you can complain about our
processing of your personal data; and
- (h) the right to withdraw consent - to the extent that the legal basis of our
processing of your personal data is consent, you can withdraw that consent.
- 8.3 These rights are subject to certain limitations and exceptions. You can learn more about the rights of
data subjects by
visiting https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/ .
- 8.4 You may exercise any of your rights in relation to your personal data by written notice to us, using the
contact details set out below.
- 9. Third party websites
- 9.1 Our website includes hyperlinks to, and details of, third party websites.
- 9.2 In general we have no control over, and are not responsible for, the privacy policies and practices of
- 10. Personal data of children
- 10.1 Our website and services are targeted at persons over the age of 18.
- 10.2 If we have reason to believe that we hold personal data of a person under that age in our databases, we
will delete that personal data.
- 11. Updating information
- 11.1 Please let us know if the personal information that we hold about you needs to be corrected or
- 12. Acting as a data processor
- 12.1 In respect of data we hold on behalf of our customers (“customer data”), we do not act as a data
controller; instead, we act as a data processor.
- 12.2 Insofar as we act as a data processor rather than a data controller, this policy shall not apply. Our
legal obligations as a data processor are instead set out in the contract between us and the relevant data
- 13. About cookies
- 13.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web
server to a web browser and is stored by the browser. The identifier is then sent back to the server each
time the browser requests a page from the server.
- 13.2 Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by
a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry
date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser
- 13.3 Cookies may not contain any information that personally identifies a user, but personal data that we
store about you may be linked to the information stored in and obtained from cookies.
- 14. Cookies that we use
website and as you
navigate our website, and to help us determine if you are logged into our website;
website for you;
including preventing fraudulent use of login credentials, and to protect our website and services
- 14.2 Further details about the above cookies can be found by
- 15. Cookies used by our service providers
- 15.2 We use Google Analytics. Google Analytics gathers information about the use of our website by means of
cookies. The information gathered is used to create reports about the use of our website. You can find out
more about Google's use of information by visiting https://www.google.com/policies/privacy/partners/ and you
- 15.3 We use a Facebook pixel on our website. Using the pixel, Facebook collects information about the users
and use of our website. The information is used to personalise Facebook advertisements and to analyse the
use of our website. To find out more about the Facebook pixel and about Facebook's use of personal data
user, you can adjust how advertisements are targeted by following the instructions at
- 16. Managing cookies
- 16.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so
vary from browser to browser, and from version to version. You can however obtain up-to-date information
about blocking and deleting cookies via these links:
- 16.2 Blocking all cookies will have a negative impact upon the usability of many websites.
- 16.3 If you block cookies, you will not be able to use all the features on our website.
- 17. Cookie preferences
- 18. Amendments
- 18.1 We may update this policy from time to time by publishing a new version on our website.
- 18.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
- 19. Our details
- 19.1 This website is owned and operated by Proteus-Cyber Ltd.
- 19.2 We are registered in England and Wales under registration number 07239733, and our registered office is
at Greendale, Ray Park Road, Maidenhead SL6 8QU, United Kingdom.
- 19.3 Our principal place of business is at 20-22 Wenlock Road, London N1 7GU, United Kingdom.
- 19.4 You can contact us:
- (a) by post, to the postal address given in 19.3 above;
- (b) using our website contact form;
- (c) by telephone, on the contact number published on our website; or
- (d) by email, using the email address published on our website.
- (e) our DSAR page: https://proteuscyber.com/ja/site/dsar