Privacy Policy - Sonra

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint.

 

We collect, use and are responsible for certain personal data about you. When we do so we are subject to the EU General Data Protection Regulation (EU GDPR) in relation to services we offer to our clients in the European Economic Area (EEA).

1. Key Terms

It would be helpful to start by explaining some key terms used in this policy:

 

We, us, our Sonra Intelligence Limited, a company registered in Ireland under company number 547986 and having its registered office at 6-9 Trinity Street Dublin 2
Personal data Any information relating to an identified or identifiable individual
Special category personal data Personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership;

Genetic and biometric data (when processed to uniquely identify an individual); and

Data concerning health, sex life or sexual orientation

Data subject The individual who the personal data relates to

 

2. Personal Data We Collect About You

We may collect and use the following personal data about you:

  1. your name and contact information, including email address and telephone number and company details;
  2. information to check and verify your identity, e.g. your date of birth;
  3. your billing information, transaction and payment card information.

We collect and use this personal data to provide services to you. If you do not provide personal data we ask for, it may delay or prevent us from providing service to you.

 

3. How Your Personal Data Is Collected

We collect most of this personal data directly from you either in person, by telephone, text or email.

However, we may also collect information from other sources such as:

  1. from publicly accessible sources, e.g. Companies Registration Office, Property Registration Authority, Companies House;
  2. from a third party with your consent, e.g. your bank or building society

 

4. How and Why We Use Your Personal Data

Under data protection law, we can only use your personal data if we have a proper reason, e.g.:

  1. where you have given consent;
  2. to comply with our legal and regulatory obligations;
  3. for the performance of a contract with you or to take steps at your request before entering into a contract; or
  4. for our legitimate interests or those of a third party.

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own.

The table below explains what we use your personal data for and why.

 

What we use your personal data for Our reasons
Providing services to you To perform our contract with you or to take steps at your request before entering into a contract
Preventing and detecting fraud against you or us For our legitimate interests or those of a third party, i.e. to minimise fraud that could be damaging for you and/or us
Conducting checks to identify our customers and verify their identity

Screening for financial and other sanctions or embargoes

Other activities necessary to comply with professional, legal and regulatory obligations that apply to our business, e.g. under health and safety law or rules issued by our professional regulator

To comply with our legal and regulatory obligations
Operational reasons, such as improving efficiency, training and quality control For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service to you at the best price
Ensuring the confidentiality of commercially sensitive information For our legitimate interests or those of a third party, i.e. to protect trade secrets and other commercially valuable information

To comply with our legal and regulatory obligations

Statistical analysis to help us manage our business, e.g. in relation to our financial performance, customer base, product range or other efficiency measures For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service to you at the best price
Preventing unauthorised access and modifications to systems For our legitimate interests or those of a third party, i.e. to prevent and detect criminal activity that could be damaging for you and/or us

To comply with our legal and regulatory obligations

Updating customer records To perform our contract with you or to take steps at your request before entering into a contract

To comply with our legal and regulatory obligations

For our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about existing orders and new products

Statutory returns To comply with our legal and regulatory obligations
Ensuring safe working practices, staff administration and assessments To comply with our legal and regulatory obligations

For our legitimate interests or those of a third party, e.g. to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you

Marketing our services to:

—existing and former customers;

For our legitimate interests or those of a third party, i.e. to promote our business to existing and former customers

 

Where we process special category personal data, we will also ensure we are permitted to do so under data protection laws, for example:

  1. we have your explicit consent;
  2. the processing is necessary to protect your (or someone else’s) vital interests where you are physically or legally incapable of giving consent; or
  3. the processing is necessary to establish, exercise or defend legal claims.

 

5. Marketing

We may use your personal data to send you updates (by email, text message, telephone or post) about our services, including exclusive offers, promotions or new services.

We have a legitimate interest in using your personal data for marketing purposes (see above ‘How and why we use your personal data’). This means we do not usually need your consent to send you marketing information. However, where consent is needed, we will ask for this separately and clearly. You have the right to opt out of receiving marketing communications at any time.

We will always treat your personal data with the utmost respect and never sell or share it with other organisations for marketing purposes.

 

6. Who We Share Your Personal Data With

We routinely share personal data with:

  1. third parties we use to help deliver our services to you, e.g. payment service providers;
  2. other third parties we use to help us run our business, e.g. website hosts;
  3. third parties approved by you;

 

We only allow our service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers to ensure they can only use your personal data to provide services to us and to you.

We may also need to:

  1. share personal data with external auditors, e.g. in relation to the audit of our accounts;
  2. disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations;
  3. share some personal data with other parties, such as potential buyers of some or all of our business or during a restructuring—usually, information will be anonymised but this may not always be possible, however, the recipient of the information will be bound by confidentiality obligations.

If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).

 

7. Where Your Personal Data is Held

Personal data may be held at our offices and those of our group companies, third party agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal data with’).

Some of these third parties may be based outside the EEA. For more information, including on how we safeguard your personal data when this happens, see below: ‘Transferring your personal data out of the EEA

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8. How Long Your Personal Data Will Be Kept

We will keep your personal data while we are providing services to you.

Thereafter, we will keep your personal data for as long as is necessary:

  1. to respond to any questions, complaints or claims made by you or on your behalf;
  2. to show that we treated you fairly;
  3. to keep records required by law.

We will not keep your personal data for longer than necessary. Different retention periods apply for different types of personal data. When it is no longer necessary to keep your personal data, we will delete or anonymise it.

 

9. Transferring Your Personal Data out of the EEA 

To deliver services to you, it is sometimes necessary for us to share your personal data outside the EEA, e.g.:

  1. with your and our service providers located outside the EEA; and
  2. if you are based outside the EEA.

 

Under data protection law, we can only transfer your personal data to a country or international organisation outside the EEA where:

  1. the European Commission has decided the particular country or international organisation ensures an adequate level of protection of personal data (known as an ‘adequacy decision’);
  2. there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for data subjects; or
  3. a specific exception applies under data protection law.

 

10. Your Rights

You have the following rights, which you can exercise free of charge:

Access The right to be provided with a copy of your personal data
Rectification The right to require us to correct any mistakes in your personal data
Erasure (also known as the right to be forgotten) The right to require us to delete your personal data, in certain situations
Restriction of processing The right to require us to restrict processing of your personal data in certain circumstances, e.g. if you contest the accuracy of the data
Data portability The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party, in certain situations
To object The right to object:

  • at any time to your personal data being processed for direct marketing (including profiling);
  • in certain other situations to our continued processing of your personal data, e.g. processing carried out for the purpose of our legitimate interests
Not to be subject to automated individual decision making The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

 

If you would like to exercise any of those rights, please:

  1. email, call or write to us—see below: ‘How to contact us’; and
  2. provide enough information to identify yourself and any additional identity information we may reasonably request from you;
  3. let us know what right you want to exercise and the information to which your request relates.

 

11. Keeping your personal data secure

We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access 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.

 

12. How to complain

Please contact us if you have any query or concern about our use of your information (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.

You also have the right to lodge a complaint with the Data Protection Commissioner.

 

13. Changes to this privacy policy

This privacy notice was published on 4 May 2022. We may change this privacy notice from time to time—when we do we will inform you via email.

 

14. How to contact us

You can contact us by post or email if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.

Our contact details are shown below:

[email protected]
Sonra Intelligence Limited

6-9 Trinity Street 

Dublin 2

Ireland