Last Updated: 4 December 2024

1. Introduction

Reinvent Systems Ltd ("we", "us", "our", or "the Company") is committed to protecting your privacy and personal data. This Privacy Policy explains how we collect, use, store, and protect your personal information in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

We are the data controller responsible for your personal data. If you have any questions about this Privacy Policy or how we handle your data, please contact us using the details provided in Section 12.

2. Information We Collect

2.1 Information You Provide to Us

We collect personal data that you voluntarily provide to us, including:

• Contact Information: Name, email address, phone number, postal address, company name, and job title
• Professional Information: Details about your business, project requirements, and technical specifications
• Communication Records: Content of emails, messages, phone calls, and meeting notes
• Account Information: Login credentials, preferences, and account settings if you use our client portal or services
• Payment Information: Billing address and payment method details (processed securely by our payment providers)
• Feedback and Correspondence: Survey responses, testimonials, and any other information you choose to share

2.2 Information Collected Automatically

When you visit our website, we automatically collect certain information:

• Technical Data: IP address, browser type and version, device type, operating system, time zone setting
• Usage Data: Pages visited, time spent on pages, links clicked, referring website, date and time of visits
• Cookie Data: Information collected through cookies and similar tracking technologies (see Section 9)

2.3 Information from Third Parties

We may receive information about you from:

• Professional networking sites (e.g., LinkedIn) if you connect with us through such platforms
• Business partners, referrers, or clients who introduce you to our services
• Publicly available sources including company directories and professional registries
• Analytics and search engine providers

3. How We Use Your Information

3.1 Legal Basis for Processing

We process your personal data under the following legal bases:

• Contractual Necessity: To perform our contract with you or take steps at your request before entering into a contract
• Legitimate Interests: To operate and improve our business, provided your interests and rights do not override these interests
• Legal Obligation: To comply with legal and regulatory requirements
• Consent: Where you have given specific consent for particular processing activities

3.2 Purposes of Processing

We use your personal data for the following purposes:

• Service Delivery: To provide, maintain, and improve our professional services
• Client Management: To manage our relationship with you, including responding to inquiries and communicating about projects
• Contract Administration: To prepare proposals, statements of work, invoices, and manage payments
• Business Operations: To plan resources, manage our team, and maintain quality standards
• Marketing and Communications: To send relevant information about our services, industry insights, and updates (with your consent or legitimate interest)
• Website Functionality: To provide website features, personalize content, and improve user experience
• Analytics and Improvement: To analyze website usage, understand client needs, and improve our services
• Security: To protect our systems, prevent fraud, and ensure data security
• Legal Compliance: To comply with legal obligations, enforce our terms, and protect our legal rights
• Professional Services: Where providing expert witness or advisory services, to fulfill our professional and legal duties

4. Disclosure of Your Information

4.1 When We Share Information

We may share your personal data with the following categories of recipients:

• Service Providers: Third-party providers who support our business operations (e.g., hosting, email, analytics, payment processing)
• Professional Advisors: Lawyers, accountants, auditors, and other professional advisors
• Subcontractors: Carefully vetted contractors who assist in delivering our services, bound by confidentiality obligations
• Business Partners: With your consent or where necessary to deliver services you have requested
• Legal Authorities: Courts, regulators, law enforcement, or other public authorities when legally required
• Business Transfers: In connection with a merger, acquisition, or sale of all or part of our business

4.2 Data Processing Agreements

Where we share your data with service providers who process data on our behalf, we ensure appropriate data processing agreements are in place to protect your information and ensure compliance with data protection laws.

4.3 International Transfers

Your personal data may be transferred to and processed in countries outside the UK. Where we transfer data internationally, we ensure appropriate safeguards are in place, including:

• Standard Contractual Clauses approved by the UK Information Commissioner's Office
• Adequacy decisions recognizing equivalent data protection standards
• Other legally approved transfer mechanisms

5. Data Retention

We retain personal data only for as long as necessary to fulfill the purposes for which it was collected, including:

• Active Client Data: During the course of our engagement and for a reasonable period thereafter
• Financial Records: For at least 6 years after the end of the financial year in which the transaction occurred (as required by HMRC)
• Marketing Communications: Until you unsubscribe or withdraw consent, after which we will suppress your details to prevent further contact
• Legal Matters: For as long as reasonably necessary to protect our legal interests or comply with legal obligations
• Website Analytics: Typically 26 months or as configured in our analytics tools

When we no longer need your personal data, we will securely delete or anonymize it. In some cases, we may retain information in anonymized form for statistical or analytical purposes.

6. Your Data Protection Rights

Under UK data protection law, you have the following rights:

6.1 Right of Access

You have the right to request a copy of the personal data we hold about you, along with information about how we use it.

6.2 Right to Rectification

You have the right to request correction of inaccurate or incomplete personal data.

6.3 Right to Erasure (Right to be Forgotten)

In certain circumstances, you have the right to request deletion of your personal data, including when:

• The data is no longer necessary for the purposes for which it was collected
• You withdraw consent and there is no other legal basis for processing
• You object to processing and there are no overriding legitimate grounds
• The data has been unlawfully processed

6.4 Right to Restriction of Processing

You have the right to request that we restrict processing of your personal data in certain circumstances, such as while we verify the accuracy of disputed data.

6.5 Right to Data Portability

You have the right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit it to another controller.

6.6 Right to Object

You have the right to object to processing based on legitimate interests or for direct marketing purposes. We will cease processing unless we can demonstrate compelling legitimate grounds that override your interests.

6.7 Rights Related to Automated Decision-Making

You have the right not to be subject to decisions based solely on automated processing that produce legal or similarly significant effects. We do not currently engage in such automated decision-making.

6.8 Right to Withdraw Consent

Where we process your data based on consent, you have the right to withdraw that consent at any time. This will not affect the lawfulness of processing before withdrawal.

6.9 Exercising Your Rights

To exercise any of these rights, please contact us using the details in Section 12. We will respond to your request within one month, though this may be extended by two months for complex requests.

7. Data Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. These measures include:

• Encryption of data in transit and at rest
• Secure authentication and access controls
• Regular security assessments and vulnerability testing
• Employee training on data protection and security
• Confidentiality agreements with staff and contractors
• Secure backup and disaster recovery procedures
• Network security including firewalls and intrusion detection

While we take all reasonable steps to protect your data, no method of transmission or storage is completely secure. If you believe your data has been compromised, please contact us immediately.

8. Children's Privacy

Our services are not directed to individuals under the age of 18. We do not knowingly collect personal data from children. If we become aware that we have inadvertently collected information from a child, we will take steps to delete it promptly.

9. Cookies and Tracking Technologies

9.1 What Are Cookies

Cookies are small text files placed on your device when you visit our website. We use cookies and similar technologies to improve your experience, analyze website performance, and for marketing purposes.

9.2 Types of Cookies We Use

• Essential Cookies: Necessary for the website to function properly, including security and session management
• Performance Cookies: Collect anonymous information about how visitors use our website, helping us improve functionality
• Functional Cookies: Remember your preferences and provide enhanced features
• Marketing Cookies: Track your activity across websites to deliver relevant advertising (only with your consent)

9.3 Third-Party Cookies

We may use third-party services such as Google Analytics, which place their own cookies. These third parties have their own privacy policies governing their use of information.

9.4 Managing Cookies

You can control and manage cookies through your browser settings. However, disabling cookies may affect the functionality of our website. Most browsers allow you to:

• View and delete cookies
• Block third-party cookies
• Block cookies from specific sites
• Block all cookies
• Delete cookies when you close your browser

10. Marketing Communications

We may send you marketing communications about our services, industry insights, and updates where:

• You have given consent to receive such communications, or
• We have a legitimate interest in contacting you (e.g., you are an existing client or have inquired about our services)

10.1 Opting Out

You can opt out of marketing communications at any time by:

• Clicking the "unsubscribe" link in any marketing email
• Contacting us directly using the details in Section 12
• Updating your preferences in your account settings (if applicable)

Please note that even if you opt out of marketing communications, we may still send you service-related communications necessary for our business relationship.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of any material changes by:

• Posting the updated policy on our website with a new "Last Updated" date
• Sending you an email notification if you are an active client
• Providing a prominent notice on our website

We encourage you to review this Privacy Policy periodically. Your continued use of our services after changes are posted constitutes your acceptance of the updated policy.

12. Contact Information and Complaints

12.1 Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

Reinvent Systems Ltd
Email: info@reinventsystems.com
Website: www.reinventsystems.com

12.2 Complaints to the Supervisory Authority

You have the right to lodge a complaint with the UK Information Commissioner's Office (ICO) if you believe we have not handled your personal data in accordance with data protection law.

Information Commissioner's Office (ICO)
Wycliffe House
Water Lane
Wilmslow
Cheshire SK9 5AF
Tel: 0303 123 1113
Website: www.ico.org.uk

However, we would appreciate the opportunity to address your concerns before you approach the ICO, so please contact us first if possible.

13. Additional Information for Specific Services

13.1 Client Project Work

When providing services to clients, we may process personal data on behalf of the client as a data processor. In such cases, the client is the data controller and we process data according to their instructions under a Data Processing Agreement.

13.2 Expert Witness and Advisory Services

When providing expert witness or advisory services in legal proceedings, we may be required to disclose information as part of our duty to the court or legal obligations. Any such disclosures will be made in accordance with applicable legal and professional requirements.