Last updated: 21 July 2020
Sonrai Analytics (\”us\”, \”we\”, or \”our\”) operates the https://sonraianalytics.com website and the InDRA data analytics platform at https://indraengine.com/ (the \”Service\”) and is the data controller responsible for the website. This page informs you of our policies regarding the collection, use and disclosure of Personal Information when you use our Service.
We use your Personal Information for providing and improving the Service. By using the Service, you agree to the collection and use of information in accordance with this policy.
Information Collection and Use
While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you. Personally, identifiable information will include your email address, first and last name, phone number and postal address (\”Personal Information\”). We may also collect some information automatically via Google Analytics or Cookies.
Lawful basis for processing your Personal Information
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances, in accordance with Article 6(1) of the GDPR:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal obligation.
- Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
We collect your Personal Information in order to:
- Provide and maintain the Service in order to perform our contract with you and in accordance with our legitimate business interests.
- Notify you about changes to our Service in order to ensure performance of our contract with you and in accordance with our legitimate interests to keep users up-to-date.
- Provide customer care and support in accordance with our legitimate interests to offer an efficient and optimum Service.
- Provide analysis or valuable information so that we can improve the Service in accordance with our legitimate business interests to offer a good Service that will be most beneficial to our users and to study how users use our Service.
- Inform you about new products/services, or provide information, that may be of interest to you.
- Monitor the usage of the Service in accordance with our legitimate interests to keep up-to-date with what elements of the Service are working well and what areas could be improved.
- Detect, prevent and address technical issues which are necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud) and necessary to comply with a legal obligation.
- Monitor and manage staff access to our systems and facilities to protect our networks, and the personal data of employees and customers/clients, from unauthorised access.
- Manage client relationships in accordance with our legitimate interests to ensure a user-friendly Service is provided.
- Enforce our terms of business to ensure compliance with our legal obligations and in order to perform our contract with you.
We may also collect information that your browser sends whenever you visit our Service or when you access the Service by or through a mobile device (\”Log Data\”).
This Log Data may include information such as your computer\’s Internet Protocol (\”IP\”) address, browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages and other statistics.
When you access the Service by or through a mobile device, this Log Data may include information such as the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use and other statistics.
In addition, we may use third party services such as Google Analytics that collect, monitor and analyse this type of information in order to increase our Service\’s functionality. These third-party service providers have their own privacy policies addressing how they use such information.
We may use and store information about your location, if you give us permission to do so. We use this information to provide features of our Service, to improve and customize our Service. You can enable or disable location services when you use our Service at any time, through your mobile device settings.
Cookies are files with small amounts of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a web site and stored on your computer\’s hard drive.
We use \”cookies\” to collect information. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.
Google AdWords remarketing service is provided by Google Inc. You can opt out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: https://www.google.com/settings/ads
Google also recommends installing the Google Analytics Opt-out Browser Add-on – https://tools.google.com/dlpage/gaoptout – for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.
For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://www.google.com/intl/en/policies/privacy/
Facebook remarketing service is provided by Facebook Inc. You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/164968693837950
To opt-out from Facebook\’s interest-based ads follow these instructions from Facebook: https://www.facebook.com/about/ads/#568137493302217
Facebook adheres to the Self-Regulatory Principles for Online Behavioural Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada https://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe https://www.youronlinechoices.eu/, or opt-out using your mobile device settings.
For more information on the privacy practices of Facebook, please visit Facebook\’s Data Policy: https://www.facebook.com/privacy/explanation
AdRoll remarketing service is provided by Semantic Sugar, Inc. You can opt-out of AdRoll remarketing by visiting this AdRoll Advertising Preferences web page: http://info.evidon.com/pub_info/573?v=1nt=1nw=false
We may employ third party companies and individuals to facilitate our Service, to provide the Service on our behalf, to perform Service-related services or to assist us in analysing how our Service is used.
These third parties have access to your Personal Information only to perform these tasks on our behalf and on our written instructions. We require all third-party service providers to treat your Personal Information securely and not to process it for any other purpose.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. At all times, we will ensure that we comply with the applicable rules and privacy laws when marketing to you.
We may use your Personal Information to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send. We will endeavour to deal with your opt-out request as quickly as possible.
The security of your Personal Information is important to us but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security. As such we make no warranties as to the level of security afforded to your data, except that we will always act in accordance with the relevant UK and EU legislation.
However, 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.
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.
Your information, including Personal Information, may be transferred to – and maintained on – computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those from your jurisdiction.
When you use our Service, you expressly consent to your Personal Information being accessed outside the United Kingdom. You have the right to withdraw your consent at any time by contacting firstname.lastname@example.org.
If you are located outside the United Kingdom and choose to provide information to us, please note that we transfer the information, including Personal Information, to the United Kingdom and process it there.
We will ensure at all times that we are compliant with the requirements under Article 45 or Article 46 of the GDPR and we shall implement an appropriate safeguard where applicable to do so to enable international transfers of Personal Information to take place lawfully. In the event that a dispute arises with regards to the international transfer of data, you agree that the courts of Northern Ireland shall have exclusive jurisdiction over the matter.
Links to Other Sites
We have no control over, and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.
Our Service does not address anyone under the age of 18 (\”Children\”).
We do not knowingly collect personally identifiable information from children under 18. If you are a parent or guardian and you are aware that your Children have provided us with Personal Information, please contact us. If we become aware that we have collected Personal Information from a child under the age of 18 without verification of parental consent, we will take steps to remove that information from our servers.
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.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
By law we have to keep basic information about our customers for six years after they cease being customers.
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.
Under the GDPR, you have a number of important rights free of charge. These include the right to:
Request access to your personal data. 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. This enables you to ask us to delete or remove personal data in certain circumstances. 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 , where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local laws. Please note, 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) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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 (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party (data portability). 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. 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. You may withdraw consent by contacting email@example.com.
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 us in writing at our registered address or by email.
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 may 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.
This Policy shall be governed and construed in accordance with the laws of Northern Ireland, without regard to its conflict of law provisions.
How to Complain
The GDPR also gives you the right to lodge a complaint with a supervisory authority. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/.