Introduction
Welcome to Singular Group’s (hereinafter ‘Singular’) privacy policy.
Singular respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
1. IMPORTANT INFORMATION AND WHO WE ARE
PURPOSE OF THIS PRIVACY POLICY
This privacy policy aims to give you information on how Singular collects and processes your personal data through your use of this website, including any data you may provide through this website when you input your contact details to enquire about our bespoke software development.
This website is mainly catered for companies wishing to enquire about our services and hence this website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy policy together with any other policy on this website.
CONTROLLER
Singular Trading Limited (C-69096) a company incorporated under the laws of Malta having its registered address at Tagliaferro Business Centre, High Street C/W Gaiety Lane, 1551 MT, Sliema, Malta is the controller and responsible for your personal data. Singular Group is made up of different legal entities and hence other companies belonging to Singular Group will process your data however, the controller of such data shall be the above-mentioned Maltese company namely Singular Trading Limited (C-69096). This privacy policy is issued on behalf of Singular Group so when we mention Singular, “we”, “us” or “our” in this privacy policy, we are referring to the relevant company in the Singular Group responsible for the processing of your data.
We have appointed a Data Protection officer (hereinafter ‘DPO’) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.
If you have any questions about this privacy policy or our privacy practices, please contact our DPO using the contact details above. Alternatively, you may send a letter to Singular Trading Limited in Malta to the abovementioned physical address with the caption ‘Attention DPO Singular’.
You have the right to make a complaint at any time to the Office of the Information and Data Protection Commissioner (hereinafter ‘IDPC’), the Maltese supervisory authority for data protection issues (https://idpc.org.mt). We would, however, appreciate the chance to deal with your concerns before you approach the IDPC so please contact us in the first instance.
CHANGES TO THE PRIVACY POLICY
We keep our privacy policy under regular review. This version was last updated on 10/03/2020.
THIRD-PARTY LINKS
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
2. THE DATA WE COLLECT ABOUT YOU
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).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, last name.
- Contact Data includes email address and we may ask you for your telephone numbers.
- Technical Data includes your internet protocol (hereinafter ‘IP’) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
- Usage Data includes information about how you use our website.
- Marketing and Communications Data includes your preferences in receiving marketing from us if applicable.
If applicable, we may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of persons accessing a specific website feature/page. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
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). Nor do we collect any information about criminal convictions and offences.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
- Direct Interactions. You may give us your identity and contact details when enquiring about our products or when corresponding with us by post, phone, emails or otherwise. This includes data you provide when you:
- apply for our products or services;
- if applicable, subscribe to receive marketing material;
- give us feedback or contact us.
- Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy for further details.
- Third parties or publicly available sources. We will receive personal data about you from various third parties as set out below:
Technical Data from the following parties:
- Analytics providers (such as Google based outside the EU)
4. HOW WE USE YOUR PERSONAL DATA
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:
- To contact you when you enquire about our bespoke software solutions
- 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.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out below.
Purpose/Activity
- To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data);
- To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you;
- To use data analytics to improve our website, products/services, marketing, customer relationships and experiences;
- To make suggestions and recommendations to you about goods or services that may be of interest to you.
Type of data
- Identity, Contact and Technical;
- Identity, Contact, Usage, Marketing and Communications and Technical;
- Technical and Usage;
- Identity, Contact, Technical, Usage, Marketing and Communications
Lawful basis for processing including basis of legitimate interest
1) a. Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise);
b. Necessary to comply with a legal obligation.
2) a. Necessary for our legitimate interests (to study how customers use our website, to develop the website further, to grow our business and to inform our marketing strategy).
3) Necessary for our legitimate interests (to define types of customers for bespoke software solutions, to keep our website updated and relevant, to develop and grow our business and to inform our marketing strategy).
4) Necessary for our legitimate interests (to develop our products/services and grow our business).
MARKETING
We may send you marketing material based on our legitimate interest to keep you updated about Singular’s bespoke software solutions in order to inform potential clients, to grow our business and brand name. Logically, you always have the right to unsubscribe from marketing emails.
PROMOTIONAL OFFERS FROM US
We may use your Identity, Contact, Technical, Usage and Profile Data 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 for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us and you have not opted out of receiving that marketing.
THIRD PARTY MARKETING
We will 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 with your request.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of your enquiry about our bespoke software solutions.
COOKIES
You can set your browser to refuse all or some browser cookies or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge of consent where this is required or permitted by law.
5. DISCLOSURES OF YOUR PERSONAL DATA
We may share your personal data with the parties set out below for the purposes set out in the table (Purposes for which we will use your personal data) above.
- Internal Third Parties as set out in the Glossary.
- External Third Parties: These providers have limited access to your information and are contractually bound to protect and to use it on our behalf only for the purposes for which it was disclosed and consistent with this Privacy Policy. You can always contact us to receive the full list of our service providers which process your data.
- Third Parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
If applicable, we require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow any third-party service provider to use your personal data for their own purpose and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. INTERNATIONAL TRANSFERS
We share your personal data within the Singular Group. This will involve transferring your data outside the European Economic Area (hereinafter ‘EEA’). Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA. In addition, you may always contact us to receive the full list of our service providers outside of the EEA which process your data.
7. DATA SECURITY
We have out in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
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.
8. DATA RETENTION
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it as displayed herein. 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 if applicable.
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 unauthorized 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 or other requirements.
9. YOUR LEGAL RIGHTS
Under the General Data Protection Regulation, you have the right to access, rectify, port and delete some of your data. You also have the right to object to and restrict certain processing of your data. This is a case-by-case determination that depends on criteria such as the nature of the data, why it is collected and processed, and relevant legal or operational retention needs.
You may exercise any of the rights described in this section before your Data Controller by sending an email to dpo@singular.uk Please note that we may ask you to verify your identity before taking further action on your request.
Please be aware that whilst we will try to accommodate any request you make in respect of your rights; they are not absolute rights. This means that we may have to refuse your request or may only be able to comply with it in part.
RECTIFICATION OF INACCURATE OR INCOMPLETE INFORMATION
You have the right to ask us to correct inaccurate or incomplete personal information concerning you.
DATA ACCESS AND PORTABILITY
You have the right to access your personal data held by us and a right to receive certain personal data in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider (where technically feasible).
WITHDRAWING CONSENT AND RESTRICTION OF PROCESSING
Where we have specifically requested your consent to process your personal data and have no other lawful conditions to rely on, you have the right to withdraw this consent at any time by sending a communication to dpo@singular.uk specifying which consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal.
Additionally, applicable law may give you the right to limit the ways in which we use your personal information, in particular where (i) you contest the accuracy of your personal information; (ii) the processing is unlawful and you oppose the erasure of your personal information; (iii) we no longer need your personal information for the purposes of the processing, but you require the information for the establishment, exercise or defence of legal claims; or (iv) you have objected to the processing pursuant to next section and pending the verification whether the legitimate grounds of the Data Controller override your own.
OBJECTION TO PROCESSING
You have the right to object to processing where lawful basis is in our legitimate interests, but please note that we may still process your personal data where there are other relevant lawful bases or where we have compelling grounds to continue processing your personal data in our interests which are not overridden by your rights, interests or freedoms.
You also have the right to object to direct marketing, which can be done by opting-out of direct marketing via the communication itself. You also have a right to object to any profiling to the extent that it relates to direct marketing only.
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 could refuse to comply with your request in these circumstances.
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.
10. Glossary
LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
INTERNAL THIRD PARTIES
Other companies in the Singular Group acting as joint controllers or processors and who are based in Macedonia and Georgia and provide development services for the bespoke software solutions offered by Singular and in addition, marketing services. The following are the internal companies involved in the processing of your data if applicable:
- Singular Group LLC – duly incorporated under the laws of Georgia bearing identification code 204577065;
- Singular Group DOO – duly incorporated under the laws of Macedonia bearing legal entity number 6871852;