CSS Privacy Policy

This Privacy Policy was updated on 16 August 2019.

This Privacy Policy (“Privacy Policy”) explains the collection, use, and disclosure of “personal information” by Creative Software Solutions (Europe) Limited (“CSS”). This Privacy Policy includes products and services provided through a websites that CSS operate.

CSS reserves the right to update and change this Privacy Policy from time to time. Each time a user uses the Website, the current version of the Privacy Policy applies. Accordingly, a user should check the date of this Privacy Statement (which appears at the bottom) and review for any changes since the last version.

CSS provides this Privacy Policy to make users aware of CSS’s privacy practices, and of the choices a user may make about the way the user’s information is collected and used.

By accessing the Website, you are accepting and agreeing to the practices described in this Privacy Policy.

CSS act as “Data Processors” for our clients, this means that we do not determine how and why your data is processed. We are registered as a Data Processor with the UK Information Commissioner’s Office (ICO). Our registration number is: Z284089X

1. The Information CSS Collects

1.1 Personally identifiable information is any piece of information which can potentially be used to uniquely identify, contact, or locate a user of the Website.

1.2 CSS collects personal information when a registered user:

  • Creates a user account
  • Make online purchases.
  • Request support for a CSS product.
  • Request information or materials.
  • Participate in surveys and evaluations.
  • Submit questions or comments to us.

 

1.3 The types of personal information collected may include (but are not limited to):

  • First and last name.
  • Title and your organisations name.
  • Home, or other physical address (including street name, name of a city or town, county).
  • E-mail address.
  • Telephone numbers both land line and mobile
  • Any other identifier that permits CSS to make physical or online contact with the user.
  • Any information that CSS collects online from the user and maintains in association with the user’s account, such as:
    – username,
    – password,

 

1.4 Device information is information about the device and its attributes (such as information about how your browser is configured, whether the user’s device has enabled cookies, its Flash settings, the device’s identification number and other characteristics about the device); it also may be personally identifiable information in cases where it is associated with the name or other identifier for a Website user. CSS uses device information for purposes such as enhancing the user experience.

1.5 Aggregate information is non-personally identifiable/anonymous information about users of the Website (such as frequency of visits to Website, Website pages most frequently accessed, browser type). Aggregate information also may include pages visited along with any navigation and in-page interactions used during each visit. In-page interactions monitored include: clicks and selections, mouse movement, page scrolling, and form fields focused on (specific keystrokes entered into each field are not collected). Aggregate information is used in a collective manner and no single person can be identified by that compiled information.

2. Cookies

2.1 CSS may use cookies in order to deliver relevant content and material.

Cookies are small data files with text that is stored in your browser.
Information stored in this file is used to distinguish yourself as unique visitors to the web server. Information stored in cookies from CSS does not contain any personal information. These may be ‘session’ cookies, meaning they delete themselves when leave the website or ‘persistent’ cookies which do not delete themselves and help the websites recognise you when you return.

Most browsers are initially set to allow cookies. If you do not want to allow your browser to use this feature, it can be turned off. The procedure for how to do this differs between different browsers. You will find information about this in your browser’s help function.
If you choose to disable cookies, some portions of this site will not function fully (for example login and personalization). In some cases the website may not be accessible at all.

3. How CSS Uses the Information Collected

3.1 CSS may use the personally identifiable information a user submits for any purposes related to CSS’s business, including, but not limited to:

  • Understand a user’s needs and create content that is relevant to the user.
  • Create and maintain the users accounts.
  • Complete a transaction, or provide services or customer support to users.
  • Process, fulfil, and follow-up on user’s orders.
  • Generate statistical studies and conduct market research with surveys.
  • Improve services, information, and products.
  • Communicate with the users and answering questions.
  • Update users about services, information, and products.
  • Personalise the Website for the users.
  • Register the user’s products.
  • Register the users in programs (per your request).
  • Send the user information.

 

3.2 We also use this personal information to provide you with information related to your account and the products or services you purchased from us, to better understand your needs and interests, to improve our service, and to personalise communications.

4. Your Privacy Choices and Rights

4.1 Your choices

  • You can choose not to supply your data, however you will be unable to use our websites as secure log in is required
  • You can turn off cookies in your browser. You can also delete cookies through your browser settings. If you turn off cookies, some portions of this site will not function fully (for example login and personalization). In some cases the website may not be accessible at all.

4.2 Your Rights – You can exercise your rights by emailing us at dpo@csseurope.co.uk, however please remember CSS are the data processors and some request will need action / permission from the Data Controller.

  • Right of access
    • The information we hold on you
    • The categories of data we’re processing
    • The purposes of data processing
    • How long the data will be stored
    • Your other rights regarding our use of your data

We will supply the information with one month of the request, unless doing so would adversely affect the right and freedoms of others, or the data controllers we are acting on behalf of

The following rights will need to be submitted to the data controller of your data, we will be happy to provider the details we have to help you make contact if required;

  • Right to correct any inaccurate personal data
  • Right to object to data profiling or processing
  • Right to have data ported to another service
  • Right to be ‘forgotten’

 

Finally you have the right to lodge a complaint regarding the use of your data. Please inform us or, where required, the data controller first. If your complaint is not addressed you can contact the UK Information Commissioner’s Office – on 0303 123 1113 or visit their website https://ico.org.uk/

5. Where is your data stored

5.1 All the data collected is stored with our hosting provider Rackspace. The Rackspace data centre is located in London. Rackspace are fully compliant with GDPR and Data Projection rules which can be confirmed on their website; https://www.rackspace.com/en-gb/compliance

6. Disclosure of Personal Information

6.1 Unless you explicitly agree, CSS will never share the personal information you provide to us.

7. Security and Confidentiality

7.1 Our access to the user’s personal information is limited to employees who possibly may come in contact with such information in order to provide products and services for the user or in order for the employees to carry out their duties.

In order to protect the user’s personal information we have physical, electronic and managerial safeguards and rules of procedure which fulfil legal requirements, please see our GDPR Compliance Statement. https://www.csseurope.co.uk/documents/gdpr-compliance-statement/

 

Please remember:

  • No data transmission is guaranteed to be 100% secure, any personal data is supplied at the users own risk
  • You are responsible for your username and password
  • If you believe your privacy has been breached, please contact us immediately dpo@csseurope.co.uk

8. Third-Party Sites

8.1 The Website may include links to other websites. You should consult the respective privacy policies of these third-party sites. This Privacy Policy does not apply to, and we cannot control the activities of, such other websites.

9. Retention Period

9.1 CSS are acting as the data processors, CSS will therefore, where reasonable and lawful, adopt the retention period of the Data Controller.

10. Contact Us

10.1 If you have any questions or suggestions, please contact our Data Protection Officer at dpo@csseurope.co.uk by telephone at 0844 879 4531 or visit us in person building 2 & 3 Parkside Court, Greenhough Road, Lichfield. WS13 7FE.

 

10.2 For further independent information please contact the ICO on 0303 123 1113 or visit their website https://ico.org.uk/

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