Privacy Policy

Updated March 27, 2020

Welcome to roseta.io's privacy policy.

We respect your privacy and we are committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you.

1. Important Information and who we are

roseta.io is a trading name of New Vision Software Ltd, a company registered in England and Wales under number 09361318 whose registered office is at 389 Paintworks, Bristol, BS4 3AR (collectively referred to as "roseta.io", "we", "us" or "our" in this privacy policy).

This privacy policy aims to give you information on how we collect and process your personal data. This may be when you visit our website, when you make an enquiry, subscribe to our services or otherwise interact with us. This privacy policy supplements other notices and privacy policies we may provide on specific occasions and is not intended to override them.

This website is not intended for children and we do not knowingly collect data relating to children.

If you have any questions about this privacy policy, please contact us by email: [email protected]

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Data controller or data processor?

In some circumstances we are the data controller. This means that we are the main decision-makers and have overall control over what personal data we need to collect and why. This will normally be when we collect and process personal data that you have shared with us directly, for example when you provide your contact details when you submit an enquiry about our services through our website.

In other cases, we may be acting as the data processor on behalf of a business or individual that shares your data with us. This will usually happen if they have subscribed to our services. They will normally share information like your name, address and order details which is stored on the cloud integration software we provide. This helps them run their business and keep track of the products they sell online.

In these situations we are processing your personal data on behalf of our customers who are the data controllers and they will have overall responsibility for your personal data. We will only process your data in accordance with the law and the instructions of our customers which will include telling us about:  the subject matter of the processing, how long we can process your data for, the nature and purpose of the processing, the type of personal data involved, the categories of data subject and their obligations and rights as a data controller. In these circumstances we recommend that you also review our customer’s privacy policy where relevant.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated on May 2021.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

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 your full name, username or similar identifier and title.

  • Contact Data includes billing address, email address and telephone numbers.

  • Financial Data includes bank account and payment card details.

  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.

  • Technical Data includes internet protocol (IP) address, your login data, 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.

  • Profile Data includes your username and password, subscriptions made by you, your interests, preferences and feedback.

  • Usage Data includes information about how you use our website, products and services.

  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We 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 users accessing a specific website feature. 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.

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

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, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
    • enquire about our services;
    • create an account on our website;
    • subscribe to our service or publications;
    • request marketing to be sent to you; or
    • give us feedback or otherwise 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 may collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy below for further details.
  • Third parties. We will receive personal data about you as set out below:
    1. Technical Data from analytics providers, advertising networks and search information providers; and
    2. We may receive your Contact and Transaction Data from our customers that have subscribed to our services. We receive the data when you make an online purchase from one of our customers which is then stored on our software for review by our customers. This may include:
      • Contact and Identity Data; and
      • Transaction Data relevant to the order you have placed with our customer.
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:

  • 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.

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 in the table below.

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you as a new customer
  1. Identity
  2. Contact
Performance of a contract with you

To process and deliver your subscription including:

  1. Manage payments, fees and charges
  2. Collect and recover money owed to us
  1. Identity
  2. Contact
  3. Financial
  4. Transaction
  5. Marketing and Communications
  1. Performance of a contract with you
  2. Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you which will include:

  1. Notifying you about changes to our terms or privacy policy
  2. Asking you to leave a review or provide feedback
  1. Identity
  2. Contact
  3. Profile
  4. Marketing and Communications
  1. Performance of a contract with you
  2. Necessary to comply with a legal obligation
  3. Necessary for our legitimate interests (to keep our records updated and to study how customers use our services)
To provide a service to our clients which will include processing your personal data on their behalf
  1. Identity
  2. Contact
  3. Transaction
  1. Necessary for our legitimate interests (to provide a service to our customers)
  2. Necessary to comply with a legal obligation (fulfilling a contract with our customers)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
  1. Identity
  2. Contact
  3. Technical
  1. 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 reorganisation or group restructuring exercise)
  2. Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
  1. Identity
  2. Contact
  3. Profile
  4. Usage
  5. Marketing and Communications
  6. Technical
Necessary for our legitimate interests (to study how customers use our services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, services, marketing, customer relationships and experiences
  1. Technical
  2. Usage
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about services that may be of interest to you
  1. Identity
  2. Contact
  3. Technical
  4. Usage
  5. Profile
  6. Marketing and Communications
Necessary for our legitimate interests (to develop our services and grow our business)
Marketing

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 services and offers may be relevant for you as part of our marketing strategy.

You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

You can ask us to stop sending you marketing messages at any time by contacting us by email: [email protected]

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service or subscription purchase, other transactions or where we are acting as a data processor.

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 or consent, in compliance with the above rules, 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:

  • Our employees and agents who are under a obligation to keep your personal data confidential;
  • Professional advisers including lawyers, bankers, auditors and insurers who may provide consultancy, banking, legal, insurance and accounting services;
  • HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances;
  • Third party service providers who provide services to us which require the processing of personal data, for example the software providers that provide computer programmes that are integrated into the platform and services we provide our customers and payment providers; and
  • 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.

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 our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

International transfers

Our third party service provided may be based outside the UK so their processing of your personal data will involve a transfer of data outside the UK. For example, this could occur if our servers are located outside of the UK.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data; or
  • We may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.
7. Data security

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. 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

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.

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.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:

  • Request access to your personal data;
  • Request correction of your personal data;
  • Request erasure of your personal data;
  • Object to processing of your personal data;
  • Request restriction of processing your personal data;
  • Request transfer of your personal data; and
  • Withdraw consent of processing your personal data.

More information about your rights is available here: Your data protection rights | ICO.

If you wish to exercise any of the rights set out above, 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.

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.

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.