Privacy Policy

Privacy Policy

1. Introduction

Welcome to the privacy policy of SourceBreaker Limited.

SourceBreaker respects your privacy and is committed to protecting your personal data. This privacy policy informs you of how we look after your personal data and tells you about your privacy rights and how the law protects you.

2. Purpose of this privacy policy

This privacy policy aims to give you information on how Sourcebreaker collects and processes your personal data if you are a customer of ours, if you use or access our website, or if you otherwise interact with us in a non-employment relationship including any data you may provide to us via our website when you contact us or provide us with your personal data for any other purpose.  This privacy policy also applies to all authorised uses of the SourceBreaker SaaS platform (the “Platform”).  

Our 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 fair processing information we may provide on specific occasions, including if you become a customer, so that you are fully aware of how and why we are using your personal data.   

2.1 Controller

SourceBreaker Limited is the controller and responsible for your personal data (collectively referred to as “SourceBreaker”, “we”, “us” or “our” in this privacy policy).

We have appointed a data protection manager 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 our data protection manager using the details set out below.

2.2 Contact details

If you have any questions about this privacy policy or our privacy practices, please contact us in the following ways:

Full name of legal entity: SourceBreaker Limited 

Email address: gdpr@sourcebreaker.com

Postal address: Data Protection Officer, 68 Dalling Road, London, W6 0JA

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority 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.

2.3 Changes to the privacy policy and your personal data

We keep our privacy policy under regular review. This version was last updated in January 2022.

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.

2.4 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.

3. The data we collect about you

Personal data, or personal information, means any information about you from which you can be, either directly or indirectly, identified. It does not include data where your identity has been removed (anonymous data).

We may collect, use or store some or all of the following categories of personal information about you:

Identity Data includes first name, last name, username or similar identifier, title and gender.

Contact Data includes billing address (where applicable), email address and telephone numbers.

Financial Data includes bank account and payment card details (where applicable).

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 (where applicable), 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 (please see our Cookies Policy for further information).

Profile Data includes your preferences, feedback and survey responses (where applicable).

Usage Data includes information about how you use our website, Platform, products and/or services.

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

We also may 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 customers requesting a specific service from us. 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.

3.1 If you fail to provide personal data

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 product or service you have with us but we will notify you if this is the case at the time.

4. How is your personal data collected?

We use different methods to collect data from and about you which may include through:

Direct interactions. You may give us your personal data by filling in forms, using our Platform or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

4.1.1 apply for or request information relating to our products and services;

4.1.2 create an account on our website;

4.1.3 enter into an agreement for services with us; 

4.1.4 work for a customer or a supplier of ours, or for someone who uses our products or services;

4.1.5 subscribe to receive any information or communications from us, including requesting marketing to be sent to you; or

4.1.6 give us feedback or contact us for any reason.

Automated technologies or interactions. As you interact with our website, we may collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy for further details (Cookie Policy – Sourcebreaker).

Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:

4.1.7 Technical Data from analytics providers such as Google Analytics;

4.1.8 Identity and Contact Data from a third party who has referred to you our services or made an introduction to you.  If you are an authorised user of our platform, you personal data will be provided to us by the organisation that has engaged our services; 

4.1.9 Identity and Contact Data from publicly available sources such as Companies House; and

4.1.10 We may also inadvertently collect personal data as part of our automated Internet searches, including searches of publicly available job postings (for example where a business is offering a role and has included an individual’s name or email address as part of the contact details for enquiries regarding the role). We do not knowingly collect personal data as part of these activities, but if we do so it will be processed lawfully and in accordance with our security measures. 

5. 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:

5.1.1 where we need to perform the contract we are about to enter into or have entered into with you;

5.1.2 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;

5.1.3 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 electronic 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.

5.2 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 would like 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/ActivityType of data (as defined in section 3 above)Lawful basis for processing
To contact you in relation to or in connection with our services as well as to deliver our services to you.  (a) Identity

 

(b) Contact

(a) Performance of a contract with you

 

(b) Necessary for our legitimate interests (to recover debts due to us or to collect your marketing consents)

To manage our relationship with you which will include:

 

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

(a) Identity

 

(b) Contact

(c) Profile

(d) Usage

(a) Performance of a contract with you

 

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)(a) Identity

 

(b) Contact

(c) Technical

(d) Usage

(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 reorganisation or group restructuring exercise)

 

(b) Necessary to comply with a legal obligation

To make suggestions and recommendations about services that may interest you or the person that you work for and subject to your stated preferences, where relevant.(a) Identity

 

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

(a) Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

 

(b) Consent (where legally required)

To improve our website, services, marketing, customer relationships and experiences(a) Technical

 

(b) Usage

 (c) Contact

 (d) Profile

(a) 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)

 

(b) Consent (where legally required)

 

5.3 Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

5.3.1 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 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 or purchased goods or services from us and, where legally required, you have opted into receiving that marketing.

5.3.2 Third-party marketing

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

5.3.3 Opting out

You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.

5.4 Cookies

Our site uses cookies to distinguish you from other users of our website and Platform.  This helps us to provide you with a good experience when you browse our website, using our Platform and also allows us to improve our sites and services.  For more information about what cookies we use and how you can manage these cookies see our Cookie Policy (Cookie Policy – Sourcebreaker). 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. 

5.5 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.

6. 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 above.

6.1 Internal Third Parties which may include any affiliate company of SourceBreaker acting as controllers or processors who are based in the United Kingdom. 

6.2 External Third Parties which include: 

6.2.1 service providers acting as processors based within the EEA and United Kingdom, communications and system administration services.

6.2.2 professional advisers acting as processors or controllers including lawyers, bankers, auditors and insurers based in and outside the EEA and United Kingdom who provide consultancy, banking, legal, insurance and accounting services.

6.2.3 HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.

6.2.4 Sub-contractors and third party service providers that we use to facilitate the provision of our services to you where necessary for the provision of such services.  Sub-contractors may be based outside the UK and the EEA. Categories of third parties include, but are not limited to: User authentication and authorisation, user access and feature management, user analytics, user support and ticketing, data visualisation of customer user data, accounting, sales and management systems holding customer names and data.

6.2.5 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 or partners 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.

7. International transfers

We may share your personal data with service providers and/or third parties (in accordance with section 6 above) that are located outside the UK and/or the EEA.  This will involve transferring your data outside the UK and the EEA.  Whenever we transfer your personal data out of the UK and the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented in accordance with applicable law:

7.1 Where the transfer is to countries that have been deemed to provide adequate level of protection for personal data.

7.2 Where we use certain service providers, we may use specific contracts approved for use in the UK and/or EU (as appliable) which give personal data the same protection it has in the UK and/or the EU (as applicable).  

Please contact us if you want further information on the specific transfer mechanisms used by us when transferring your personal data outside the UK or the EEA.

8. 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.

9. Data retention

9.1 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 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 you can ask us to delete your data, see your legal rights below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for statistical purposes, in which case we may use this information indefinitely without further notice to you.

10. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. 

Your legal rights include:

10.1 Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

10.2 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.

10.3 Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. Note, however, that 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.

10.4 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.

10.5 Request restriction of processing of your personal data in certain circumstances. 

10.6 Request the transfer of your personal data to you or to a third party. 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.

10.7 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.

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

Automated decision making

Automated decision making takes place when an electronic system uses personal information to make a decision without human intervention.  We do not currently take any decisions and do not envisage that any decisions will be taken about you using automated means.

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.