We respect your privacy and are 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 and it explains how we comply with the Data Protection Act 2018 (DPA), and the retained EU law version of the General Data Protection Regulation ((EU) 2016/679) (UK GDPR), and the PECR (Privacy and Electronic Communications Regulations). 

We have appointed a data privacy 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 the data privacy manager using the details set out above. 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.

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 

Our 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.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. Please keep us informed if your personal data changes during your relationship with us. Open Credo Limited is the controller and responsible for your personal data. We keep our privacy policy under regular review.

This version was last updated on 27th June 2024

1. The data we collect about you

We collect data from and about you as you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We only share data within the Open Credo or Trifork Group acting as joint controllers or processors. We will only use your personal data for the purposes for which we collected it or for another compatible reason.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity data such as names, username or similar identifier.
• Contact data and Company data we use analytic tools to track more information about who is visiting our website, to improve our advertising and marketing activities. These products use contact data such as names, company, email address and telephone numbers.
• Technical Data includes internet protocol (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 our website.
• Profile data includes preferences, feedback and survey responses.
• Usage data includes information about how you use our website
• Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.

We also collect, use and share aggregated data such as statistical or demographic data for any purpose which does not directly reveal your identity.

2. How we use your personal data

We will only use your personal data when the law allows us to and following an enquiry by you via our website, at which point your personal data is sent to our CRM system for our review to determine the nature of your enquiry and for us to provide a response, which may include sending you marketing communications if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing. 

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.  

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of services we have provided to you. 

We regard this process as necessary for our legitimate interests (the interest of our business to enable us to perform the best services, the most secure experience and to develop our services and grow our business).

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. 

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.

3.  Disclosures of your personal data

We may share your personal data only with third parties who require reporting of processing activities in certain circumstances, or 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.

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We do transfer your personal data outside the United Kingdom to the United States in three instances but we ensure that a similar degree of protection is afforded to your personal data. First, we transfer your personal data to our website hosting company in the United States Webflow Inc (Webflow). Webflow is a data processor of your personal data. Webflow lawfully processes your personal data because it uses the United Kingdom’s International Data Transfer Agreement as its transfer mechanism to export data from the United Kingdom.

For more information on how Webflow processes your personal data please see: Data Processing Addendum (webflow.com).

We transfer your personal data to Calendly, LLC based in the United States (Calendly). Calendly is a scheduling automation platform and is a data processor of your personal data. Calendly lawfully processes your personal data because it complies with the UK Extension to the EU-U.S. DPF, as set forth by the U.S. Department of Commerce. Calendly has certified to the U.S. Department of Commerce that it adheres to the processing of personal data received from the United Kingdom in reliance on the UK Extension to the EU-U.S. DPF.  For more information on how Calendly processes your personal data please see: Privacy Notice | Calendly.

We transfer your personal data to Zapier Inc (Zapier) based in the United States. Zapier allows us to easily automate your submissions of contact us forms to our website, and processes that data and transfers it to JumpDemand (below). Zapier lawfully processes your personal data because it complies with the UK Extension to the EU-U.S. DPF, as set forth by the U.S. Department of Commerce. Zapier has certified to the U.S. Department of Commerce that it adheres to the processing of personal data received from the United Kingdom in reliance on the UK Extension to the EU-U.S. DPF. For more information on how Zapier processes your personal data please see: https://zapier.com/legal/data-privacy. 

We also transfer your personal data outside the United Kingdom to JumpDEMAND Inc (JumpDEMAND) which is a digital marketing automation solutions company based in Canada. Transfers of personal data from the United Kingdom to Canada are lawful because the United Kingdom has made a partial finding of adequacy in relation to Canada as the legal framework in Canada has been assessed as providing adequate protection for personal data.  JumpDEMAND lawfully processes your personal data because it complies with Canada's Personal Information Protection and Electronic Documents Act 2000.

To find out information about what cookies we use please refer to our cookie policy here.

4. 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

5. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data including the following:

• 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.
• Request correction of your personal data.
  • 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 where there is no good reason for us continuing to process it. 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 (see below), where we may have processed your information unlawfully or  where we are required to erase your personal data to comply with local law. 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. 
• 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 your personal data.
  • This enables you to ask us to suspend the processing of your personal data in the  following scenarios:  
  • If you want us to establish the data's accuracy. 
  • Where our use of the data is unlawful but you do not want us to erase it. 
  • 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.  
  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.  
• Request transfer of your personal data.
  • 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.
• Right to withdraw consent.
  • 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. 

If you would like to contact us about our privacy policy or your data please use the contact details provided above.

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