Gobby Privacy Policy

BACKGROUND:

Gobby Ltd (We/ Us/ Our) understand that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of our Clients e.g. organisations that purchase the Gobby service and software to engage with their stakeholders and Users e.g. stakeholders that have agreed to sharing and use of data with the organisation under their own Data Protection and Privacy Policy.

We, as a ‘Data Processor’ e.g. processing personal data on behalf of the Client and under agreed terms. Will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.

Our obligations regarding the collection, processing, transfer, storage, and disposal of personal data is set out in Our Data Protection Policy. The procedures and principles set out therein applies to all employees and third parties working for or providing services on Our behalf, set out below.

1.

Information About Us

Gobby Ltd is registered in England under company number 11776608.
Registered address: C/O BTS Accountancy Services The Hall, Thorpe Street, Raunds, Northants, England, NN9 6LT
VAT number: 306582995.

Data Protection Officer: Gary Beckwith

Email address: info@gobby.io
Telephone number: 07875263091
Postal address: C/O BTS Accountancy Services, The Hall, Thorpe Street, Raunds, Northants, England, NN9 6LT

2.

What Does This Notice Cover?

This Privacy Information explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.

3.

What is Personal Data?

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

The personal data that we use is set out in Part 5, below.

4.

What Are My Rights?

Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:

a.
The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 11.
b.
The right to access the personal data we hold about you. Part 10 will tell you how to do this.
c.
The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 11 to find out more.
d.
The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 11 to find out more.
e.
The right to restrict (e.g prevent) the processing of your personal data.
f.
The right to object to us using your personal data for a particular purpose or purposes.
g.
The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
h.
The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
i.
Rights relating to automated decision-making and profiling. Part 6 explains more about how we use your personal data, including profiling.

For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 11.

It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 11.

5.

What Personal Data Do You Collect and How?

Depending upon your use of Our Site, we may collect and hold some or all of the personal and non-personal data set out in the table below, using the methods also set out in the table. We do not collect any ‘special category’ or ‘sensitive’ personal data and personal data relating to children and data relating to criminal convictions and/or offences.

Data Collected

How We Collect the Data

Identity Information including name, email address and demographic data e.g. gender, job title/ role, department and location held by the organisation using the Gobby service.We receive and process personal GDPR compliant data via the Client and under agreed terms as a ‘Data Processor’ and in agreeing terms of the Contract with the Client.
Payment information including bank account details.We collect and store Client data to establish a commercial contract. No User payment information is collected or stored.
Profile information including communication preferences, interests and purchase/ service use history.We offer options to opt-in to providing additional profile information and permissions for Us to share communications such as Newsletters that are outside the Legitimate Interests of the Contract relationship.
Data from third parties including contact or profile information.We receive and process personal GDPR compliant data via the Client and under agreed terms as a ‘Data Processor’. In some instances, we may receive personal data from other agreed Data Processors as part of terms of the Contract.
Response data from Gobby engagements.Respondents (Users) are invited, via a unique URL sent to their email address, to provide answers to engagement questions via the Gobby online platform.
All data is stored on UK based servers:

- Local storage
- Office 365
- OpusVL
(Gobby Content Management System (CMS) Developers)
Gobby services feedbackClients are invited, via a unique URL sent to their email address, to provide answers to engagement questions via the Gobby online platform.
All data is stored on UK based servers:
- Local storage
- Office 365
- OpusVL (Gobby Content Management System (CMS) Developers)

6.

How Do You Use My Personal Data?

Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes how we may use your personal data, and our lawful bases for doing so:

What We Do

What Data We Use

Our Lawful Basis

Administering our business.Client contact name, address, email address, telephone number(s).Contractual Necessity.
Supplying our products and services to Clients and Users e.g. designing, implementing and analysing Gobby engagement data on behalf of the Client.User names, email addresses, business and demographic information.Contractual Necessity -
Clients are data controllers of the response data collected, while we are the data processors of this data.
ReportingResponse data from Gobby engagements are stored on the Gobby online platform CMS and downloaded to secure local and cloud-based storage for the purpose of analysis and report writing.Contractual Necessity.
Anonymised data will be used to inform organisational decision-making, internal communications and external marketing as deemed appropriate by the Client.
Quality controlClient Lead Contact information as set out in the Proposal and Contract Contractual Necessity.
Anonymised data will be used to inform Our improvement cycle, internal communications and external marketing as deemed appropriate by Us.
Managing payments for our products services.Bank account details, contact name, email address and telephone number(s)Contractual Necessity.
Communicating with Clients.Client contact name, address, email address, telephone number(s).Contractual necessity.

We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 11.

If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.

In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.

7.

How Long Will You Keep My Personal Data?

We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):

Type Of Data

How Long We Keep it

Identity Information including name and demographic data e.g. gender, held by the organisation using the Gobby service.Dependent on the length of the contract with the Client and terms agreed as a data processor. Any User data held following the termination of a contract will be retained for three years or until an objection is made.
Contact information including email addressDependent on the length of the contract with the Client and terms agreed as a data processor. Any User data held following the termination of a contract will be retained for three years or until an objection is made.
Business information including job title or role, department and location.Dependent on the length of the contract with the Client and terms agreed as a data processor. Any User data held following the termination of a contract will be retained for three years or until an objection is made.
Payment information including bank account details.Any financial transaction details held as part of fulfilling contract terms will be retained in line with HMRC statutory requirements plus one year from the end of the last company financial year they relate to.
Consent: Analysis and use of profile information including preferences, interests and purchase/ service use history.We will continue to process your information under this basis until you withdraw consent, or it is determined your consent no longer exists.

8.

How and Where Do You Store or Transfer My Personal Data?

We will only store or transfer your personal data within the UK. This means that it will be fully protected under the Data Protection Legislation.

9.

Do You Share My Personal Data?

We will not share any of your personal data with any third parties for any purposes, subject to the following exceptions.

If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Notice.

In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

10.

How Can I Access My Personal Data?

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 11.

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We will respond to your subject access request within five working days and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

11.

How Do I Contact You?

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details (for the attention of Gobby Support):

Email address: info@gobby.io
Telephone number: 07875263091

12.

Changes to this Privacy Notice

We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

Any changes will be made available on our Terms and Conditions web page at https://gobby.io/terms-conditions.

Last updated on 09/06/2019