Triaster Privacy Policy

Version 11: 2nd August 2023

We are Triaster Ltd. This policy sets out the basis on which we process the data we collect from you or that you provide to us. This policy is to be read alongside our Triaster Terms of Service and Triaster Cloud Services Terms of Use.

Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.

1. Important Information and Who We Are

Triaster Limited is a limited company registered in England and Wales under company number 02911867 and have our registered office at Thames Wing Office 2, Howbery Business Park, Wallingford, Oxfordshire, OX10 8BA. Our VAT number is GB 603 9034 66.

Triaster Ltd is the data controller or processor (as appropriate) and is referred to as the “Company”, “we”, “us” or “our” in this policy Our full details are:

Full name: Triaster Limited
Email address: info@triaster.co.uk
Trading address:  Thames Wing Office 2, Howbery Business Park, Wallingford, Oxfordshire, OX10 8BA
Telephone number: 0207 770 8053

2. What Information Do We Collect or Process?

We may collect, use, store and transfer different kinds of personal data in relation to visitors to our websites, or our customers or prospective customers of our services (for these purposes where the customer or prospective customer is a business, its account administrators or representatives, and its end-users) which we have grouped together below.

• Admin Data includes first name, last name, position, username or similar identifier, title, email address, telephone numbers, address.
• Transaction Data includes details about purchases and orders made, payments to and from us, billing and other details of products and services you have purchased from us.
• Technical Data includes internet protocol (IP) address, 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 used to access this website and/or our services.
• User Data in relation to your employees / customers / contractors or other third parties who you grant access to our services (“Users”) including username and password, email address, [other].
• Usage Data includes information about how you and your Users use our website, software, 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 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 may also process Special Categories of Personal Data about your Users (this includes details about their race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about their health including any medical conditions and health and sickness records) if this is necessary for your use of our services.

Where data is provided to us relating to your Users, you, as the data controller in relation to such data, will be responsible for determining whether to provide us with the data, as well as establishing an appropriate legal basis for our processing of the data as required under data protection law.

We do not collect any information about criminal convictions and offences or details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership and genetic and biometric data.

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

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.

Where we act as processor

Where you are a User of our customer, our customer may collect and process personal data about you via the services that we provide to our customer. In such circumstances, we are acting a processor of the personal data on behalf of our customer, who is the controller of that personal data and determines the purposes for which they will use your personal data and the lawful basis for which it will be processed. Our customer should provide you with information about the personal data they collect about you, the purposes for, and the lawful basis on which, they are processing that personal data and how to exercise your rights as a data subject. You should refer to that information in relation to the processing of personal data by our customer.

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 Admin and Transaction Data by filling in forms or by corresponding with us by post, phone, email, live chat or otherwise. Your Users may give us User Data, Usage Data and Technical Data by using our websites or services. This includes personal data provided when:
  • You make an enquiry about a product or service;
  • User accounts are created on our sites;
  • You subscribe for any services;
  • Data is uploaded to our systems as part of the services that we provide to you;
  • Marketing or other information is requested to be sent to you by us or a third party (such as requests for marketing information you have requested by attending an affiliated event);
  • You complete a survey; or
  • You or your Users give us feedback or contact us.
• Third party services. We will receive personal data about you from various third parties, including:
  • HubSpot which is used to log and track support issues you may have. Your data including name, email address and contact number will be added to the support ticket to support our contractual obligation to you. Hubspot’s Privacy Policy is published here https://legal.hubspot.com/privacy-policy.
  • Adobe Sign and Xodo are used to digitally sign contractual information. Your data including name and email address are stored on Adobe Sign and Xodo. Adobe Sign’s Privacy Policy is published here https://www.adobe.com/uk/privacy/policies-business/esign.html. Xodo’s Privacy Policy is stored here https://eversign.com/legal/privacy.
  • HubSpot is our CRM system and one of our content management systems. Your data including name, email address, contact number, history of site interactions and stated marketing preferences is stored on HubSpot. It is used to provide product information to you which may help you make a selection of a supplier. HubSpot’s Privacy Policy is published here https://legal.hubspot.com/privacy-policy.
  • Xero which is used to maintain billing and financial information. Your data including name, email address and contact number will be added to the customer record to maintain our supplier relationship to you. Xero’s Privacy Policy is published here https://www.xero.com/uk/about/legal/privacy/.
  • Stripe is used to maintain billing and financial information. Your data including name, email address, subscription information and credit card details are stored on this site. Credit card details are encrypted and not visible to Triaster. Stripe’s Privacy Policy is available here https://stripe.com/gb/privacy. 
  • Google which may provide us with Technical Data about your visit to our website via its analytics service. Google’s privacy policy is published here https://www.google.com/policies/privacy/partners/.

Cookies

Triaster uses cookies to distinguish users. Third party services may also use cookies and you are referred to the policy locations listed above for details on third party use of cookies.

When a cookie is placed on your hard drive by Triaster, it is intended to gather information about your use of the web site or service you are using at that time. This helps us ensure that you are provided with a good experience when you browse our website or use our services. The type of cookies we use can be broken down as follows:

• Strictly necessary cookies that are required for the operation of our website. For example, cookies that enable you to log in to our secure areas.
• Functionality cookies that are used to recognise you when you return to our site and display the site according to your preferences and feature selections.

4. How Do We Use Your Information?

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:

• To fulfil and perform any contracts we have with you in order to provide our services;
• Where it is necessary for our legitimate interests (or those of a third party) and your interest and fundamental rights do not override those interests; and
• Where we need to comply with a legal obligation.

The glossary below sets out more detail about the types of lawful basis that we will rely on to process your personal data.

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. 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 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 both where such processing occurs across the portfolio of services we offer and for specific services we offer. We have also identified what our legitimate interest are where appropriate.

We may process your personal data for more than one lawful ground depending on the specific purposes 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.

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. Who has Access to Your Personal Data?

We will retain access to all personal data that we collect from or about you.

We may share your personal information within any business that is controlled or managed by Triaster, or with selected third parties for the purpose of our routine business operations including but not limited to:

• Our approved, resellers, suppliers and subcontractors;
• Service providers acting as processors including but not limited to our website host provider HubSpot, Elite Group (Hosted Services provider), Xodo, Adobe Sign, HappyFox, Xero, and Stripe;
• Advertisers and advertising networks that we use for our marketing;
• Professional advisers including lawyers, bankers, accountants and insurers based in the UK;
• HM Revenue and Customs, regulators and other authorities based in the United Kingdom; and
• Any analytic providers that assist us in the improvement and optimisation of our website.

We may disclose your personal information to third parties:

• If we are required to do so by law or in order to comply with any legal obligations;
• If our business is sold or merged, or if we sell or buy any business or assets, we may disclose your personal data to the prospective seller or buyer of such business or assets; and
• If we offer or supply you a service that is provided on our behalf by a third party.

6. Data Retention

We will 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.

By law we must keep basic information about our customers (including Contact, Identity, Financial and Transaction Data for six years after they cease being a customer for tax purposes.

In particular:

• Support Tickets will be retained for the duration of your contract with us and supporting files will be securely. destroyed after a maximum of 1 year upon resolution of support issue;
• Personal data will be retained for a maximum of 2 years after the termination of a contract;
• Financial transactions will be retained in line with current HMRC regulations;
• Data provided for an event held by Triaster will be retained for 6 months following the event;
• Marketing contacts will be retained for a maximum of 12 months where no contact has been made.

7. Where Do We Store Your Personal Data?

The data that we collect from you may be transferred to and stored at, a destination outside of the UK. It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers and includes suppliers operating in the US.

Whilst destinations outside of the UK may not have equivalent obligations for the protection of personal data, we are under a duty to ensure, so far as is reasonably necessary, that the storage and use of your data outside of the UK is processed and stored securely and in accordance with this policy.

Unfortunately, the transmission of information via the internet is not completely secure. We implement appropriate technical and organisation measures to protect your personal data, but we cannot guarantee the security of your data transmitted to our site. Any transmission of data is at your own risk.

When transferring your data outside of the UK ensure a similar degree of protection is afforded to it by ensuring one of the following safeguards is implemented:

• We will only transfer data to countries that have been deemed to provide an adequate level of protection for personal data.
• Where we use service provides outside the UK, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

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. Your Legal Rights

Under data protection laws you have the following rights in relation to your personal data:

• 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 the personal data that we hold about you. 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 of 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; or
  • You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
    
    
• 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.
• 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 have any questions, comments or requests in relation to our processing of your data please contact us on https://www.triaster.co.uk/contact.

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.

You have the right to ask us not to process your personal data for marketing purposes at any time, and You can exercise your right to prevent such processing by ticking any relevant boxes on the forms we use to collect your data, or by contact us on https://www.triaster.co.uk/contact.

Our site may contain links to third-party websites. Please note that these third parties have their own privacy policies and we do not accept any liability or responsibility for these policies. Please check these policies before you submit your personal data to their websites.

Your Right to Complain

If you have a complaint about how we are processing your personal data, you have the right to complain to the supervisory authority. In the UK this is the Information Commissioners Office https://ico.org.uk/concerns.

Changes to this Policy

Any changes we make to this policy in the future will be posted on this page and, where appropriate, notified to you. Please check back frequently to see any updates or changes.

If you need to contact us, please visit https://www.triaster.co.uk/contact.

9. Glossary

Lawful Basis

Legitimate Interest

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of a Contract

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a Legal Obligation

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.