Privacy Notice

CDSM INTERACTIVE SOLUTIONS LIMITED PRIVACY NOTICE

Last updated April 2018

Under the EU’s General Data Protection Regulation (GDPR) ‘Personal Data’ is defined as:

“any information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.

CDSM respects your privacy and is committed to protecting your Personal Data. This Privacy Notice will inform you as to how we look after your Personal Data, tell you about your privacy rights and how the law protects you.

1.0 Purpose of this Privacy Notice

2.0 Contact details

3.0 Changes to the Privacy Notice and your duty to inform us of changes

It is important that the Personal Data we hold about you is accurate and current. Therefore, please keep us informed if your Personal Data changes during your relationship with us.

4.0 The data we collect about you

We do not normally collect any special categories of data nor do we collect any information about criminal convictions and offences other than for our employees or applicants for employment. However, if we do need to process any special categories of data then we will ask for your explicit consent to do so.

5.0 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 or employee benefits). 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.

6.0 We use different methods to collect data from and about you including through:

7.0 How we use your Personal Data

8.0 Purposes for which we will use your Personal Data

Purpose/Activity
Category of Personal Data
Lawful basis for processing including basis of legitimate interest
To register you as a new client, customer, employee or prospective employee.
(a) Identity
(b) Contact
Performance of a contract with you
To process and deliver your service or order including:

(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests
- to recover debts due to us.
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
(c) As an employee
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Financial
(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,
- to study how customers and clients use our products/services; and,
- to administer our employee relationships
To enable you to partake in a prize draw, competition or complete a survey
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests
- to study how customers use our products/services; and
- to develop them and grow our business.
To administer and protect our business and our intranet and website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)  
(a) Identity
(b) Contact
(c) Profile
(d) Technical
(e) Usage
(a) Necessary for our legitimate interests
- for running our business and employee relationship,
- 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 deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical
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.


To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
(a) Technical
(b) 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 goods or services that may be of interest to you
(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
Necessary for our legitimate interests
- to develop our products/services; and,
- to grow our business

9.0 Marketing

10.0 Change of purpose

11.0 Disclosures of your Personal Data

12.0 International transfers

13.0 Data security

14.0 Data retention

15.0 Your legal rights

16.0 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.

17.0 Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may 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.