Privacy Policy
1. Introduction
1.1 We are committed to safeguarding the privacy of our website visitors, service users, individual customers and customer personnel, and individual suppliers and supplier personnel.
1.2 This policy applies where we are acting as a data controller with respect to the personal data of such persons; in other words, where we determine the purposes and means of the processing of that personal data.
1.3 We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website and services, we will ask you to consent to our use of cookies when you first visit our website.
1.4 In this policy, the terms “we”, “us” and “our” refer to Morphologic Ltd. For more information about us, see Section 19.
2. The personal data that we collect
2.1 In this Section 2 we have set out the general categories of personal data that we process and, in the case of personal data that we did not obtain directly from you, information about the source and specific categories of that data.
2.2 We may process data enabling us to get in touch with you (“contact data”). The contact data may include your name, email address, telephone number, and/or postal address. The source of the contact data is you and/or your employer.
2.3 We may process information relating to our customer relationships (“customer relationship data”). The customer relationship data may include your name, the name of your business or employer, your job title or role, your contact details, your classification / categorisation within our customer relationship management system and information contained in or relating to communications between us and you, or between us and your employer. The source of the customer relationship data is you and/or your employer.
2.4 We may process information contained in or relating to any communication that you send to us or that we send to you (“communication data”). The communication data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms.
2.5 We may process your personal data that is contained in or associated with any deliverables that you produce and provide to us, or that is contained in or associated with any deliverables produced and provided to us by your employer or any relevant third party in connection with the work that your employer performs for us (“deliverables data”). The source of the service data is you, your employer or the relevant third party.
2.6 We may process your personal data relating to the services that your employer provides to us, including data in contracts between us and your employer, data concerning the nature of the services and data concerning the time and manner of the performance of the services (“services data”). The source of the services data is you, your employer or our own personnel.
2.7 We may process data about your use of our website and services (“usage data”). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system.
2.8 Please do not supply any other person’s personal data to us, unless we prompt you to do so.
3. Purposes of processing and legal bases
3.1 In this Section 3, we have set out the purposes for which we may process personal data and the legal bases of the processing.
3.2 Operations – We may process your personal data for the purposes of operating our website, the processing and fulfilment of orders, providing our services, generating invoices, bills and other payment-related documentation, and credit control. The legal basis for this processing is our legitimate interests, namely the proper administration of our website, services and business.
3.3 Relationships and communications – We may process contact data, account data, customer relationship data, transaction data and/or communication data for the purposes of managing our relationships, communicating with you (excluding communicating for the purposes of direct marketing) by email, SMS, post and/or telephone, providing support services and complaint handling. The legal basis for this processing is our legitimate interests, namely communications with our website visitors, suppliers, service users, individual customers and customer personnel, the maintenance of our relationships, enabling the use of our services and supplier services, and the proper administration of our website, services and business.
3.4 Direct marketing – We may process contact data, account data, profile data, customer relationship data and/or transaction data for the purposes of creating, targeting and sending direct marketing communications by email, SMS and/or post and making contact by telephone for marketing-related purposes. The legal basis for this processing is our legitimate interests, namely promoting our business and communicating marketing messages and offers to our website visitors and service users.
3.5 Research and analysis – We may process usage data and/or transaction data for the purposes of researching and analysing the use of our website and services, as well as researching and analysing other interactions with our business. The legal basis for this processing is our legitimate interests, namely monitoring, supporting, improving and securing our website, services and business generally.
3.6 Record keeping – We may process your personal data for the purposes of creating and maintaining our databases, back-up copies of our databases and our business records generally. The legal basis for this processing is our legitimate interests, namely ensuring that we have access to all the information we need to properly and efficiently run our business in accordance with this policy.
3.7 Security – We may process your personal data for the purposes of security and the prevention of fraud and other criminal activity. The legal basis of this processing is our legitimate interests, namely the protection of our website, services and business, and the protection of others.
3.8 Insurance and risk management – We may process your personal data where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks and/or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
3.9 Legal claims – We may process your personal data where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
3.10 Legal compliance and vital interests – We may also process your personal data where such processing is necessary for compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person. others.
4. Providing your personal data to others
4.1 Subject to receiving your prior consent, we may disclose your personal data to our business change consultant partner, insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.
4.2 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice.
4.3 Your personal data will be stored on the servers of our hosting services providers: Digital Ocean and Auth0.
4.4 We may disclose your personal data to our suppliers or subcontractors identified in the table below insofar as reasonably necessary for providing our services.
Supplier: MS 365
Service provided: Email, office application
4.5 In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
5. International transfers of your personal data
5.1 In this Section 5, we provide information about the circumstances in which your personal data may be transferred to a third country under UK data protection law.
5.2 Auth0 (one of our hosting services providers) process the personal data we control in the EU. The competent data protection authorities have made an adequacy determination with respect to the data protection laws in the EU.
5.3 MS 365 is situated in the United States. Transfers to this country will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the competent data protection authorities, a copy of which can be obtained from https://www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA?year=2021
5.4 You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
6. Retaining and deleting personal data
6.1 This Section 6 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
6.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
6.3 We will retain your personal data as follows:
(a) Where you (or your employer) are our customer, we will retain your personal data for so long as you (or your employer) remain our customer and for 6 years after you (or your employer) cease to be our customer.
(b) Where you (or your employer) are our supplier, we will retain your personal data for so long as you (or your employer) remain our supplier and for 6 years after you (or your employer) cease to be our supplier.
(c) Where you are on our mailing list for marketing purposes, we shall retain your data for as long as you consent to be on that mailing list.
(d) Otherwise, we will retain your personal data for a maximum period of one month following its collection.
6.4 Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
7. Security of personal data
7.1 We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.
7.2 We will store your personal data on secure servers, personal computers and mobile devices, and in secure manual record-keeping systems.
7.3 Data relating to your enquiries that is sent from your web browser to our web server, or from our web server to your web browser, will be protected using encryption technology.
7.4 You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
8. Your rights
8.1 In this Section 8, we have listed the rights that you have under data protection law.
8.2 Your principal rights under data protection law are:
(a) the right to access – you can ask for copies of your personal data
(b) the right to rectification – you can ask us to rectify inaccurate personal data and to complete incomplete personal data;
(c) the right to erasure – you can ask us to erase your personal data;
(d) the right to restrict processing – you can ask us to restrict the processing of your personal data;
(e) the right to object to processing – you can object to the processing of your personal data;
(f) the right to data portability – you can ask that we transfer your personal data to another organisation or to you;
(g) the right to complain to a supervisory authority – you can complain about our processing of your personal data; and
(h) the right to withdraw consent – to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.
8.3. These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by visiting https://edpb.europa.eu/our-work-tools/general-guidance/gdpr-guidelines-recommendations-best-practices_en and https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.
8.4 You may exercise any of your rights in relation to your personal data by written notice to us, using the contact details set out below.
9. Third party websites
9.1 Our website includes hyperlinks to, and details of, third party websites.
9.2 In general we have no control over, and are not responsible for, the privacy policies and practices of third parties.
10. Personal data of children
10.1 Our website and services are targeted at persons over the age of 18.
10.2 If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.
11. Updating information
11.1 Please let us know if the personal information that we hold about you needs to be corrected or updated.
12. Acting as a data processor
12.1 In respect of our Customers’ personal data that we process following their instructions whilst using our services, we do not act as a data controller; instead, we act as a data processor.
12.2 Insofar as we act as a data processor rather than a data controller, this policy shall not apply. Our legal obligations as a data processor are instead set out in the contract between us and the relevant data controller.
13. About cookies
13.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
13.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
13.3 Cookies may not contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.
14. Cookies that we use
14.1
We also use the following cookies:
Strictly necessary cookies. These are cookies that are required for the operation of our website. In particular, the cookies we use are required for login to function properly within our software. Cookies used for this purpose are:
auth0.sessionID.organization_hint
auth0.sessionID.is.authenticated
_legacy_auth0.sessionID.organization_hint
_legacy_auth0.sessionID.is.authenticated
15. Managing cookies
15.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647 (Chrome);
(b) https://support.mozilla.org/en-US/kb/enhanced-tracking-protection-firefox-desktop (Firefox);
(c) https://help.opera.com/en/latest/security-and-privacy/ (Opera);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(e) https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac (Safari); and
(f) https://support.microsoft.com/en-gb/help/4468242/microsoft-edge-browsing-data-and-privacy (Edge);
15.2 Blocking all cookies will have a negative impact upon the usability of many websites.
15.3 If you block cookies, you will not be able to use all the features on our website.
16. Amendments
16.1 We may update this policy from time to time by publishing a new version on our website.
16.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
17. Our details
17.1 This website is owned and operated by Morphologic Ltd.
17.2 We are registered in England and Wales under registration number 09346803.
17.3 Our principal place of business is at The Plex, 15 Margaret Street, WF1 2DQ.
17.4 You can contact us:
(a) by post, to the postal address given above; or
(b) using our website contact form.
18. Data protection registration
18.1 We are registered as a data controller with the UK Information Commissioner’s Office.
18.2 Our data protection registration number is ICO:ZA743298