Privacy Policy

This policy explains how PositiveITSystems.co.uk Ltd (“we”, “us”, “our”), the operator of www.positiveitsystems.co.uk(the “Site”), collects, uses and protects your personal data. It is written to comply with the UK General Data Protection Regulation (UK GDPR) and Data Protection Act 2018, and the EU General Data Protection Regulation (EU GDPR) (Regulation (EU) 2016/679), for visitors based in the United Kingdom and the European Economic Area (EEA).

If you have any questions about this policy or how we handle your data, please contact us using the details in the “How to Contact Us” section below.

1. Who We Are

Data controller: PositiveITsystems.co.uk Ltd

Address:c/o Bedford Business Centre, 61 -63 St Peter’s Street, Bedford MK40 2PR

Email: privacy@positiveitsystems.co.uk

If you are based in the EEA and we do not have an establishment there, our EU representative (if required under Article 27 GDPR) is: Hanish Naran

We have an appointed Data Protection Officer, Hanish Naran.

2. What Personal Data We Collect

As a website, we collect the following categories of personal data:

• Contact form data: your name, email address, and the content of any message you send us through a contact or enquiry form.
• Account data: if you register for an account (e.g. to comment or access member content), we collect your username, email address, password (stored securely, hashed), and any profile information you choose to add.
• Newsletter/marketing data: your email address, and, if provided, your name, when you subscribe to our newsletter or mailing list.
• Usage and analytics data: information about how you use the Site, collected automatically via cookies and similar technologies, including your IP address, browser type and version, device type, pages visited, time spent on pages, referring website, and general location (city/country level).

We do not knowingly collect any special category data (such as health, religious belief, or political opinion data) through the Site.

3. How We Collect Your Data

• Directly from you: when you fill in a contact form, create an account, or subscribe to our newsletter.
• Automatically: through cookies and similar tracking technologies when you browse the Site (see Section 6, Cookies).

4. Legal Basis for Processing

Under UK GDPR and EU GDPR, we must have a valid legal basis to process your personal data. We rely on the following:

• Consent (Article 6(1)(a)): for placing non-essential cookies and analytics tags, and for sending marketing/newsletter emails. You can withdraw consent at any time.
• Contract (Article 6(1)(b)): to create and manage your account and provide the services you request.
• Legitimate interests (Article 6(1)(f)): to respond to enquiries submitted via our contact form, to maintain the security and proper functioning of the Site, and to understand how the Site is used so we can improve it. We have considered that these interests are not overridden by your rights and freedoms.
• Legal obligation (Article 6(1)(c)): where we need to retain or disclose data to comply with the law.

5. How We Use Your Data

• To respond to messages sent through our contact form.
• To create, maintain and secure your account, and to enable features such as commenting.
• To send newsletters or marketing communications you have subscribed to (you may unsubscribe at any time via the link in any email or by contacting us).
• To analyse Site traffic and usage patterns (via Google Analytics) so we can understand and improve the content and performance of the Site.
• To maintain the security of the Site and prevent fraud or abuse.
• To comply with our legal obligations.

We do not sell your personal data to third parties.

6. Cookies and Similar Technologies

The Site uses cookies and similar technologies to distinguish you from other users, remember your preferences, and understand how the Site is used. On your first visit, we ask for your consent to non-essential cookies via a cookie banner, in line with the UK Privacy and Electronic Communications Regulations (PECR) and the EU ePrivacy Directive.

We use the following categories of cookies:

• Strictly necessary cookies: required for the Site to function (e.g. keeping you logged in). These do not require consent.
• Analytics cookies: Google Analytics cookies that help us understand how visitors use the Site (e.g. pages visited, time on site, general location). These are only set with your consent.
• Functionality cookies (if used): remember choices you make, such as language preference.

You can manage or withdraw your cookie consent at any time through your browser settings. Disabling cookies may affect the functionality of the Site.

7. Sharing Your Data with Third Parties

We use the following third-party service provider, which processes personal data on our behalf as a data processor:

• Google Analytics (Google Ireland Limited / Google LLC): used to collect anonymised/pseudonymised analytics about Site usage. Google’s privacy policy is available at https://policies.google.com/privacy.

We may also disclose your data where required by law, to protect our legal rights, or in connection with a business transfer (such as a merger or sale of assets), in which case we will notify you where required to do so.

We do not share your personal data with third parties for their own independent marketing purposes without your consent.

8. International Data Transfers

Some of our third-party service providers, such as Google, may process data outside the UK and EEA, including in the United States. Where this happens, we ensure appropriate safeguards are in place, such as:

• The recipient being certified under an adequacy decision recognised by the UK or the European Commission; or
• Standard Contractual Clauses (SCCs) approved by the European Commission, together with the UK International Data Transfer Addendum, where applicable.

You can request more information about these safeguards by contacting us.

9. Data Retention

• Contact form enquiries: retained for 2 years after our correspondence ends, unless a longer period is needed to resolve a dispute or comply with the law.
• Account data: retained for as long as your account remains active, and for 7 years after closure, after which it is deleted or anonymised.
• Newsletter/marketing data: retained until you unsubscribe or withdraw consent.
• Analytics data: retained in Google Analytics in line with Google’s default retention settings 14 months
• We will not keep your personal data for longer than necessary for the purposes it was collected for.

10. Your Rights

Under the UK GDPR and EU GDPR, you have the following rights in relation to your personal data:

To exercise any of these rights, please contact us using the details in Section 1. We will respond within one month, as required by law. We may need to verify your identity before actioning a request.

11. How to Complain

If you are unhappy with how we have handled your personal data, please contact us first so we can try to resolve the issue. You also have the right to lodge a complaint with a supervisory authority:

• UK residents: Information Commissioner’s Office (ICO) — ico.org.uk, telephone 0303 123 1113.
• EEA residents: the data protection authority in your EU member state of residence, work, or the location of the alleged infringement. A full list is available at https://edpb.europa.eu/about-edpb/about-edpb/members_en.

12. Children’s Privacy

The Site is not directed at children, and we do not knowingly collect personal data from anyone under the age of 16 (or the applicable age of consent in your country). If you believe a child has provided us with personal data, please contact us so we can delete it.

13. Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, loss or destruction.This includes the use of secure hosting environments, encryption of passwords,TLS/SSL encryption for data in transit and strict internal access controls. However, please note no method of transmission over the internet is 100% secure, and we cannot guarantee absolute security.

14. Changes to This Policy

We may update this policy from time to time to reflect changes in our practices or legal requirements. The “Last updated” date at the top of this policy shows when it was last revised. We encourage you to review this policy periodically.

15. How to Contact Us

If you have any questions about this Privacy Policy or wish to exercise your data protection rights, please contact us:

• Email: dpo@positiveitsystems.co.uk
• Post: PositiveITSystems.co.uk Ltd, c/o Bedford Business Centre, 61 – 63 St Peter’s Street, Bedford MK40 2PR