We are Photon Force Ltd (Photon Force), a company incorporated in Scotland with registered number SC501215 and having our registered office address at Murchison House, 10 Max Born Crescent, Edinburgh, Scotland, EH9 3BF.
Photon Force is a controller for the purposes of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27th April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (General Data Protection Regulation) as it forms part of the law of England and Wales, Scotland and Northern Ireland by virtue of section 3 of the European Union (Withdrawal) Act 2018 (the UK GDPR), the Data Protection Act 2018 and related data protection legislation.
In this privacy statement, we explain what personal data Photon Force processes and for what purposes. If you have any questions about the contents of the privacy statement, you can contact Photon Force at privacy@photon-force.com.
“Personal data”, or personal information, means any information about an individual from which that person can be identified. Photon Force processes different types of personal data for different purposes. The types of personal data and purposes involved are explained below.
Where we need to collect personal data by law or under the terms of a contract we have with you (or are trying to enter into with you) and you fail to provide that data when requested, we may not be able to perform the contract. In this case, we may have to cancel a contract (but we will notify you if this is the case at the time).
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 the Information Commissioner’s Office of a breach where we are legally required to do so.
Lawful basis of processing
Personal data will be processed by us where you consent to the processing or where that processing is necessary for 1) the performance of a contract with you; or 2) compliance with a legal obligation to which we are subject; or 3) the purposes of our legitimate interests (or those of a third party).
“Legitimate interests” means the interest of our business in conducting and managing that 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.
Delivery of our products
In order to deliver our products, we need your name, organisation name, e-mail address, delivery address, invoice address, payment details, and your telephone number. This data allows us to process your request, contact you, provide our services, and keep you informed of the process. Where necessary for delivering the products, we disclose your personal data to third parties, e.g. Xero, our accounting software provider, Zoho, our CRM software provider, and to delivery services.
Social media
Photon Force can be found on social media, such as Twitter. We collect your personal data for our legitimate interests when you use functions on these websites and/or apps, such as a Twitter like. If you use such a function, we are able to obtain your personal data via our social media.
Financial data
We do not currently collect financial information directly from you, as that information is collected and stored by our third-party payment provider. However, we may from time to time request and receive some of your financial information from our financial institution for the purposes of completing transactions you have initiated through the services, protecting against or identify possible fraudulent transactions, and otherwise as needed to manage our business. In those cases we will use best practices to protect your financial information.
Business Development and Customer Identification
Direct marketing
For acquiring new customers, we collect commercially interesting information about organisations, such as the position of a company within the market, the possible interest or further interest of the organisations in our products, and the persons within the organisations who we wish to contact or have contacted. We collect the contact details of those persons, information about their visits to trade fairs, memos based on discussions and telephone conversations, emails, and visit reports. We collect similar information of suppliers and potential suppliers. This information is carefully organised and stored in Capsule CRM, a database that is accessible only by authorised employees.
If you represent another business, we may provide you with direct marketing communications where we feel that this may be relevant to your business (provided that you have not opted out of such communications). When we use your personal data for such purposes, we do so on the basis that it is in our legitimate interests to pursue direct marketing, provided that it constitutes fair processing of your personal data to do so.
You can also opt-out or unsubscribe from all or some of these marketing communications at any time by contacting us at privacy@photon-force.com.
Where you opt out of receiving these marketing communications, this opt-out will not apply to personal data provided to us for any other purpose.
Recipients
Within the organization of Photon Force, we can pass on personal data. We do not share your personal details with companies, organisations, or individuals outside Photon Force, except in one of the following circumstances.
Implementation of an agreement
Issuing your personal data to third-party organisations is permitted if this is necessary to fulfil our contractual obligations with respect to you. This involves processing and delivering your order. If it is necessary for the delivery of the products ordered by you or the services requested, we use a third party for the finalisation of payments. We also pass on your data to the deliverer as far as necessary so that the order can be delivered to you.
For external processing
We issue personal details to our partners so that they can process data for us on the basis of our instructions and in accordance with our privacy policy and other appropriate confidentiality and security measures. Our partners include our IT suppliers, analytics parties and the CRM system administrator.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
For legal reasons
We share personal data if we believe that disclosure of the data is necessary in order to comply with applicable legislation, statutory procedures or requests from government bodies.
Except in emergency situations or when consistent with the Photon Force Terms and Conditions or this Privacy Policy, Photon Force requires valid and sufficient legal process to compel disclosure of records or information about Photon Force customers. This process must contain enough information to identify the customer’s account and minimize the likelihood of accidental disclosure of information from unrelated accounts.
In the event of a sale
In some cases, we may choose to buy or sell assets. In these types of transactions, personal information is typically one of the transferred business assets. Moreover, if we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, personal information would be one of the assets that is transferred or acquired by a third party. If a change happens to our business, then the new owners may use your personal information in the same way as set out in this privacy notice.
Retention period
Our principle at Photon Force is to only hold your data as long as is necessary, unless we have a statutory obligation to retain your personal data for a longer period. Our basic principle is that we retain your personal data only for as long as that is necessary in order to deliver our products and/or services to you. We will subsequently remove your personal data in so far as possible. If, for instance, you have provided your e-mail address so that we can keep you informed of our services, we will retain your data for that purpose.
Transfer of personal data outside the UK
We generally do not transfer your personal data out of the UK. However, whenever we are required to transfer your personal data out of the UK (for example where a third-party supplier is located outside of the UK), we ensure a similar degree of protection is afforded to it by ensuring that appropriate safeguards are implemented, including any of the following:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the UK.
- Where we use certain service providers, we may use specific contracts approved by the UK government which give personal data the same protection it has in the UK.
Photon Force is responsible for the optimal performance of its website. To ensure that the website functions properly, Photon Force uses technology that involves processing personal data, such as cookies.
A cookie is a small text file that is stored on the visitor’s device (electronic appliance) when the site is first visited. Cookies are intended to collect information about a person, the website or statistics. Some cookies are also intended to improve user experiences of the website.
You can opt out of optional cookies on our website through our cookie consent bar. If you have previously accepted our cookies, the cookie notice will no longer appear upon visiting our site and you will have to remove the cookies yourself in your browser settings (if desired).
You can also opt to block the use of cookies via your browser. If you block the use of all cookies, our website will work less efficiently. We advise you to block only undesired cookies. You can do so in your browser settings.
Google Analytics
This website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to help the website operators analyse how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google.
Third Party Sites
Please be aware that some of the websites to which we provide links may collect personally identifiable information about you. We do not control these sites and are not responsible for the content or practices of third party websites. This privacy policy does not cover such sites.
Social Media Cookies
Photon Force is active on a range of social media platforms. We have no control over the use of cookies on these third-party sites. Please follow these links for more information on the privacy policies of the individual social media sites where Photon Force is active:
Twitter – https://twitter.com/privacy
LinkedIn – http://www.linkedin.com/static?key=privacy_policy
You have a number of statutory rights with respect to us: access, corrections or additions, data deletion, limitation of processing, data portability, and the right of objection. We explain these rights below. We also explain how you can exercise these rights with respect to Photon Force.
Right of access
Upon your request, we will inform you in writing whether we are processing your personal data. When making your request, you must identify yourself by means of a copy of your driving licence or identity document. In our response, we will explain which of your personal data we have processed or are still processing. We will also explain the purposes for which the data has been or is still being processed, the parties with which the data is being shared, the period for which this data is expected to be stored, and which other rights you can exercise.
Corrections or additions
If you have received details about the processing of your personal data, you can request that we correct inaccuracies or to make additions to incomplete information. We will respond accordingly. If we make corrections, you will receive a supplementary statement from us. That statement will also be sent to any recipients of your incorrect or incomplete data.
Deletion of personal data
You can request that we delete your personal data from our systems in one or more of the following cases:
- the personal data is no longer necessary for the purposes for which we have processed it;
- you withdraw your permission for processing or further processing and no other basis for processing exists;
- you lodge a motivated objection, and there are no urgent reasons for not respecting your objection;
- the personal data has been wrongfully processed by us;
- we have to delete your personal data on the basis of a statutory obligation of which we had no knowledge before you informed us thereof.
Limitation of processing
If you have noticed an inaccuracy or incompleteness in your personal data, you can request that we limit the processing for as long as we are dealing with your request. You may also request that we limit the processing of your data if you believe that we are wrongfully processing your data or if we no longer need it, or if you have lodged an objection against the processing or the further processing of the data. After the receipt of your limitation request, we will continue to process the data only with your permission or if there are compelling reasons for doing so (such as legal proceedings).
Data Portability
If you have provided us with personal data and we have processed your data with your permission or in the context of implementing an agreement with you, where technically feasible, you will be entitled to request a copy of this data to be transferred directly to another service provider/data controller.
Objection
You may lodge an objection at any time against the processing of personal data relating to you. We will cease processing your data following the receipt of your objection, unless we can put forward justifiable reasons that outweigh your interests, rights and liberties.
If we process your personal data for direct marketing purposes, you may object at any time and we will cease processing immediately.
Exercising rights
If you wish to exercise one or more of the rights summarised above, you can contact us at legal@photon-force.com. Photon Force will decide on your request within one month, unless we inform you within that period that we need more time.
If your personal data is processed on the basis of your permission, you will be entitled to withdraw that permission. Any withdrawal of your permission will not prejudice previous processing on the basis of that permission.
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 may refuse to comply with your request in these circumstances.
Complaints
If you have a complaint about the use of your personal data, please contact Photon Force at legal@photon-force.com. You can also contact the Information Commissioner’s Office. This body is authorised to examine your complaint.
Any questions?
If you have any questions, please e-mail us at: privacy@photon-force.com.
We reserve the right to update this privacy statement periodically. The latest version will be published on this page.