BetterTrack(TM) – Platform as a Service Privacy Policy Overview

  • This policy is effective from 1st October 2021.

  • BetterTrack Ltd (“we”, “us” or “our” within this privacy notice) is committed to protecting and respecting and safeguarding your right to privacy while using and interacting with the software as a service platform.

  • Any information collected will only be used in accordance with this privacy policy.

  • BetterTrack may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes.

  • This privacy policy explains how we use any personal information we collect about you. This privacy policy specifically regards personal data collected on instance. Bettertrack.org and any subdomains thereof.

  • We require this information to provide you with a better service, and in particular for the following reasons:

  • To run tests on software usage and performance including performance through customer networks

  • To provide proactive help and support where we identify usage issues which may include a reconfiguration of the software

  • To improve the quality and performance our software and services

  • To evaluate the value of improved practices using the software

  • We are committed to ensuring that your information is secure. In order to prevent unauthorized access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information.

  • We do not use cookies.

  • We will not sell, distribute or lease your personal information to third parties unless we are required by law to do so.

Our Status

BetterTrack Limited is the data controller and we are responsible for your personal data.

Our Contact Details

Our full details are:

  • Company name: BetterTrack Limited

  • Company Number: 11877539 (Company registered in England & Wales)

  • Email address: info@bettertrack.org

Complaints
  • If you are not happy with any aspect of how we collect and use your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO), the UK’s data protection supervisory authority for data protection issues (https://ico.org.uk/concerns/). 

  • We would appreciate being contacted first if you do have any issues, so that we may look to resolve.

Keeping Data Up To Date
  • It is important that the personal data we keep is accurate and, where necessary, kept up to date via the user profile screen.

Why We Use Your Personal Data
  • In accordance with the EU’s GDPR, all personal data shall be processed lawfully, fairly, and in a transparent manner. We will only use your personal data in circumstances where we are legally permitted to do so. The most common uses of your personal data are:

  • Where you have consented to receive marketing communications from us via email or text; To fulfil contractual obligations between us;

  • Where it is necessary for our legitimate interests or those of a 3rd party except where the interests, rights, and freedoms of you override those interests;

  • Where we need to comply with a legal or regulatory obligation.

  • Please see Your Rights with regard to your management of all personal data collected.

What Personal Data Do We Collect
  • Personal data is any information relating to an identifiable person who can be directly or indirectly identified by that data. It does not include anonymised data.

  • The personal data categories we may process are as follows:

    1. Identity - this may include your first name, last name, username, title, date of birth and gender.

    2. Technical Data - this may include your login data, internet protocol addresses, browser type and version, browser plug-in types and versions, time zone setting and location, operating system and platform and other technology on the devices you use to access this site.

    3. Profile Data - this may include your username and password, preferences, feedback and survey responses.

    4. Usage Data - this may include information about how you use our application.

  • In failing to provide the personal data required to fulfil delivery of our products or services we may not be able to deliver in accordance with our contractual obligation.

Sensitive Data
  • We do not collect sensitive data about you. Sensitive data refers to race, ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We do not collect any information about criminal convictions and offences.

How Do We Collect Your Personal Data

We collect personal data through a variety of different methods, including:

  1. Direct engagement: We may receive your data when you fill out forms on our site, or through communicating with us by post, phone, email.

  2. Technology engagement: We may automatically collect personal data in the form of technical data about your equipment, browsing actions and usage patterns. We do not use cookies to collect this data.

We use your personal data in the following way:

  • Purpose/Activity: To register you as a new subscriber

    • Type of Data Used: ​

      • Identity

      • Contact​

    • Lawful basis for processing

      • Performance of a contract with you​

  • Purpose/Activity: To process and deliver your order including: Manage payments, fees and charges; Collect and recover money owed to us

    • Type of Data Used

      • Identity

      • Contact

      • Financial

      • Transaction

      • Marketing and Communications​

    • Lawful basis for processing

      • Performance of a contract with you

      • Necessary for our legitimate interests to recover debts owed to us

  • Purpose/Activity: To manage our relationship with you which will include: Notifying you about changes to our terms or privacy policy; Asking you to leave a review or take a survey

    • Type of Data Used

      • Identity

      • Contact

      • Profile

      • Marketing and Communications​

    • Lawful basis for processing

      • Performance of a contract with you

      • Necessary to comply with a legal obligation

      • Necessary for our legitimate interests to keep our records updated and to study how customers use our products/services​

  • Purpose/Activity: To administer and protect our business and our site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

    • Type of Data Used​​

      • Identity

      • Contact

      • Technical​

    • Lawful basis for processing

      • Necessary for our legitimate interests for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise

      • Necessary to comply with a legal obligation​

  • Purpose/Activity: To deliver relevant content and advertisements to you and measure and understand the effectiveness of our advertising

    • Type of Data Used

      • Identity

      • Contact

      • Profile

      • Usage

      • Marketing and Communications

      • Technical​​​

    • Lawful basis for processing

      • 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​

  • Purpose/Activity: To make suggestions and recommendations to you about goods or services that may be of interest to you

    • Type of Data Used

      • Identity

      • Contact

      • Technical

      • Usage

      • Profile​​​​

    • Lawful basis for processing

      • Necessary for our legitimate interests to develop our products/services and grow our business

Purpose Of Processing Your Personal Data
  • The personal data we collect will be processed only in line with that specified at the time of collection. Your personal data will not be processed in a manner that is incompatible with those purposes.

  • In the event that we need to process your personal data for purpose unrelated to the purpose for which we collected the data, we will provide you with the legal justification as to the processing required.

  • We may process your personal data without your knowledge or consent where this is required or permitted by law.

How Long We Hold Your Data For
  • We will retain your data for as long as is required to fulfil the legitimate purpose the data has been collected for.

  • 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 requirements.

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

  • In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Your Legal Rights

As an individual, you have the following legal rights with regards to the personal data collected about you:

  • The right to be informed: Individuals have the right to be informed about the collection and use of their personal data.

  • The right of access: Individuals have the right to access their personal data and supplementary information.

  • The right to rectification: individuals have the right to have inaccurate personal data rectified, or completed if it is incomplete.

  • The right to erasure: individuals have the right to have personal data erased.

  • The right to restrict processing: Individuals have the right to request the restriction or suppression of their personal data.

  • The right to portability: individuals have the right to obtain and reuse their personal data for their own purposes across different services

  • The right to to object: individuals have the right to object to the processing of their personal data

You can see more about your individual rights at https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/?q=retention

  • If you wish to exercise any of these rights, please email us at info@bettertrack.org

  • 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.

  • 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 28 days. Occasionally it may take us longer 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.

Transfer Of Your Personal Data
  • We may have to share your personal data with the parties set out below for the purposes set out in the table above:

  • Service providers who provide IT and system administration services. Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.

  • HM Revenue & Customs, regulators and other authorities based in the United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances.

  • Third parties to whom we sell, transfer, or merge parts of our business or our assets.

  • We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

International Transfer
  • Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.

  • 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 European Commission; or

  • Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or

  • Where we use providers based in the United States, we may transfer data to them if they are part of the EU-US Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.

  • If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.

Data Security
  • Your personal data is processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.

  • We restrict access to your data to those within BetterTrack, and to third parties, that have a legitimate business need to access.

  • Where 3rd parties have access to your personal data, we have in place data processor agreements that enforce the correct usage and protections of your data.

  • We have put in place procedures to deal with any suspected data breach and will notify you and any applicable regulator of a breach where we are legally required to do so in no more than 72 hours.