We ask that you read this privacy notice carefully as it contains important information on who we are, how and why we collect, store, use and share personal information, your rights in relation to your personal information and on how to contact us and supervisory authorities in the event you have a complaint.
This notice was last updated on Tuesday April 6th, 2021 and complies to the UK GDPR, underpinned by the UK law the Data Protection Act (2018), and regulated by the UK ICO (Information Commissioners Office).
Scope & Responsibilities
Our scope is all data subjects, whose personal data is collected, in line with the requirements of the UK GDPR.
The Data Protection Officer (DPO) is responsible for ensuring that this notice is made available to data subjects prior to Soto Digital Limited collecting/processing their personal data.
All employees of Soto Digital Limited who interact with data subjects are responsible for ensuring that this privacy notice is drawn to the data subject’s attention and their consent to the processing of their personal data is secured.
Who we are?
Soto Digital Limited design and provide bespoke website development services. Established in 2009, our team has flourished and grown into the perfect blend of inspirational creative, experienced development and results-driven online marketing. Much of our work lies with building or maintaining WordPress websites, but for most of our clients we are more than just a service provider; we become part of your team, building long lasting, collaborative relationships.
Soto Digital Limited collects and processes certain personal information about you.
When we do so we are regulated under the UK General Data Protection Regulation, which is underpinned by the Data Protection Act (2018)
We are responsible as the ‘data controller’ & ‘data processor’ for all personal information collected for the purposes of those laws. The Data Protection Officer (DPO) is Zoey O’Neill, Soto Digital Limited, Unit 19, Equinox South, Great Park Road, Bradley Stoke, Bristol, England, BS32 4QL.
Soto Digital Limited can be contacted via email email@example.com or by phone on 0117 230 3322.
The personal information we collect and use.
Lawful bases for processing of personal data:
The lawful bases for processing are set out in Article 6 of the UK GDPR. At least one of these must apply whenever Soto Digital Limited processes your personal data:
- Contract – the processing is necessary for Soto Digital Limited to fulfil the obligations of an agreement or contract for the provision of website development services. Both parties would be provided with a signed copy of the contract and a copy of this privacy notice.
- Consent – the individual has given clear consent for Soto Digital Limited to process their personal data for a specific purpose. The individual has the right to object and the right to withdraw consent.
You can find more about the UK GDPR lawful bases here or by visiting www.ico.org.uk
How we use your personal information
Soto Digital Limited uses your personal information:
- To pre-qualify which of our services are suitable for your requirements (e.g., providing estimates)
- To provide and maintain our services (e.g., provision of contracts, engagement letters, emails, calls)
- To notify you about changes to our services (e.g., direct communications through secure & trusted Soto Digital Limited communication channels)
- To allow you to participate in any interactive features of our services when you choose to do so (e.g., video calls & meetings, feedback surveys)
- To provide customer care and support (e.g., after sales support and contract renewal)
- To detect, prevent and address technical issues (e.g., web hosting, website back office)
- To monitor the analysis/usage of the services (e.g., non-personal data via Google Analytics in relation to the Soto Digital Limited website)
- To produce invoices & documentation for our services (e.g., invoices, direct debit mandates)
- To provide compliance with all legal requirements of England & Wales (e.g., UK data protection laws)
Information collected by us.
While providing our services Soto Digital Limited collects the following personal information when you provide it to us:
- Names and, contact details (e.g., contact names, email addresses, contact numbers)
- Financial details (e.g., bank account names, sort codes & account numbers for processing of invoices, customer payments, etc.)
- Addresses (e.g., business addresses & other nominated addresses)
Who we share your personal information with?
Soto Digital Limited may exchange personal data, as highlighted in the ‘information collected by us’ section of this privacy notice, with our clients (data subjects) in certain EU countries. This data transfer between the UK and EEA is covered by UK GDPR under the current UK adequacy regulations. We may also exchange personal data with data subjects in non-EU countries and this would be a restricted transfer under UK GDPR using the appropriate safeguard known as ‘standard contractual clauses’ (e.g., risk assessments).
We would always inform you ahead of acting on any instructions to proceed with any of our services, if there is a requirement for your personal data be transferred outside of the UK. Further details on international data transfers can be found here.
This data sharing enables Soto Digital Limited to supply the above documented services to you in a professional and timely manner, whilst undertaking quality control & regulatory compliance procedures. Furthermore, it ensures compliance with all necessary UK GDPR & Data Protection Act (2018) lawful requirements.
Soto Digital Limited will share personal information with law enforcement or other authorities if required by applicable law. We will not share your personal information with any other third party.
Whether information must be provided by you, and if so why?
The provision of certain personal data including (but not limited to) contact name, registered address, email address, telephone number & certain financial information is required from you. This enables Soto Digital Limited to provide our website development services to you.
We will inform you at the point of collecting information from you, whether you are required to provide this and any other additional information to us.
How long your personal information will be kept?
- We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any contractual, legal, or reporting requirements.
- 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.
- We will hold your personal data, including but not limited to, name, address, and contact details for the duration of your contracted agreement with Soto Digital Limited plus 12 months after any contract end date, to facilitate aftersales support.
- Details of retention periods for different aspects of your personal data are available in our Document Destruction & Retention Policy which you can request from us by contacting us.
- Any personal data held in hard document copy or on any end-of-life software/hardware (e.g., hard drives, discs, CD’s) are securely stored pre-destruction after use and are destroyed with a Certificate of Destruction in line with our UK GDPR Document Destruction & Retention
Reasons we can collect and use your personal information.
Soto Digital Limited collects your personal data to enable us to provide our website development services to you.
Soto Digital Limited may also contact you by email, phone, video call or letter in line with the service you have paid for. We may occasionally email you or send a letter about something relevant to the service you have paid for.
Furthermore, we may email you to inform of company updates and items of interest via our official channels.
Under the UK GDPR, Data Protection Act (2018) and ICO guidance you have several important rights free of charge. At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:
- Right of access – you have the right to request a copy of the information that we hold about you.
- Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
- Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
- Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
- Right of portability – you have the right to have the data we hold about you transferred to another organisation.
- Right to object – you have the right to object to certain types of processing such as direct marketing.
- Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the Information Commissioner’s Office (ICO) on individuals rights under the UK General Data Protection Regulation.
If you would like to exercise any of those rights, please:
- Call, email, or write to us in the first instance.
- Let us have enough information to identify you,
- Let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill), and
- Let us know the information to which your request relates?
Keeping your personal information secure
We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator (e.g., ICO) of a suspected data security breach where we are legally required to do so.
If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses, and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
Soto Digital Limited only use non-personal data essential cookies on this website to track the performance of the website via Google Analytics. This non personal data helps us to understand how to improve the website content for the benefit of all users. If you want to block cookies, then you can do this through your browser via the help function. You can also visit www.aboutcookies.org for further guidance.
How to complain
We hope that we can resolve any query or concern you raise about our use of your personal data.
The UK General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority. The supervisory authority in the UK is the Information Commissioners Office (ICO) who may be contacted here or by telephone on 0303 123 1113.
Changes to this privacy notice
This privacy notice was last reviewed and published on Tuesday April 6th, 2021.
Soto Digital Limited is a UK based company, registered in England & Wales, under company registration number 07961116.
We may change this privacy notice from time to time, when we do, we will inform you via email and/or our company website.
How to contact us
Please contact us if you have any questions about this privacy notice or the information, we hold about you.
The Data Protection Officer (DPO) is Zoey O’Neill.
If you wish to contact us, please send an email to firstname.lastname@example.org or write to Soto Digital Limited, Unit 19, Equinox South, Great Park Road, Bradley Stoke, Bristol, England, BS32 4QL or call 0117 230 3322.