Privacy and cookies policy

  1. Introduction

1.1     We are committed to safeguarding the privacy of our website visitors; in this policy we explain how we will treat your personal information.

1.2     [We will ask you to consent to our use of cookies in accordance with the terms of this policy when you first visit our website. / By using our website and agreeing to this policy, you consent to our use of cookies in accordance with the terms of this policy.]

  1. Collecting personal information

2.1     We may collect, store and use the following kinds of personal information:

(a)      information about your computer and about your visits to and use of this website (including [your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths]);

(b)      information that you provide to us when registering with our website (including [your email address]);

(c)      information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (including [your name and email address]);

(d)      information that you supply to us through our enquiry form and information relating to the use of the form (including [your name, your email address, your telephone number, your postal address and the date and time of your enquiry]);

(e)      information that you provide to us when using the services on our website, or that is generated in the course of the use of those services (including [the timing, frequency and pattern of service use]);

(f)      information that you post to our website for publication on the internet (including [your user name and the content of your posts]);

(g)      information contained in or relating to any communication that you send to us or send through our website (including [the communication content and metadata associated with the communication]);

(h)      any other personal information that you choose to send to us; and

2.2     Before you disclose to us the personal information of another person, you must obtain that person’s consent to both the disclosure and the processing of that personal information in accordance with this policy.

HOW WE USE YOUR INFORMATION TO SUPPORT OUR BUSINESS
We use the Information you share and we collect about you primarily for the legitimate interest of administering our business; (i) for registration and to manage your profiles and listings, including to facilitate your access to and use of our Sites; (ii) to enable us to publish your reviews and other submitted content; (iii) to respond to your questions and requests and otherwise customize your digital markets experience; (iv) to measure interest in and improve our products and services; (v) to notify you about special offers available from us, our Affiliates or Partners, which may be of interest to you; (vi) to resolve disputes and troubleshoot problems; (vii) to prevent prohibited or illegal activities and disclose to legal or government authorities upon lawful request; (viii) to enforce our policies; and as otherwise described to you at the point of collection.

  1. Using personal information

3.1     Personal information submitted to us through our website will be used for the purposes specified in this policy or on the relevant pages of the website.

3.2     We may use your personal information to:

(a)      administer our website and business;

(b)      personalise our website for you;

(c)      refer you to suppliers of goods or services in which you have expressed an interest;

(d)      enable suppliers of goods or services in which you have expressed an interest to contact you;

(e)      send you non-marketing commercial communications;

(f)      send you email notifications that you have specifically requested;

(g)      send you our email newsletter, if you have requested it (you can inform us at any time if you no longer require the newsletter);

(h)      send you marketing communications relating to our business [or the businesses of carefully-selected third parties] which we think may be of interest to you, by post or, where you have specifically agreed to this, by email or similar technology (you can inform us at any time if you no longer require marketing communications);

(i)       provide third parties with statistical information about our users (but those third parties will not be able to identify any individual user from that information);

(j)      deal with enquiries and complaints made by or about you relating to our website;

(k)      keep our website secure and prevent fraud;

(l)       verify compliance with the terms and conditions governing the use of our website [(including monitoring private messages sent through our website private messaging service)]; and

(m)     [other uses.]

3.3     If you submit personal information for publication on our website, we will publish and otherwise use that information in accordance with the licence you grant to us.

3.4     Your privacy settings can be used to limit the publication of your information on our website, and can be adjusted using privacy controls on the website.

WITH WHOM WE SHARE YOUR INFORMATION
We may, in administering our Sites and Services to provide you the best possible online experience, share your Information with our Affiliates and with the following entities:

Third-party vendors who help us administer our Sites and Services may access and collect Information only as needed to perform their functions and are not permitted to share or use the Information for any other purpose (e.g., marketing, customer service, business analytics, payment processing).
Software vendors. As part of our lead generation program, software buyers consent to allow us to share their Information with software vendors participating in the program who meet their business needs.
Social Media Services. If you opt to access social media websites and services through our Sites (such as LinkedIn, facebook), you are sharing your Information with those sites under their privacy policies.
Legal Process. We will share your Information in response to court orders and legal process; to defend against legal claims; or as otherwise required by law; when we believe it is necessary to investigate and prevent or protect and defend our rights, property, or safety as well as those of our customers; or in connection with a corporate transaction, such as a divestiture, investment, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.
We will notify you before we share your Information with third parties for reasons other than those listed above, and you will have an opportunity to opt out of such sharing. We also may share aggregate or anonymous information about you (which does not contain any personal information) to develop content and services and further improve your digital markets experience.

HOW YOU MAY ACCESS YOUR INFORMATION
We ensure that the Information we collect about you is accurate, complete and used for its intended purpose. You may access, review, correct and update your Information or close your account by sending an email to use per the notice section at the end of this Privacy Policy.

While we generally retain Information for so long as it may be relevant to the purpose for which it was collected or submitted, we also may retain certain Information associated with your account in our archives for analytical, archival and business continuity purposes.

To exercise these rights, please contact us via the contact information at end of this Privacy Notice.

YOUR CHOICES WITH RESPECT TO THE COLLECTION AND USE OF YOUR INFORMATION

You have choices with regard to how your Information is collected and used.

Informed Consent. We will always inform you at the point of collection as to how your Information will be used so that you can make an informed decision. You may choose not to provide us with any Information about yourself and your preferences, although it may be needed to customize and get the most value from your digital markets experience.
Unsubscribe. While data privacy laws permit us to send you communications related to administration of your services without including an unsubscribe option (e.g., service announcements and messages relating to your account), we will, where legally required, provide both registered and unregistered users with an option to unsubscribe from our non-administrative emails, such as our promotional and marketing communications,.
Access and Review. As described above, you may access, review, correct, update and delete the Information we hold about you as described above.
Set Preferences. Also as described above, you may set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of the Sites may be inaccessible or not function properly.

HOW WE SAFEGUARD YOUR INFORMATION

We are committed to safeguarding the Information you share with us. While we, like any website provider, cannot guarantee your security on the internet, we have, in accordance with applicable law, implemented appropriate administrative, technical and physical security controls to help prevent unauthorized access, maintain data security and ensure proper and effective use of the data we collect.

In addition, only authorized employees are permitted to access Information, and only for permitted business functions. And we use encryption when transmitting your Information between your system and ours, and we, together with our Partners and third party providers, employ firewalls and intrusion detection systems to help prevent unauthorized persons from gaining access to your Information.

In the end, you are responsible for activity on our Sites conducted with your credentials and for maintaining the secrecy of credentials that may be used to access your Account or Service; and you must immediately report to us, per the contact information at the end of this Policy, any suspected unauthorized activity.

  1. Disclosing personal information

4.1     We may disclose your personal information to [any of our employees, officers, insurers, professional advisers, agents, suppliers or subcontractors] insofar as reasonably necessary for the purposes set out in this policy.

4.2     We may disclose your personal information to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes set out in this policy.

4.3     We may disclose your personal information:

(a)      to the extent that we are required to do so by law;

(b)      in connection with any ongoing or prospective legal proceedings;

(c)      in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk);

(d)      [to the purchaser (or prospective purchaser) of any business or asset that we are (or are contemplating) selling; and]

(e)      [to any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.]

4.4     Except as provided in this policy, we will not provide your personal information to third parties.

  1. International data transfers

5.1     Information that we collect may be stored and processed in and transferred between any of the countries in which we operate in order to enable us to use the information in accordance with this policy.

5.2     Information that we collect may be transferred to the following countries which do not have data protection laws equivalent to those in force in the European Economic Area: [the United States of America, Russia, Japan, China and India].

5.3     Personal information that you publish on our website or submit for publication on our website may be available, via the internet, around the world. We cannot prevent the use or misuse of such information by others.

5.4     You expressly agree to the transfers of personal information described in this Section 5.

  1. Retaining personal information

6.1     This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal information.

6.2     Personal information that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

6.4     Notwithstanding the other provisions of this Section 6, we will retain documents (including electronic documents) containing personal data:

(a)      to the extent that we are required to do so by law;

(b)      if we believe that the documents may be relevant to any ongoing or prospective legal proceedings; and

(c)      in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).

  1. Security of personal information

7.1     We will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information.

7.2     We will store all the personal information you provide on our secure (password- and firewall-protected) servers.

7.3     You acknowledge that the transmission of information over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.

7.4     You are responsible for keeping the password you use for accessing our website confidential; we will not ask you for your password (except when you log in to our website).

7.5     Where we transfer to another business the information that you supply to us through our enquiry forms, we will do so securely. We keep such transfers secure by [encrypting transferred data].

  1. Amendments

8.1     We may update this policy from time to time by publishing a new version on our website.

8.2     You should check this page occasionally to ensure you are happy with any changes to this policy.

8.3     We may notify you of changes to this policy [by email or through the private messaging system on our website].

  1. Your rights

9.1     You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to:

(a)      the payment of a fee (currently fixed at GBP 10); and

(b)      the supply of appropriate evidence of your identity [(for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address)].

9.2     We may withhold personal information that you request to the extent permitted by law.

9.3     You may instruct us at any time not to process your personal information for marketing purposes.

9.4     In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.

  1. Third party websites

10.1    Our website includes hyperlinks to, and details of, third party websites.

10.2    We have no control over, and are not responsible for, the privacy policies and practices of third parties.

  1. Updating information

11.1    Please let us know if the personal information that we hold about you needs to be corrected or updated.

  1. About cookies

12.1    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.

12.2    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.

12.3    Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

12.4    Cookies can be used by web servers to identify and track users as they navigate different pages on a website and identify users returning to a website.

  1. Our cookies

13.1    We use [only session cookies / only persistent cookies / both session and persistent cookies] on our website.

13.2    The names of the cookies that we use on our website, and the purposes for which they are used, are set out below:

(a)      we use [cookie name] on our website to [recognise a computer when a user visits the website / track users as they navigate the website / enable the use of a shopping cart on the website / improve the website’s usability / analyse the use of the website / administer the website / prevent fraud and improve the security of the website / personalise the website for each user / target advertisements which may be of particular interest to specific users / [describe purpose(s)]];

(b)      [repeat as necessary.]

  1. Analytics cookies

14.1    We use [Google Analytics] to analyse the use of our website.

14.2    Our analytics service provider generates statistical and other information about website use by means of cookies.

14.3    The analytics cookies used by our website have the following names: [_ga, _gat, __utma, __utmt, __utmb, __utmc, __utmz and __utmv].

14.4    The information generated relating to our website is used to create reports about the use of our website.

14.5    Our analytics service provider’s privacy policy is available at: [http://www.google.com/policies/privacy/].

  1. Third party cookies

15.1    Our website also uses third party cookies.

15.2    15.3    Details of [other] third party cookies used by our website are set out below:

(a)      [third party cookie details;]

(b)      [repeat as necessary.]

  1. Blocking cookies

16.1    Most browsers allow you to refuse to accept cookies; for example:

(a)      in Internet Explorer (version 11) you can block cookies using the cookie handling override settings available by clicking “Tools”, “Internet Options”, “Privacy” and then “Advanced”;

(b)      in Firefox (version 39) you can block all cookies by clicking “Tools”, “Options”, “Privacy”, selecting “Use custom settings for history” from the drop-down menu, and unticking “Accept cookies from sites”; and

(c)      in Chrome (version 44), you can block all cookies by accessing the “Customise and control” menu, and clicking “Settings”, “Show advanced settings” and “Content settings”, and then selecting “Block sites from setting any data” under the “Cookies” heading.

16.2    Blocking all cookies will have a negative impact upon the usability of many websites.

16.3    If you block cookies, you will not be able to use all the features on our website.

  1. Deleting cookies

17.1    You can delete cookies already stored on your computer; for example:

(a)      in Internet Explorer (version 11), you must manually delete cookie files (you can find instructions for doing so at http://windows.microsoft.com/en-gb/internet-explorer/delete-manage-cookies#ie=ie-11);

(b)      in Firefox (version 39), you can delete cookies by clicking “Tools”, “Options” and “Privacy”, then selecting “Use custom settings for history” from the drop-down menu, clicking “Show Cookies”, and then clicking “Remove All Cookies”; and

(c)      in Chrome (version 44), you can delete all cookies by accessing the “Customise and control” menu, and clicking “Settings”, “Show advanced settings” and “Clear browsing data”, and then selecting “Cookies and other site and plug-in data” before clicking “Clear browsing data”.

17.2    Deleting cookies will have a negative impact on the usability of many websites.

  1. Cookie preferences

18.1    You can manage your preferences relating to the use of cookies on our website by visiting: www.softwhere.co

  1. Our details

20.1    This website is owned and operated by S2R Services.

20.2    We are registered in [England and Wales] under registration number [number], and our registered office is at 3 Down Lane, Bathampton, Bath, BA2 6UE.

20.3    Our principal place of business is at 3 Down Lane, Bathampton, Bath, BA2 6UE.

20.4    You can contact us by writing to the business address given above, by using our website contact form, by email to [email protected] or by telephone on +44 01225 462486.