Sense Network Limited is a company registered in England and Wales (collectively referred to as “Sense”, “we” or “us” in this policy).

Overview

This policy applies when you visit and interact with our website at https://www.sense-network.co.uk and/or sign up to receive our publications that we distribute to our viewership. It contains information about:

  • How we use your data;
  • What personal data we collect;
  • How we ensure your privacy is maintained; and
  • Your legal rights relating to your personal data.

Introduction

This privacy policy will inform you as to how we look after your personal data when you visit http://www.sense-network.co.uk (regardless of where you visit it from) as well as when you instruct us as a content distributor (as the distributer of our two publications) and tells you about your privacy rights and how the law protects you.

  1. Important information and who we are
Purpose of this privacy notice


It is important that you read this privacy policy together with any other privacy notice or fair processing notice that we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements the other notices and is not intended to override them.

Controller

Sense Network Limited is the controller and responsible for your personal data (collectively referred to as Sense “we”, “us” or “our” in this privacy policy).

Contact details

If you have any questions about this privacy policy, please contact us using the details below.

Sense Network Limited
Brookdale Centre,
Manchester Road,
Knutsford,
WA16 0SR
Email address: compliance@sense-network.co.uk
Telephone number: 01565 658 840

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance via the contact details provided.

Changes to the privacy notice and your duty to inform us of changes

This version was last updated on 20/05/2020

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

  1. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. We may collect, use, store and transfer the following kinds of personal data about you:

  • Identity Data: Includes first name, last name.
  • Contact Data: Includes email address.
  • Marketing and Communications Data: Includes your preferences in receiving marketing from us and our third parties and your communication preferences. In this case, your Marketing and Communications Data preferences solely relates to receiving our two communications.
  1. How is your personal data collected?

We use different methods to collect data from and about you including:

  • Direct interactions. You may give us your Identity and Contact Data by signing up to our newsletter or by corresponding with us by post, phone, email or otherwise.
  • Automated technologies or interactions. As you interact with the Sense Website, we collect Technical Data in the form of anonymous cookies solely. We reserve the right to use cookies as an anonymous method of recording your usage of our site and would ask that if you do not wish to have cookies recorded on your machine, you amend the settings on your browser to prevent them from being created. To read our Cookie Policy click here, or for more information on cookies click here.
  1. How we use your personal data

We will only use your personal data to distribute publications of which you have opted in to. We do not collect any identifying data beyond which you have submitted through direct interactions.

You have the right to withdraw consent to marketing at any time by contacting us or by unsubscribing via the “unsubscribe” link which can be found at the bottom of every email we send.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity

Type of data

Lawful basis for processing

Bi-Weekly Newsletter

Contact data

You have opted in to receive this type of communication

Compliance Updates

Contact data

Members will be opted in to receive this type of communication by default

Webinar Reminders

Contact data

Members will be opted in to receive this type of communication by default. Non-members have chosen to opt in to receive this type of communication

Sense Communications

Contact data

Members will be opted in to receive this type of communication by default. Non-members have chosen to opt in to receive this type of communication

Feedback

Contact data

We may send you feedback surveys to improve the quality of our newsletters

Cookies

Technical data

We rely on cookies to provide a better user experience when accessing https://www.sense-network.co.uk. We also use cookies to gauge activity anonymously on the website (e.g what type of device, what pages have been accessed). This is expressed in the form of overall figures (rather than identifiable data) through Google Analytics.


Distributing the Bi-Weekly Newsletter, Communications, Reminders and Compliance
Updates

Twice a month we distribute a newsletter which you will have opted into through direct interactions.

Your personal information will never be sold/given to the third parties producing content for these articles.

We may also send feedback surveys to help improve the quality of our content.

Promotional offers from us

We will never use your Identity, Contact, Technical, Usage and Profile Data to advertise products or services and offers.

Third-party marketing

We will never share your personal data with third parties.

Opting out

You can ask us to stop sending you messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our website Cookie Policy here.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Disclosure of your personal data

We will never disclose your identifiable data to third parties involved in the creation of content for our publications.

Data security

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.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

  1. Data retention

How long will you use my personal data for?

We will retain your personal data for the purposes described in the table in section 4, unless you directly contact Sense to ask for your data to be removed.

All of our data is held within our preferred Customer Relationship Management Tool, HubSpot.

Hubspot’s product infrastructure is hosted on Amazon Web Services (AWS) in the United States East region. HubSpot leverages the Google Cloud Platform (GCP) in the EU (Frankfurt, Germany region) to support the processing of local customer data that is critical to our customers' businesses. This includes leads, email events, and analytics. By hosting these services in both AWS in the US and GCP in Germany, HubSpot has increased the performance and reliability of those services by locating them closer to end users in the EU. 

Customer data is processed and secured in the EU before being transmitted and stored in the US. The cloud infrastructure hosted on GCP provides additional redundancy for all HubSpot customers for critical components of our system. A number of HubSpot services are routed through the GCP EU data center before being securely transferred to the US and securely stored in AWS. 

There is no obligation under the GDPR for data to be stored in the EU and the rules regarding transfer of personal data outside the EU remain largely unchanged. The GDPR permits transfers of personal data outside of the EU subject to certain conditions.

The EU-U.S. Privacy Shield continues to be one valid way to ensure adequate safeguards are in place for personal data transfer from the EU to the U.S. The EU model clauses also remain a valid mechanism to lawfully transfer personal data.   

HubSpot offers a Data Processing Agreement that incorporates the model clauses to our EU/EEA customers. We are also Privacy Shield certified.

  1. Access to your data

No fee usually required

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.

What we may need from you

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.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month 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.

7.  Your legal rights

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data. Where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which overrides your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time.