United Kingdom Privacy

Last Revised: May 23, 2018

Practice Ignition Limited (“Company”) is committed to protecting your privacy. We have prepared this Privacy Policy to describe to you our practices regarding the personal information we collect from users of our website located at www.practiceignition.com (the “Platform”) and services (the “Services”) and to tell you about your privacy rights and how the law protects you.

This Policy, together with our Terms of Use (https://www.practiceignition.com/gb/terms) (and any other document referred to in it) governs the way in which any personal data you provide us, or we collect from you will be processed. Please read this Policy carefully as by visiting the Platform or using the Services you are agreeing and consenting to the practices described herein.

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

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

For the purposes of data protection laws the data controller, who is responsible for your personal data, is Practice Ignition Limited of Hikenield House Icknield Way, East Anton Court, Andover, Hampshire, SP10 5RG.

1. Questions; Contacting Company; Reporting Violations. If you have any questions or concerns or complaints about our Privacy Policy or our data collection or processing practices, or if you want to report any security violations to us, please contact us at the following address:

   Practice Ignition Limited
   20-22 Wenlock Road
   London
   N1 7GU

   We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below:

   Dane Thomas
   Co-founder & Head of Product
   [email protected]
   Level 7, 54-66 Wentworth Ave, Surry Hills, NSW, 2010, Australia

   For the avoidance of doubt, you have the right to make a complaint to the Information Commissioner’s Office (ICO), who are responsible for regulating data protections issues. We would however appreciate the change to address any concerns you may have before you approach the ICO so we ask that you please contact us in the first instance.
   
   

2. A Note About Children. Our website is not intended for children and as such we do not intentionally gather personal information from visitors who are under the age of 13. If a child under 13 submits personal information to the Company and we learn that the personal information is the information of a child under 13, we will attempt to delete the information as soon as possible. If you believe that we might have any personal information from a child under 13, please contact us at: [email protected]
   
   
3. Types of Data We Collect. Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as set out below.
   1. Identity Data, which includes first name, maiden name, last name, username (or other identifier, marital status, title, date of birth and gender.
   2. Contact Data, which includes billing address, delivery address, email address and telephone numbers
   3. Transaction Data, which includes details about payments to and from you and other details of products and services you have purchased from us
   4. Technical Data, which includes IP address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website
   5. Profile Data, which includes your username, password, purchases or orders made by you, your interests, preferences, feedback and survey responses
   6. Usage Data, which includes information about how you use our website, products and services
   7. Marketing and Communications Data, which includes your preferences in receiving marketing from us and our third parties and your communication preferences

   We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

   We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

   Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
   
   

4. How Your Data is Collected
   1. Information You Provide to Us
      • We may collect personal information from you, such as your first and last name, email and mailing address, professional title, company name and password when you create an account to log in to our Company Properties (“Account”).
      • When you order Services, or make payments on our Platform, our third-party payment processor will collect all information necessary to complete the transaction, including your name, third party payment provider information (e.g. credit card information), and billing information. As of the date of this Privacy Policy listed above, we use Stripe as our third-party payment processor. We do not process, record or maintain your credit card or bank account information. For more information on how payments are handled, or to understand the data security and privacy afforded such information, please refer to Stripe’s privacy policy at: https://stripe.com/gb/terms.
      • We retain information on your behalf, such as files and messages that you store using your Account. However, you the Services are not intended as a storage service and you are solely responsible for the backup all of your files, messages and other content that you upload to the Services.
      • If you provide us feedback or contact us via e-mail, we will collect your name and e-mail address, as well as any other content included in the e-mail, in order to send you a reply.
      • We also collect other types of personal information that you provide to us voluntarily and other requested information if you contact us via e-mail regarding support for the Services.
      • We may also collect personal information, such as at other points in our Service that state that personal information is being collected.
      • You can check the information that we hold about you by e-mailing us at [email protected] or by writing to us at Practice Ignition, 37 Shepherd St, Chippendale, NSW 2008, Australia. An administration fee of £10 will be payable to Practice Ignition.
        
   2. Information Collected via Technology
      • Log Files. As is true of most websites, we gather certain information automatically and store it in log files. This information includes IP addresses, browser type, Internet service provider (“ISP”), referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information to analyse trends, administer the Platform, track users’ movements around the Platform, gather demographic information about our user base as a whole, and better tailor our Services to our users’ needs. Except as noted in this Privacy Policy, we do not link this automatically-collected data to personal information.
      • Cookies. Like many online services, we use cookies to collect information. “Cookies” are small pieces of information that a website sends to your computer’s hard drive while you are viewing the website. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Service. This type of information is collected to make the Service more useful to you and to tailor the experience with us to meet your special interests and needs. You can block certain types of the cookies we us by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.
      • Pixel Tags. In addition, we use “Pixel Tags” (also referred to as clear Gifs, Web beacons, or Web bugs). Pixel Tags are tiny graphic images with a unique identifier, similar in function to Cookies that are used to track online movements of Web users. In contrast to Cookies, which are stored on a user’s computer hard drive, Pixel Tags are embedded invisibly in Web pages. Pixel Tags also allow us to send e-mail messages in a format users can read, and they tell us whether e-mails have been opened to ensure that we are sending only messages that are of interest to our users. We may use this information to reduce or eliminate messages sent to a user. We do not tie the information gathered by Pixel Tags to our users’ personal information.
      • Traffic Analytics. We use a number of third party service provides, such as Google Analytics, to help analyse how users use the Service (“Analytics Companies”). These Analytics Companies use Cookies to collect information such as how often users visit the Service, what features they use on our Service, and what other sites they used prior to coming to the Platform. We use the information we get from these Analytics Companies only to improve our Platform and Services. These Analytics Companies collect only the IP address assigned to you on the date you visit the Service, rather than your name or other personally identifying information. We do not combine the information generated through the use of our Analytics Companies with your personal information. Although these Analytics Companies may plant a persistent Cookie on your web browser or mobile device to identify you as a unique user the next time you visit the Service, the Cookie cannot be used by anyone but the Analytics Company that placed the applicable Cookie. This Policy does not apply to and we are not responsible for the Cookies used by these Analytics Companies.
        
        
5. Use of Your Personal information.

   We will only use your personal data when the law allows us to, and most commonly to enable us to perform the Services for you.

   Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us on the details above. We have set out below a description of all the ways we plan to use your personal data, and which of the legal bases we rely upon to do so.

   Purpose/Activity	Type of Data	Basis for processing
   To register you as a new customer	(a) Identity (b) Contact	Performance of a contract with you
   To process and deliver the Services	(a) Identity (b) Contact (c) Transaction (d) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us)
   To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
   To enable you to partake in a prize draw, competition or complete a survey	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
   To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	(a) 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) (b) Necessary to comply with a legal obligation
   To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical	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)
   To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	(a) Technical (b) Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
   To make suggestions and recommendations to you about goods or services that may be of interest to you	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile	Necessary for our legitimate interests (to develop our products/services and grow our business)

   We may create anonymous data records from personal information by excluding information (such as your name) that makes the data personally identifiable to you. We use this anonymous data to analyse request and usage patterns so that we may enhance the content of our Services and improve Platform navigation. We reserve the right to use anonymous data for any purpose and disclose anonymous data to third parties in our sole discretion.
   
   

6. Disclosure of Your Personal Information. We disclose your personal information for the purposes set out above to the following.
   1. Third Parties Designated by You. When you use the Services, the personal information you provide will be shared with the third parties that you designate to receive such information. For the avoidance of doubt we will get your express opt-in consent before we share your personal data with any third-party company for marketing purposes.
   2. Third Party Service Providers. We may share your personal information with External Third Party (as described in the Glossary below) service providers to: provide you with the Services that we offer you through our Platform; to conduct quality assurance testing; to facilitate creation of accounts; to provide technical support; and/or to provide other services to the Company. These third party service providers are required not to use your personal information other than to provide the services requested by Company.
   3. Corporate Restructuring. We may share some or all of your personal information in connection with or during negotiation of any merger, financing, acquisition or dissolution, transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets. In the event of an insolvency, bankruptcy, or receivership, personal information may also be transferred as a business asset. If another company acquires our company, business, or assets, that company will possess the personal information collected by us and will assume the rights and obligations regarding your personal information as described in this Privacy Policy.
   4. Other Disclosures. Regardless of any choices you make regarding your personal information (as described below), Company may disclose personal information if it believes in good faith that such disclosure is necessary (i) in connection with any legal investigation; (ii) to comply with relevant laws or to respond to subpoenas or warrants served on Company; (iii) to protect or defend the rights or property of Company or users of the Platform or Services; and/or (iv) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or our Terms of Use.
      
7. Your Choices Regarding Your Information. You have several choices regarding use of information on our Services:
   1. Email Communications. We will periodically send you free newsletters and e-mails that directly promote the use of our Platform, or Services. When you receive newsletters or promotional communications from us, you may indicate a preference to stop receiving further communications from us and you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the e-mail you receive or by contacting us directly (please see contact information below). Despite your indicated e-mail preferences, we may send you service related communications, including notices of any updates to our Terms of Use or Privacy Policy.
   2. Changing or Deleting Your Personal Information. You may change any of your personal information in your Account by clicking the “Delete account” text within the “Company” page of your Account or by visiting https://ignite.practiceignitio... and following the directions therein. You may request deletion of your personal information by us, and we will use commercially reasonable efforts to honor your request, but please note that we may be required to keep such information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements). When we delete any information, it will be deleted from the active database, but may remain in our archives. We may also retain your information for fraud prevention or similar purposes.
      
8. Security of Your Personal Information. Company is committed to protecting the security of your personal information. We use a variety of industry-standard security technologies and procedures to help protect your personal information from unauthorised access, use, or disclosure. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while Company uses reasonable efforts to protect your personal information, Company cannot guarantee its absolute security. We will notify any applicable regulator of any breach where we are legally required to do so.
   
   
9. Storing Your Personal Information.

   The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

   Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

   • 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. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
   • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
   • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

   
   Please contact us if you require further information on the specific mechanism used by us when transferring your personal data out of the EEA.

   Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

   Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
   
   

10. Data retention. How long will you use my personal data for?

    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 legal, accounting, 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.

    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, you can ask us to delete your data: see below for further information.
    
    

11. Changes to This Privacy Policy. This Privacy Policy is subject to occasional revision, and if we make any material changes in the way we use your personal information, we will notify you by sending you an e-mail to the last e-mail address you provided to us and/or by prominently posting notice of the changes on our Platform. Any changes to this Privacy Policy will be effective upon the earlier of thirty (30) calendar days following our dispatch of an e-mail notice to you or thirty (30) calendar days following our posting of notice of the changes on our Platform. These changes will be effective immediately for new users of our Service. Please note that at all times you are responsible for updating your personal information to provide us with your most current e-mail address. In the event that the last e-mail address that you have provided us is not valid, or for any reason is not capable of delivering to you the notice described above, our dispatch of the e-mail containing such notice will nonetheless constitute effective notice of the changes described in the notice. If you do not wish to permit changes in our use of your personal information, you must notify us prior to the effective date of the changes that you wish to deactivate your Account with us. Continued use of our Platform or Service, following notice of such changes shall indicate your acknowledgement of such changes and agreement to be bound by the terms and conditions of such changes.

Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our 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

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

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 override 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 at any time where we are relying on consent to process your personal data. 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 you withdraw your consent.