PRIVACY POLICY
Effective date 25th May 2018
This Privacy Policy sets out how we, Sketchanet Limited, collect, store and use information about you when you use or interact with our website, https://www.sketchanet.com and our sub domains thereof, and where we otherwise obtain or collect information about you.
Contents
You can use the quick links below to jump to a specific section of this privacy policy
Information we collect when you visit our website
Information we collect when you contact us
Information we collect when you interact with our website
Information we collect when you sign up for our services
How we collect or obtain information about you from third parties
Our use of automated decision-making and profiling
Disclosure and additional uses of your information
How long we retain your information
How we secure your information
Transfers of your information outside the European Economic Area
Your rights in relation to your information
Your right to object to the processing of your information for certain purposes
Sensitive Personal Information
California Do Not Track Disclosures
Summary
This section summarises how we obtain, store and use information about you. It is intended to provide a very general overview only. It is not complete in and of itself and it must be read in conjunction with the corresponding full sections of this Privacy Policy.
Data controller: Sketchanet Limited
How we collect or obtain information about you:
- when you provide it to us (e.g. by contacting us, or if you sign up to our services or mailing list)
- from your use of our website, using cookies and similar technologies, and
- from third parties, for example if an existing user adds you as a user of their Sketchanet account. We may also collect publicly available information about you so that we can provide our design services.
Information we collect if you visit our website:
information from cookies, information about your computer or device (e.g. device and browser type), information about how you use our website (e.g. which pages you have viewed, the time when you view them and what you clicked on, the geographical location from which you accessed our website (based on your IP address).
Information we collect if you sign up for a Sketchanet account or join our mailing list:
in addition to the above we will also collect your name, contact details, IP address, and your company name or business name (if applicable).
How we use your information:
for administrative and business purposes (particularly to contact you and process orders you place on our website), to improve our business and website, to fulfil our contractual obligations, to advertise our goods and services, to analyse your use of our website, and in connection with our legal rights and obligations
Disclosure of your information to third parties:
only to the extent necessary to run our business, to our service providers, to fulfil any contracts we enter into with you, or where required by law or to enforce our legal rights.
Do we sell your information to third parties (other than in the course of a business sale or purchase or similar event): No
How long we retain your information:
for no longer than necessary, taking into account any legal obligations we have (e.g. to maintain records for tax purposes), any other legal basis we have for using your information (e.g. your consent, performance of a contract with you or our legitimate interests as a business) and certain additional factors described in the main section below entitled How long we retain your information. For specific retention periods in relation to certain information which we collect from you, please see the main section below entitled How long we retain your information.
How we secure your information:
using appropriate technical and organisational measures such as storing your information on secure servers, encrypting transfers of data to or from our servers using Secure Sockets Layer (SSL) technology, encrypting payments you make on or via our website using Secure Sockets Layer (SSL) technology, only granting access to your information where necessary.
Use of cookies and similar technologies:
we use cookies and similar information-gathering technologies such as web beacons on our website including essential, functional, analytical and targeting cookies. For more information, please visit our cookies policy here: https://www.sketchanet.com/cookies-policy
Transfers of your information outside the European Economic Area:
in certain circumstances we transfer your information outside of the European Economic Area, specifically to the United States so we can make use of various technical services based there, which are listed below. It is our policy to ensure that any such services have self-certified themselves as compliant with the EU-U.S. Privacy Shield. At present we make use of the following services based in the United States: Fogbugz (view their policy at https://www.fogcreek.com/privacy), Nimble (view their policy at https://www.nimble.com/company/privacy), Drip (view their policy at https://www.drip.com/privacy), Asana (view their policy at https://asana.com/terms#privacy-policy), and DropBox (view their policy at https://www.dropbox.com/en_GB/privacy).
Use of automated decision making and profiling:
we use automated decision making. If you sign up for a Sketchanet account or join our mailing list and consent to us doing so, we use algorithms to automatically send you emails based on your actions such as the links you click or the pages you view on our website. These emails are targeted to help you learn how to use the Sketchanet platform and to bring specific features to your attention that we think you will find useful. We may also use web beacons or targeting cookies to display advertisements to people who visit our website on other websites around the internet (e.g. using the Google AdSense network, or Facebook Ads).
Your rights in relation to your information:
- to access your information and to receive information about its use
- to have your information corrected and/or completed
- to have your information deleted
- to restrict the use of your information
- to receive your information in a portable format
- to object to the use of your information
- to withdraw your consent to the use of your information
- not to have significant decisions made about you based solely on automated processing of your information, including profiling
- to complain to a supervisory authority
Sensitive personal information:
we do not knowingly or intentionally collect what is commonly referred to as ‘sensitive personal information’. Please do not submit sensitive personal information about you to us. For more information, please see the main section below entitled Sensitive Personal Information.
Our details
The data controller in respect of our website is Sketchanet Limited (company registration number: 7734483) of 78 York Street, London, W1H 1DP.
You can contact the data controller by writing to us at the aforementioned address or sending an email to support@sketchanet.com.
If you have any questions about this Privacy Policy, please contact the data controller.
Information we collect when you visit our website
We collect and use information from website visitors in accordance with this section and the section entitled Disclosure and additional uses of your information.
Web server log information
We use Amazon Web Services to host the Sketchanet platform and all of our websites, the privacy policy of which is available here: https://aws.amazon.com/privacy. Our website servers automatically log the IP address you use to access our website as well as other information about your visit such as the pages accessed, the date and time of the request, the source of your access to our website (e.g. the website or URL (link) which referred you to our website), and your browser version and operating system.
Our servers are located in Ireland.
Use of website server log information for IT security purposes
We and Amazon Web Services collect and store server logs to ensure network and IT security and so that the server and website remain uncompromised. This includes analysing log files to help identify and prevent unauthorised access to our network, the distribution of malicious code, denial of services attacks and other cyber attacks, by detecting unusual or suspicious activity.
Unless we are investigating suspicious or potential criminal activity, we do not make, nor do we allow our hosting provider to make, any attempt to identify you from the information collected via server logs.
Legal basis for processing: compliance with a legal obligation to which we are subject (Article 6(1)(c) of the General Data Protection Regulation).
Legal obligation: recording access to our website using server log files is an appropriate technical measure to ensure a level of security appropriate to protect information collect by our website under Article 32(1) of the General Data Protection Regulation.
Use of website server log information to analyse website use and improve our website
We use the information collected by our website server logs to analyse how our website users interact with our website and its features. For example, we analyse the number of visits and unique visitors we receive, the time and date of the visit, the location of the visit and the operating system and browser used.
We use the information gathered from the analysis of this information to improve our website. For example, we use the information gathered to change the information, content and structure of our website and individual pages based according to what users are engaging most with and the duration of time spent on particular pages on our website.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: improving our website for our website users and getting to know our website users’ preferences so our website can better meet their needs and desires.
Cookies and similar technologies
Cookies are data files which are sent from a website to a browser to record information about users for various purposes.
We use cookies and similar technologies on our website, including essential, functional, analytical and targeting cookies and web beacons. For further information on how we use cookies, please see our cookies policy which is available here: https://www.sketchanet.com/cookies-policy
You can reject some or all of the cookies we use on or via our website by changing your browser settings or non-essential cookies by using our cookie control tool, but doing so can impair your ability to use our website or some or all of its features. For further information about cookies, including how to change your browser settings, please visit http://www.allaboutcookies.org/ or see our cookies policy.
Information we collect when you contact us
We collect and use information from individuals who contact us in accordance with this section and the section entitled Disclosure and additional uses of your information.
When you send an email to the email address displayed on our website we collect your email address and any other information you provide in that email (such as your name, telephone number and the information contained in any signature block in your email).
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.
Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).
Transfer and storage of your information
We use a third party email provider to store emails you send us. Our third party email provider is Amazon Web Services based in Ireland. Their privacy policy is available here: https://aws.amazon.com/privacy
Emails you send us will be stored within the European Economic Area on our third party email provider’s servers in Ireland.
Contact form
When you contact us using our contact form, we collect any information that you explicitly provide when filling out the form. If you do not provide the mandatory information required by our contact form, you will not be able to submit the contact form and we will not receive your enquiry.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.
AND
Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).
Transfer and storage of your information
Messages you send us via our contact form will be stored within the European Economic Area on our third party email provider’s servers in Ireland. Our third party email provider is Amazon Web Services based in Ireland. Their privacy policy is available here: https://aws.amazon.com/privacy
We may occasionally use a third party contact form provider to store messages you send us. Our third party contact form provider is Drip, located in the United States and their privacy policy is available here: https://www.drip.com/privacy.
Messages you send to us via our third party contact form will be stored outside the European Economic Area on our contact form provider’s servers in the United States.
For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.
Phone
When you contact us by phone, we collect your phone number and any information provide to us during your conversation with us.
We do not record phone calls.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation)
Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.
AND
Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).
Transfer and storage of your information
Information about your call, such as your phone number and the date and time of your call, is processed by our third party telephone service provider which is located in the United Kingdom.
Information about your phone call will be stored by our third party telephone service provider within the European Economic Area.
Post
If you contact us by post, we will collect any information you provide to us in any postal communications you send us.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation)
Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.
AND
Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).
Information we collect when you interact with our website
We collect and use information from individuals who interact with particular features of our website in accordance with this section and the section entitled Disclosure and additional uses of your information.
E-Newsletter
When you sign up for our e-newsletter on our website or opt to receive news, offers or instructional advice regarding our services from us by entering your name and email address and clicking subscribe or ticking a box during the Sketchanet account signup process indicating that you would like to receive your e-newsletter, we collect your name and email address.
Legal basis for processing: your consent (Article 6(1)(a) of the General Data Protection Regulation).
Consent: you give your consent to us sending you our e-newsletter by signing up to receive it using the steps described above.
Transfer and storage of your information
We use a third party service to send out our e-newsletter and administer our mailing list, Drip. Their privacy policy is available here: https://www.drip.com/privacy
Information you submit to subscribe for our e-newsletter will be stored outside the European Economic Area on our third party mailing list provider’s servers in the United States. For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.
Use of web beacons and similar technologies in emails
We use technologies such as web beacons (small graphic files) and unique links in the emails we send to allow us to assess the level of engagement our emails receive by measuring information such as the delivery rates, open rates and click through rates and which our emails achieve.
For more information on how we use web beacons in our e-newsletter emails, see our cookies policy which is available here: https://www.sketchanet.com/cookies-policy
For more information about our third party mailing list provider and whether they use web beacons, please see their privacy policy which is available here: https://www.drip.com/privacy
Registering on our website
When you register and create an account on our website, we collect the following information: name, email address, and any other information you provide to us when you complete the registration form.
If you do not provide the mandatory information required by the registration form, you will not be able to register or create an account on our website.
Legal basis for processing: necessary to perform a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: creating an account on our website is necessary to allow you to access the services you have requested from us
Optional information
We also ask you how you heard about us, and if you would like to receive marketing communications from us. For further information, see ‘Marketing communications’ in this section below.
Legal basis for processing: our legitimate interests (Article 6(1)(b) of the General Data Protection Regulation).
Legitimate interests: to find out how you heard about us to improve our business’ advertising methods
AND
Legal basis for processing: your consent (Article 6(1)(a) of the General Data Protection Regulation).
Legitimate interests: you consent to us processing any optional information you provide by submitting that information to us.
Transfer and storage of your information
Information you submit to us via the registration form on our website will be stored by two third parties.
Your main account information including your name and email address will be stored within the European Economic Area on our third party hosting provider’s servers in Ireland. Our third party hosting provider is Amazon Web Services. Their privacy policy is available here: https://aws.amazon.com/privacy
Your name and email address and your contact preferences will also be stored outside the European Economic Area on our third party mailing list provider’s servers in the United States. Our third party mailing list provider is Drip. Their privacy policy is available here: https://www.drip.com/privacy.
We use Drip for all of our essential service emails in addition to our marketing emails.
For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.
Information we collect when you subscribe to our service or pay an invoice on our website
We collect and use information from individuals who make a payment on our website in accordance with this section and the section entitled Disclosure and additional uses of your information.
Information collected when you place an order
Mandatory information
When you place an order for goods or services on our website, we collect your name, email address, billing address, and company name (if applicable). If you do not provide this information, you will not be able to purchase goods or services from us on our website or enter into a contract with us.
Legal basis for processing: necessary to perform a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: we need the mandatory information collected by our checkout form to establish who the contract is with and to contact you to fulfil our obligations under the contract, including sending you receipts and order confirmations.
Processing your payment
After you place an order on our website you will need to make payment for the goods or services you have ordered. In order to process your payment we use third party payment processors, including SagePay and Stripe. Your payment will be processed by SagePay or Stripe via a payment gateway. Sketchanet does not handle or transmit sensitive payment information such as credit card details.
SagePay or Stripe collects, uses and processes your information, including payment information, in accordance with their privacy policies. You can access their privacy policies via the following link(s): https://www.sagepay.co.uk/policies/privacy-policy and https://stripe.com/gb/privacy
Transfer and storage of your information
Both SagePay and Stripe are global businesses and their data processing may be located both inside and outside the European Economic Area.
For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.
Legal basis for processing: necessary to perform a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: to fulfil your contractual obligation to pay for the goods or services you have ordered from us.
Marketing communications
There are two ways that we may engage with you for marketing purposes.
1) If you sign up for a Sketchanet account, then you are using our services and will have the option to opt out of receiving marketing communications from us. See the section Our Similar Goods and Services below.
2) If you have not signed up for any of our services but submit a form on our web site we may give you the option to opt in to receive our marketing communications. See the section Our Goods and Services below.
Our similar goods and services
This section applies if you have signed up for a Sketchanet account. You can opt-out from receiving marketing communications in relation to our paid goods and /or services which are similar to those for which you registered or purchased from us by ticking a box to opt out or by unticking a pre-ticked box. We may send you marketing communications in relation to similar goods and services if you do not opt out from receiving them.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interests: direct marketing and advertising our products and services.
Our goods and services
This section applies if you have not signed up for a Sketchanet account. You can opt in to receiving marketing communications from us in relation to our goods and services by email, phone, or by ticking a box indicating that you would like to receive such communications. We will send you marketing communications in relation to our goods and services only if you opt-in to receive them.
Legal basis for processing: consent (Article 6(1)(a) of the General Data Protection Regulation).
Consent: you give your consent to us sending you information about our goods and services by signing up to receive such information in accordance with the steps described above.
Transfer and storage of your information
We use a third party service to administer our mailing list, Drip.
Information you submit to subscribe for our e-newsletter will be stored outside the European Economic Area on our third party mailing list provider’s servers in the United States. For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.
Use of web beacons and similar technologies in emails
We use technologies such as web beacons (small graphic files)] and unique links in the emails we send to allow us to assess the level of engagement our emails receive by measuring information such as the delivery rates, open rates and click through rates which our emails achieve.
For more information on how we use web beacons in our emails, see our cookies policy which is available here: https://www.sketchanet.com/cookies-policy
For more information about our third party mailing list provider and they use web beacons, please see their privacy policy which is available here: https://www.drip.com/privacy
Information collected or obtained from third parties
This section sets out how we obtain or collect information about you from third parties.
Information received from third parties
We may occasionally receive information about you from third parties. The third parties from which we receive information about you will generally include existing users of our services or business partners in our industry. It is also possible that third parties with whom we have had no prior contact may provide us with information about you.
Information we obtain from third parties will generally be your name and contact details, but will include any additional information about you which they provide to us.
Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: where a third party has passed on information about you to us (such as your name and email address) in order for us to provide services to you, we will process your information in order to take steps at your request to enter into a contract with you and perform a contract with you (as the case may be).
AND
Legal basis for processing: consent (Article 6(1)(a) of the General Data Protection Regulation).
Consent: where you have asked that a third party to share information about you with us and the purpose of sharing that information is not related to the performance of a contract or services by us to you, we will process your information on the basis of your consent, which you give by asking the third party in question to pass on your information to us.
AND
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interests: where a third party has shared information about you with us and you have not consented to the sharing of that information, we will have a legitimate interest in processing that information in certain circumstances.
For example, we would have a legitimate interest in processing your information to perform our obligations under a sub-contract with the third party, where the third party has the main contract with you. Our legitimate interest is the performance of our obligations under our sub-contract.
Similarly, third parties may pass on information about you to us if you have infringed or potentially infringed any of our legal rights. In this case, we will have a legitimate interest in processing that information to investigate and pursue any such potential infringement.
Where we receive information about you in error
If we receive information about you from a third party in error and/or we do not have a legal basis for processing that information, we will delete your information.
Information obtained by us from third parties
In certain circumstances (for example, to verify the information we hold about you or obtain missing information we require to provide you with a service) we will obtain information about you from certain publicly accessible sources, both EU and non-EU, such as Companies House, business directories, media publications, social media, and websites (including your own website if you have one).
In certain circumstances will also obtain information about you from private sources, both EU and non-EU, such as lead generation services.
Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: where you have entered into a contract or requested that we enter into a contract with you, in certain circumstances, we will obtain information about you from public sources in order to enable us to understand your business and provide services to you or services to a sufficient standard.
For example, we would obtain and/or verify your email address from your website or from a directory where you ask us to send you information by email but we do not possess the information or we need to confirm that we have recorded your email address correctly.
AND
Legal basis for processing: our legitimate interests (Article 6(1)(b) of the General Data Protection Regulation).
Legitimate interests: in certain circumstances, we will have a legitimate interest in obtaining information about you from public and private sources. For example, if you have infringed or we suspect that you have infringed any of our legal rights, we will have a legitimate interest in obtaining and processing information about you from such sources in order to investigate and pursue any suspected or potential infringement.
AND
Legal basis for processing: consent (Article 6(1)(a) of the General Data Protection Regulation).
Consent: we may obtain information from third parties, such as data brokers, where you have consented to them sharing information with us by ticking a box stating that you would like your information to be share with us.
Our use of automated decision-making and profiling
We use automated decision making on our website. We do not consider that this has any legal effect on you or similarly significantly affects you.
You have the right to object to our use of automated decision making described in this section. You can do that by opting-out of cookies and similar technologies in accordance with the method described in the relevant section below.
You can find out more about our use of cookies and similar technologies (including the legal basis on which we use them) and how to opt out from them in our cookies policy, which is available here: https://www.sketchanet.com/cookies-policy
Automated decision making
Automated decision making is decision making by technological means (i.e. by a machine) without human involvement.
Use of automated decision making for display advertising
We automate the display of advertisements containing our products and services on other websites you visit, based on the fact that you have visited our website using cookies. For further information on the cookies we use, please see our cookies policy which is available here: https://www.sketchanet.com/cookies-policy
Logic involved: automatically displaying advertisements to individuals who have visited our website results in increased efficiencies and costs savings for us than manually displaying advertisements or displaying advertisements by different means.
Significance and envisaged consequences: cookies will be used to recognise the fact that you have visited our website in order to display advertisements to you (unless you have blocked such cookies) and will collect information about your online behaviour.
How to object: you can block these cookies by using the cookies control management tool on our site. For further information, please see our cookies policy: https://www.sketchanet.com/cookies-policy
Use of automated decision making for sending you relevant marketing emails or help emails
We use automated decision making for sending you emails that may help you understand how to better use our services. We may also send you emails bringing additional services to your attention that you may not know about.
Logic involved: to increase efficiencies and to help you understand our services that are relevant to you and how to use them
Significance and envisaged consequences: cookies and unique links will be used to track which pages on our website you have visited, and will collect data about which of our services you are interested in.
How to object: do not allow images when opening the email, do not click any links in the email. You can also unsubscribe from our marketing or our help emails by clicking the unsubscribe link in any of our emails.
Legal basis for processing: Our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: We want to help you get the most out of our services, and we also want to avoid sending you emails that may not be relevant to you.
Profiling
Profiling is any form of automated processing of your information to evaluate personal aspects about you, in particular to analyse or predict things like your interests, reliability, and behaviour.
Use of profiling for web analytics
Our web analytics service, Google Analytics, collects information such as your location (based on your IP address) and your behaviour (based on cookies) when you access our website (such as the pages you visit and what you click on). We will only process information from cookies if you have consented to us setting cookies on your computer in accordance with our cookies policy (https://www.sketchanet.com/cookies-policy). Information collected about you, once collected is anonymised and stored on an aggregate basis.
Logic involved: by automatically analysing and categorising information such as the location (based on IP address) as well as the behaviour and devices of visitors to our website (using cookies), we are able to gain a better understanding of what our website visitors want (in terms of the content of our website and our products), how to improve our website and how to advertise and market our services to them.
Significance and envisaged consequences: cookies will be used to track and store information about your behaviour and device on our website (unless you have opted out from receiving such cookies by opting out from analytical cookies used on your website) and your location will be analysed based on your IP address. We may target advertisements based on the level of interest we receive from certain visitors and their behaviour on our website.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: improving our marketing activities
Use of profiling in marketing emails
We use web beacons and unique links in our marketing emails to analyse who opens our emails and what actions they take (for example, what they click on). We will only process information from web beacons and unique links if you have consented to their use in accordance with our cookies policy (https://www.sketchanet.com/cookies-policy).
Logic involved: by analysing how our email recipients respond to our emails, we are able to improve the content and effectiveness of our emails and gauge who is most interested.
Significance and envisaged consequences: your behaviour when you open our emails will be tracked using small gif files (web beacons) and unique links, including open rates, click through rates, and what pages you subsequently visit.
How to object: do not allow images when opening the email, do not click any links in the email. You can also unsubscribe from our marketing or our help emails by clicking the unsubscribe link in any of our emails.
Legal basis for processing: legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: analysing the level of engagement and effectiveness of our marketing emails and content.
Disclosure and additional uses of your information
This section sets out the circumstances in which will disclose information about you to third parties and any additional purposes for which we use your information.
Disclosure of your information to service providers
We use a number of third parties to provide us with services which are necessary to run our business or to assist us with running our business and who process your information for us on our behalf. These include the following:
- Telephone provider, Voipfone. Their privacy policy is available here: https://www.voipfone.co.uk/your-data.php
- Email provider, Amazon Web Services. Their privacy policy is available here: https://aws.amazon.com/privacy/
- IT service providers, including DropBox. Their privacy policy is available here: https://www.dropbox.com/en_GB/privacy
- Occasionally, freelance designers, illustrators, animators, and web developers.
- Hosting providers, including Amazon Web Services (their privacy policy is available here: https://aws.amazon.com/privacy), and ICUK (their privacy policy is available here: https://www.icuk.net/contact/policies_privacy.asp)
- Bug Tracking provider Fogbugz (view their privacy policy at https://www.fogcreek.com/privacy)
- CRM Provider, Nimble (view their privacy policy at https://www.nimble.com/company/privacy/)
- Mailing List provider, Drip (view their privacy policy at https://www.drip.com/privacy)
- Project Management tools, including Asana (view their privacy policy at https://asana.com/terms#privacy-policy)
Our third party service providers are located in the United Kingdom, apart from DropBox, Fogbugz, Nimble, Drip, and Asana, which are located in the United States. Our freelance designers, illustrators, and web developers are located in the United Kingdom.
Your information will be shared with these service providers where necessary to provide you with the service you have requested, whether that is accessing our website or ordering goods and services from us.
Legal basis for processing: legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest relied on: where we share your information with these third parties in a context other than where is necessary to perform a contract (or take steps at your request to do so), we will share your information with such third parties in order to allow us to run and manage our business efficiently.
AND
Legal basis for processing: necessary to perform a contract and/or to take steps at your request prior to entering into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: we may need to share information with our service providers to enable us to perform our obligations under that contract or to take the steps you have requested before we enter into a contract with you.
Disclosure of your information to other third parties
We disclose your information to other third parties in specific circumstances, as set out below.
Providing information to third parties such as Google Inc. and Crazy Egg.
Google collects information through our use of Google Analytics on our website. Google uses this information, including IP addresses and information from cookies, for a number of purposes, such as improving its Google Analytics service. Information is shared with Google on an aggregated and anonymised basis. To find out more about what information Google collects, how it uses this information and how to control the information sent to Google, please see the following page: https://www.google.com/policies/privacy/partners/
Crazy Egg collects information such as mouse position, tap position, and scroll position as you navigate through our website. Crazy Egg uses this information to provide us with heat-maps showing how users interact with our website pages. Information is shared with Crazy Egg on an aggregated and anonymised basis. To find out more about what information Crazy Egg collects, how it uses this information and how to control the information sent to Crazy Egg, please see the following page: https://www.crazyegg.com/privacy
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s): meeting our contractual obligations to Google under our Google Analytics Terms of Service (https://www.google.com/analytics/terms/us.html)
You can opt out of Google Analytics by installing the browser plugin here: https://tools.google.com/dlpage/gaoptout
AND
Legal basis for processing: your consent (Article 6(1)(a) of the General Data Protection Regulation).
Consent: you give your consent to our use of cookies. For more information, please visit our cookies policy here: https://www.sketchanet.com/cookies-policy
Sharing your information with third parties, which are either related to or associated with the running of our business, where it is necessary for us to do so.
These third parties include our accountants, advisors, business partners, independent contractors, and insurers. Further information on each of these third parties is set out below.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: running and managing our business efficiently.
Accountants
We share information with our accountants for tax purposes. For example, we share invoices we issue and receive with our accountants for the purpose of completing tax returns and our end of year accounts.
Our accountants are located in the United Kingdom
Advisors
Occasionally, we obtain advice from advisors, such as lawyers and public relations professionals. We will share your information with these third parties only where it is necessary to enable these third parties to be able to provide us with the relevant advice.
Our advisors are located in the United Kingdom
Business partners
Business partners are businesses we work with which provide goods and services which are complementary to our own or which allow us to provide goods or services which we could not provide on our own. We share information with our business partners where you have requested services which they provide whether independently from, or in connection with or own services.
Our business partners are located in the United Kingdom
Insurers
We will share your information with our insurers where it is necessary to do so, for example in relation to a claim or potential claim we receive or make or under our general disclosure obligations under our insurance contract with them.
Our insurers are located in the United Kingdom
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: running and managing our business effectively.
AND
Legal basis for processing: necessary to perform a contract or to take steps at your request prior to entering into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: we need to share your information with other companies in order to be able to meet our contractual obligations to you or to take steps at your request prior to entering a contract, for example because of the services or information you have requested.
We do not display the identities of the other third parties we may share information with by name for security and competitive reasons. If you would like further information about the identities of such third parties, however, please contact us directly via our contact form or by email and we will provide you with such information where you have a legitimate reason for requesting it (where we have shared your information with such third parties, for example).
We will share your information with a prospective or actual purchaser or seller in the context of a business or asset sale or acquisition by us, a merger or similar business combination event, whether actual or potential.
Legal basis for processing: legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s): sharing your information with a prospective purchaser, seller or similar person in order to allow such a transaction to take place.
Disclosure and use of your information for legal reasons
Indicating possible criminal acts or threats to public security to a competent authority
If we suspect that criminal or potential criminal conduct has been occurred, we will in certain circumstances need to contact an appropriate authority, such as the police. This could be the case, for instance, if we suspect that we fraud or a cyber crime has been committed or if we receive threats or malicious communications towards us or third parties.
We will generally only need to process your information for this purpose if you were involved or affected by such an incident in some way.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interests: preventing crime or suspected criminal activity (such as fraud).
In connection with the enforcement or potential enforcement our legal rights
We will use your information in connection with the enforcement or potential enforcement of our legal rights, including, for example, sharing information with debt collection agencies if you do not pay amounts owed to us when you are contractually obliged to do so. Our legal rights may be contractual (where we have entered into a contract with you) or non-contractual (such as legal rights that we have under copyright law or tort law).
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: enforcing our legal rights and taking steps to enforce our legal rights.
In connection with a legal or potential legal dispute or proceedings
We may need to use your information if we are involved in a dispute with you or a third party for example, either to resolve the dispute or as part of any mediation, arbitration or court resolution or similar process.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s): resolving disputes and potential disputes.
For ongoing compliance with laws, regulations and other legal requirements
We will use and process your information in order to comply with legal obligations to which we are subject. For example, we may need to disclose your information pursuant to a court order or subpoena if we receive one.
Legal basis for processing: compliance with a legal obligation (Article 6(1)(c) of the General Data Protection Regulation).
Legal obligation(s): legal obligations to disclose information which are part of the laws of England and Wales or if they have been integrated into the United Kingdom’s legal framework (for example in the form of an international agreement which the United Kingdom has signed).
AND
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: where the legal obligations are part of the laws of another country and have not been integrated into the United Kingdom’s legal framework, we have a legitimate interest in complying with these obligations.
How long we retain your information
This section sets out how long we retain your information. We have set out specific retention periods where possible. Where that has not been possible, we have set out the criteria we use to determine the retention period.
Retention periods
Server log information: we retain information on our server logs for up to 2 years
Order information: when you place an order for goods and services, we retain that information for six years following the end of the financial year in which you placed your order, in accordance with our legal obligation to keep records for tax purposes.
Correspondence and enquiries: when you make an enquiry or correspond with us for any reason, whether by email or via our contact form or by phone, we will retain your information for as long as it takes to respond to and resolve your enquiry, and for up to 3 further months, after which point we will delete your information. However, if you have expressed an interest in becoming a customer we may keep your data for up to 2 years because the lead time of our customers can be up to 2 years and we may later need to refer back to previous correspondence.
E-Newsletter: we retain the information you used to sign up for our e-newsletter for as long as you remain subscribed (i.e. you do not unsubscribe) or if we decide to cancel our e-newsletter service, whichever comes earlier.
Sketchanet accounts: when you sign up for a Sketchanet account, including free trial accounts, we retain your name and email address until you cancel your account with us.
Criteria for determining retention periods
In any other circumstances, we will retain your information for no longer than necessary, taking into account the following:
- the purpose(s) and use of your information both now and in the future (such as whether it is necessary to continue to store that information in order to continue to perform our obligations under a contract with you or to contact you in the future);
- whether we have any legal obligation to continue to process your information (such as any record-keeping obligations imposed by relevant law or regulation);
- whether we have any legal basis to continue to process your information (such as your consent);
- how valuable your information is (both now and in the future);
- any relevant agreed industry practices on how long information should be retained;
- the levels of risk, cost and liability involved with us continuing to hold the information;
- how hard it is to ensure that the information can be kept up to date and accurate; and
- any relevant surrounding circumstances (such as the nature and status of our relationship with you).
How we secure your information
We take appropriate technical and organisational measures to secure your information and to protect it against unauthorised or unlawful use and accidental loss or destruction, including:
- only sharing and providing access to your information to the minimum extent necessary, subject to confidentiality restrictions where appropriate, and on an anonymised basis wherever possible;
- using secure servers to store your information;
- verifying the identity of any individual who requests access to information prior to granting them access to information;
- using Secure Sockets Layer (SSL) software to encrypt any information you submit to us via any forms on our website and any payment transactions you make on or via our website;
- only transferring your information via closed system or encrypted data transfers;
Transmission of information to us by email
Transmission of information over the internet is not entirely secure, and if you submit any information to us over the internet (whether by email, via our website or any other means), you do so entirely at your own risk.
We cannot be responsible for any costs, expenses, loss of profits, harm to reputation, damages, liabilities or any other form of loss or damage suffered by you as a result of your decision to transmit information to us by such means.
Transfers of your information outside the European Economic Area
Your information will be transferred and stored outside the European Economic Area (EEA) in the circumstances set out below. We will also transfer your information outside the EEA or to an international organisation in order to comply with legal obligations to which we are subject (compliance with a court order, for example). Where we are required to do so, we will ensure appropriate safeguards and protections are in place.
E-Newsletter
Information you submit to us when you sign up for our e-newsletter is transferred outside the EEA and stored on our third party mailing list provider’s servers. Our third party mailing list provider is: Drip. You can access their privacy policy here: https://www.drip.com/privacy
Country of storage: The United States. This country is not subject to an adequacy decision by the European Commission.
Safeguard(s) used: our third party mailing list provider is compliant with all aspects of the GDPR
Registration / Sketchanet account sign up
When you sign up for a Sketchanet account, or when you become an activated user of a Sketchanet account, we transfer your name and email address to our mailing list provider so that we can contact you regarding essential correspondence related to our service. This information is transferred outside the EEA and stored on our third party mailing list provider's servers. Our third party mailing list provider is: Drip. You can access their privacy policy here: https://www.drip.com/privacy
Country of storage: The United States. This country is not subject to an adequacy decision by the European Commission.
Safeguard(s) used: our third party mailing list provider is compliant with all aspects of the GDPR
Bug tracking
We use bug tracking software to improve our services. Occasionally, we may create a case in our bug tracking software that contains your personal information such as your name and email or phone number. This enables us to contact in relation to the resolution of a specific bug. Our third party bug tracking provider is: Fogbugz. You can access their privacy policy here: https://www.fogcreek.com/privacy
Country of storage: The United States. This country is not subject to an adequacy decision by the European Commission.
Safeguard(s) used: our third party mailing list provider has self-certified its compliance with the EU-U.S. Privacy Shield.
Project management
We use project management software to manage our website design projects. Project data may contain your personal information such as your name and email or phone number. This enables us to contact in relation to the progress of a project. Our third party project management provider is: Asana. You can access their privacy policy here: https://asana.com/terms#privacy-policy
Country of storage: The United States. This country is not subject to an adequacy decision by the European Commission.
Safeguard(s) used: our third party mailing list provider has self-certified its compliance with the EU-U.S. Privacy Shield.
Customer relationship management
We use customer relationship management software to manage our customer information and that of our prospective customers. This is generally restricted to those who have used or may be interested in our design services. Information we collect will include your contact details and information about the prospective project. Our third party customer relationship management software provider is: Nimble. You can access their privacy policy here: https://www.nimble.com/company/privacy/
Country of storage: The United States. This country is not subject to an adequacy decision by the European Commission.
Safeguard(s) used: our third party mailing list provider has self-certified its compliance with the EU-U.S. Privacy Shield.
Your rights in relation to your information
Subject to certain limitations on certain rights, you have the following rights in relation to your information, which you can exercise by sending an email to support@sketchanet.com:
- to request access to your information and information related to our use and processing of your information;
- to request the correction or deletion of your information;
- to request that we restrict our use of your information;
- to receive information which you have provided to us in a structured, commonly used and machine-readable format (e.g. a CSV file) and the right to have that information transferred to another data controller (including a third party data controller);
- to object to the processing of your information for certain purposes (for further information, see the section below entitled Your right to object to the processing of your information for certain purposes); and
- to withdraw your consent to our use of your information at any time where we rely on your consent to use or process that information. Please note that if you withdraw your consent, this will not affect the lawfulness of our use and processing of your information on the basis of your consent before the point in time when you withdraw your consent.
In accordance with Article 77 of the General Data Protection Regulation, you also have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or of an alleged infringement of the General Data Protection Regulation.
For the purposes of the UK, the supervisory authority is the Information Commissioner’s Office (ICO), the contact details of which are available here: https://ico.org.uk/global/contact-us/
Further information on your rights in relation to your personal data as an individual
The above rights are provided in summary form only and certain limitations apply to many of these rights. For further information about your rights in relation to your information, including any limitations which apply, please visit the following pages on the ICO’s website:
https://ico.org.uk/for-the-public/is-my-information-being-handled-correctly/
You can also find out further information about your rights, as well as information on any limitations which apply to those rights, by reading the underlying legislation contained in Articles 12 to 22 and 34 of the General Data Protection Regulation, which is available here: https://eur-lex.europa.eu/eli/reg/2016/679
Verifying your identity where you request access to your information
Where you request access to your information, we are required by law to use all reasonable measures to verify your identity before doing so. These measures are designed to protect your information and to reduce the risk of identity fraud, identity theft or general unauthorised access to your information.
How we verify your identity
Where we possess appropriate information about you on file, we will attempt to verify your identity using that information.
If it is not possible to identity you from such information, or if we have insufficient information about you, we may require original or certified copies of certain documentation in order to be able to verify your identity before we are able to provide you with access to your information. We will be able to confirm the precise information we require to verify your identity in your specific circumstances if and when you make such a request.
Your right to object to the processing of your information for certain purposes
You have the following rights in relation to your information, which you may exercise in the same way as you may exercise by sending an email to support@sketchanet.com:
- to object to us using or processing your information where we use or process it in order to carry out a task in the public interest or for our legitimate interests, including ‘profiling’ (i.e. analysing or predicting your behaviour based on your information) based on any of these purposes; and
- to object to us using or processing your information for direct marketing purposes (including any profiling we engage in that is related to such direct marketing).
- You may also exercise your right to object to us using or processing your information for direct marketing purposes by:
- clicking the unsubscribe link contained at the bottom of any marketing email we send to you and following the instructions which appear in your browser following your clicking on that link;
- sending an email to support@sketchanet.com, asking that we stop sending you marketing communications or by including the words “OPT OUT”.
For more information on how to object to our use of information collected from cookies and similar technologies, please see the section entitled How to accept or reject cookies in our cookies policy, which is available here: https://www.sketchanet.com/cookies-policy
Sensitive Personal Information
‘Sensitive personal information’ is information about an individual that reveals their racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic information, biometric information for the purpose of uniquely identifying an individual, information concerning health or information concerning a natural person’s sex life or sexual orientation.
We do not knowingly or intentionally collect sensitive personal information from individuals, and you must not submit sensitive personal information to us.
If, however, you inadvertently or intentionally transmit sensitive personal information to us, you will be considered to have explicitly consented to us processing that sensitive personal information under Article 9(2)(a) of the General Data Protection Regulation. We will use and process your sensitive personal information for the purposes of deleting it.
Changes to our Privacy Policy
We update and amend our Privacy Policy from time to time.
Minor changes to our Privacy Policy
Where we make minor changes to our Privacy Policy, we will update our Privacy Policy with a new effective date stated at the beginning of it. Our processing of your information will be governed by the practices set out in that new version of the Privacy Policy from its effective date onwards.
Major changes to our Privacy Policy or the purposes for which we process your information
Where we make major changes to our Privacy Policy or intend to use your information for a new purpose or a different purpose than the purposes for which we originally collected it, we will notify you by email (where possible) or by posting a notice on our website.
We will provide you with the information about the change in question and the purpose and any other relevant information before we use your information for that new purpose.
Wherever required, we will obtain your prior consent before using your information for a purpose that is different from the purposes for which we originally collected it.
Children’s Privacy
Because we care about the safety and privacy of children online, we comply with the Children’s Online Privacy Protection Act of 1998 (COPPA). COPPA and its accompanying regulations protect the privacy of children using the internet. We do not knowingly contact or collect information from persons under the age of 18. The website is not intended to solicit information of any kind from persons under the age of 18.
It is possible that we could receive information pertaining to persons under the age of 18 by the fraud or deception of a third party. If we are notified of this, as soon as we verify the information, we will, where required by law to do so, immediately obtain the appropriate parental consent to use that information or, if we are unable to obtain such parental consent, we will delete the information from our servers. If you would like to notify us of our receipt of information about persons under the age of 18, please do so by sending an email to support@sketchanet.com.
California Do Not Track Disclosures
“Do Not Track” is a privacy preference that users can set in their web browsers. When a user turns on a Do Not Track signal in their browser, the browser sends a message to websites requesting that they do not track the user. For information about Do Not Track, please visit www.allaboutdnt.org
At this time, we do not respond to Do Not Track browser settings or signals. In addition, we use other technology that is standard to the internet, such as pixel tags, web beacons, and other similar technologies, to track visitors to the website. Those tools may be used by us and by third parties to collect information about you and your internet activity, even if you have turned on the Do Not Track signal. For information on how to opt out from tracking technologies used on our website, see our cookies policy which is available here: https://www.sketchanet.com/cookies-policy