1 About us and this policy
1.1 Numerable Software Ltd (“we” or “us”) is committed to protecting and respecting your privacy. We are registered in England and Wales under company number 09741232 and have our registered office at C/O Roxburgh Milkins, Merchants House North, Wapping Road, Bristol, United Kingdom, BS1 4RW.
1.2 Numerable Software Ltd provides board intelligence services provided through the Numerable web app, website, application programming interface (API), consultancy arrangements and/or as otherwise provided by Numerable from time to time (the “Service”).
1.3 Numerable Software Ltd operates a website at https://www.numerable.io/ (the “Website”).
1.4 This policy explains how we will use and share any personal information we collect from you, or that you provide to us. It also explains how your personal data is used and collected through your use of the Service.
1.5 For the purpose of the Data Protection Act 2018, the General Data Protection Regulation (EU) 2016/679 as transposed into UK law pursuant to the European Union (Withdrawal) Act 2018 (UK GDPR) and any subsequent UK data protection legislation, the data controller is Numerable Software Ltd, whose registered address is C/O Roxburgh Milkins, Merchants House North, Wapping Road, Bristol, United Kingdom, BS1 4RW (ICO Data Protection Registration Number: ZA336190).
2 Information we collect
2.1 We may collect and process the following data about you:
2.1.1 information that is in already the public domain, such as data relating to your directorships that is published by Companies House or is disclosed in a company’s accounts or annual report,
2.1.2 information that you provide to us for the purposes of creating an account or users to use the Service, subscribing to our newsletter, uploading content to the Service or by corresponding with us by phone, email, chat or otherwise. This information may include your name, place of work, job title, business e-mail address, business phone number and links to social media accounts;
2.1.3 details of transactions that you carry out through the Service, where this is required for our billing or other purposes. We do not collect or store any bank account details or card information on our servers and all payments for the Services are operated through a 3rd party payment gateway;
2.1.4 information about your use of the Service and the Website, such as your account use, number of logins and other information displayed within your account;
2.1.5 information about your IP address, which is not used to identify you and is for statistical purposes only;
2.1.6 additional e-mail recipients added to the records in relation to the Services;
2.1.7 web browser / mobile device configuration for support purposes; and
2.1.8 any further information that you choose to provide to us.
2.2 We may receive information about you from other sources, for example trade bodies, reference agencies and credit checking agencies.
2.3 We may also collect other information which does not constitute personal data, for example information which exclusively relates to your business or organisation.
3 Third party information
Before you disclose to us any personal information relating to any other person, you must ensure that you have all relevant consents and permissions required to enable us to use that information for the stated purposes.
4 Cookies
4.1 We use cookies to distinguish you from other users of the Service and the Website. This helps us to provide you with a good experience when you use the Service and Website and allows us to improve the Service.
4.2 A cookie is a file containing letters and numbers that we store on your browser or the hard drive of your computer, if you agree to this.
4.3 Cookies allow you to take advantage of some of the Service’s features. If you block or otherwise reject our cookies, it may prevent you from using certain parts of the Service.
4.4 The Service and the Website use tracking software to monitor their visitors to better understand how they use it. This software is provided by Google Analytics which uses cookies to track visitor usage. The software will save a cookie to your computer’s hard drive in order to track and monitor your engagement and usage of the Service and the Website, but will not store, save or collect personal information. You can read Google’s privacy policy on its website (https://www.google.co.uk/intl/en_uk/policies/privacy/) for further information.
4.5 Other cookies may be stored to your computer’s hard drive by external vendors when this Service or Website uses referral programs, sponsored links or adverts. Such cookies are used for conversion and referral tracking and typically expire after 30 days, though some may take longer.
5 How we use your information
5.1 We use information held about you in the following ways:
5.1.1 to include in the Service information about you that is already in the public domain;
5.1.2 to help us improve the Service and the Website for you;
5.1.3 to invite you to set up an account to use the Service;
5.1.4 to invite you to upgrade the Service;
5.1.5 to provide you with the Service and to administer and manage your account;
5.1.6 to send statements and invoices to you, and collect payments from you;
5.1.7 to notify you about any changes to the Service or the Website or to the terms and conditions or this policy, or about any technical issues which may affect you and your use of the Service or the Website;
5.1.8 to improve the Service and the Website to ensure that it is presented to you in the most effective manner for you;
5.1.9 to keep the Service and the Website secure and prevent fraud;
5.1.11 to deal with any correspondence that you send to us by email, telephone or otherwise; and
5.1.12 for statistical, research and analytics purposes.
6 Sharing your information
6.1 We may need to disclose your information to any of our employees, officers, agents, suppliers or subcontractors insofar as is reasonably necessary for the purposes of delivering the Service to you.
6.2 We may also aggregate your financial data with other users of the Services for the purposes of providing that data as a part of the Services to users for benchmarking purposes. In this instance, your data will be anonymised.
6.3 We may also disclose your information:
6.3.1 if we are required to do so to comply with any legal obligation or to enforce or apply our terms and conditions, or to protect the rights, property or safety of us or of other users of the Service or the Website;
6.3.2 in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets subject to reasonable obligations of confidentiality and in accordance with the applicable law; and
6.3.3 if we (or substantially all of our assets) are acquired by a third party, in which case personal data held about users will be transferred as an asset.
6.4 Except as provided in this policy, we will not provide your information to third parties.
7 Legal basis for processing your data
7.1 We may process your data because:
7.1.1 we are legally obliged to e.g. to confirm your identity;
7.1.2 the processing is necessary for the performance of the contract with you to provide our Services; or
7.1.3 it is in ours or a third party’s legitimate interests to do so.
7.2 In some instances, we will rely on your consent to process personal data and where we do this, it will be flagged to you at the time.
8 Storage of your information
8.1 All data that we hold about you is stored on secure cloud-based servers in the UK or Ireland (i.e. within the European Economic Area (EEA)). Where your personal data is transferred outside of the UK and the EEA, we ensure that all transfers are subject to the appropriate security measures to safeguard your personal data and fully comply with the requirements of applicable UK and EU regulations.
8.2 Payment transactions are processed by our 3rd party payment gateway, which will have access only to your payment details, which will be encrypted in accordance with their own policies. You and we will comply with the terms of the 3rd party payment service when receiving and making payments.
8.3 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 through the Service; 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.
8.4 You are responsible for selecting a secure password for your use of the Service and for keeping that password confidential. We will only ask you for your password when you log into the Service and will never ask you to disclose your password to us otherwise.
8.5 If you want to view detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
9 How long do we keep your personal information?
We keep your personal information for as long as we need to for the purposes for which it was collected or (if longer) for any period for which we are required to keep personal information to comply with our legal and regulatory requirements.
10 Deletion of your personal information
10.1 We are not able to remove your personal information unless we also remove your account, as we require this information in order to operate and manage your account.
10.2 If your account is terminated for any reason, please note that we will remove all information held within your account within 60 days. You are responsible for ensuring that you keep a copy of all information uploaded to the Service.
11 Your rights
11.1 You are responsible for ensuring that information you provide to us is accurate, complete and up-to-date. You can review and change your information by logging into the Service and visiting your account profile page.
11.2 You have a number of rights in relation to your personal data, these include the right to:
11.2.1 find out how we process your data;
11.2.2 request that your personal data is corrected if you believe it is incorrect or inaccurate;
11.2.3 obtain restriction on our, or object to, processing of your personal data;
11.2.4 if we are relying on consent, you can withdraw your consent to our processing of your personal data; and
11.2.5 obtain a copy of the personal data we process concerning you. We may, if permitted by the applicable legislation, charge a small fee towards the cost of administering any request you make and we will take steps to verify your identity before responding to your request. Once we have received the fee (if required) and verified your identity we will respond as soon as possible and in any event within one month.
11.3 If you would like to exercise any of your rights or find out more, please contact us at info@numerable.io.
12 Marketing
We operate an email newsletter program, used to inform subscribers about products and services supplied by the Service and the Website. You can subscribe through an online automated process should you wish to do so. Some subscriptions may be manually processed. You are given the opportunity to unsubscribe at any time through an automated system. This process is detailed at the footer of each email campaign. If an automated un-subscription system is unavailable clear instructions on how to un-subscribe will by detailed instead.
13 Third party websites
From time to time we may publish links on the Service and the Website to and from the websites of partner services, networks and affiliates. If you follow any of these links, please note that such websites have their own privacy policies and we do not accept any responsibility or liability for those policies. Please check those policies before you submit any personal data to those websites.
14 Social media platforms
We may use social sharing buttons which help you to share web content directly from our web pages to certain social media platforms. You are advised before using such social sharing buttons that you do so at your own discretion and note that the social media platform may track and save your request to share a web page respectively through your social media platform account.
15 Changes to this policy
Any changes we make to this privacy policy in the future will be included in the privacy policy on the Service and the Website and, where appropriate, will be notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.
16 Complaints
If you have any complaints about the way we use your personal information please contact info@numerable.io who will try to resolve the issue. If we cannot resolve any issue, you have the right to complain to the data protection authority in your country (the Information Commissioner in the UK). If you need more information about how to contact your local data protection authority please let us know by contacting info@numerable.io.
17 Contact
Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to info@numerable.io.
18 Document version
This document is our ‘Privacy Policy’, version 2.0, published January 2024.