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Stannp Privacy and Cookies Policy

This is the Privacy & Cookies Policy (the “Policy”) of Stannp Ltd, a company registered in England and Wales with company registration number 9086822 and with registered office at Unit 12 Taw Trade Park, Braunton Road, Barnstaple, Devon, England, EX31 1JZ (hereafter “Stannp”, “we” or “us”). This Policy describes the ways in which Stannp collects and uses information about you when you use its website at stannp.com (the “Website”) and/or use its service (the “Platform”).

Stannp may change this Policy at any time and whilst it will tell you about what it feels are key changes to the Policy, please check it regularly to keep up-to-date. If you do not wish to accept the new Policy you should stop using the Service. If you continue to use the Service after the changes, your continued use of the Service shows us your agreement to be bound by the new Policy.

This Policy was last changed in September 2023.

ICO Registration

For the purposes of data protection legislation, Stannp is a data controller, which has registered with the Information Commissioner's Office (“ICO”). Its registration number is ZA134992. If you are an EU Data Subject you can contact our EU Representative, Rune Peterson, at eurep@fifthsquare.eu. Our EU Representative complies with our obligations under GDPR Article 27 and is established in the Republic of Ireland. Please note that our EU Representative is a Third Party. They will process your personal data in accordance with this Privacy Policy.

Information we use about you

What information do we collect? When do we collect this? How do we use this information? Our reasons
  • First name
  • Last name
  • Email address
  • Address
  • Phone number
  • Company
  • Job title
 If you choose to sign up to the Platform and use the Service. To create your account and allow you to access and use the Service thereafter. Contractual necessity: We require details of your full name, email address, address and company to create and administer your account, including to send you personalised system notifications, identify you at sign-in, for billing and other account administration purposes.
Consent: You may elect to provide us details of your phone number, including if you wish to set up a two-step authentication verified by SMS for your account or if you sign up to our SMS delivery service. You may also elect to provide details of your job title to enable us to send you more personalised notifications, including for us to provide communications adapted to your role in your company.
  • First name
  • Last name
  • Credit card details
  • Address
 When you top up your balance on your account or set up a subscription To collect our fees Contractual necessity: We require these details to be able to collect our fees in relation to the Service provided to you.
  • First name
  • Last name
  • Email Address
  • Address
  • Phone Number
 If you choose to subscribe to marketing communications (whether by email, SMS or post (as applicable)) from Stannp or if we are otherwise permitted to send them to you by law. To send you marketing communications about our upcoming activities as well as other news and features relating to Stannp, including about services available from Stannp and its affiliates. Consent: We only send you marketing communications by either email, SMS or post (as you elect) where you have consented to receiving them, or if we are otherwise permitted to send them to you by law (e.g., by virtue of the soft opt-in). You can unsubscribe at any time by clicking the unsubscribe button in any marketing message sent to you or alternatively by toggling off the contact settings in the “how we can contact you” section of your account settings.
Any personal data you may provide when answering our surveys. If you choose to reply to one of our surveys. To conduct research about our customers' opinion of the current Service or of potential new services that may be offered. Consent (or in the case of any special category data, explicit consent): You do not have to respond to such surveys. If you do elect to answer a survey, the information is used to allow us to understand better who uses our Platform and Service and assists us in making improvements to our Services.
The information collected via those cookies/technologies which are not necessary cookies, as set out in paragraph 8 below. If you choose to allow these cookies (other than necessary cookies) to be placed then Stannp will place those cookies and therefore collect the information provided via them accordingly. To assess visitor numbers to our Platform and how users interact with our Platform and the Service, as well as for other maintenance and support purposes. Consent: We only place non-necessary cookies if you consent to these when first visiting our Website or Platform.
Information collected by our use of necessary cookies and similar technologies When you use our Website or Platform To carry out administrative tasks and to help us improve the functionalities and features of the Website and Platform. Legitimate interests: This personal data allows us to provide and improve the services that we offer you. The items of personal data collected are, limited to “technical” type data and your rights and freedoms are not outweighed by us collecting this data from you.

Sharing your information with third parties

Some of the information Stannp collects from you may be passed to third parties. These third parties are:

  1. our server, database and cloud-based file storage provider - Microsoft Azure;
  2. our CRM and marketing emails provider - Hubspot;
  3. our downstream access courier provider for physical items only - Whistl;
  4. our provider for the delivery of postcards and letters - Royal Mail;
  5. our accounts software provider - Sage;
  6. our data cleaning provider - Sagacity;
  7. our analytics provider - Google Analytics;
  8. our SMS delivery service provider - Plivo;
  9. our transactional notification emails provider - Sendgrid;
  10. certain third party analytics and cookies providers as described further in paragraph 8 below;
  11. any group companies of ours or affiliates;
  12. our regulator (the ICO);
  13. in anonymised form, Stannp may share the information with:
    1. any third party, in relation to the sale of some or all of Stannp's business, or its assets, or as part of any business restructuring or reorganisation. Stannp will take steps with the aim of ensuring that your rights continue to be protected if your personal data is transferred under these circumstances;
    2. data aggregators and platform providers as part of an analysis of user metrics or sales performance; or
    3. law enforcement agencies in compliance with law enforcement.

Links to third party websites and third party adverts

Stannp is not responsible for the privacy policies and practices of other sites even if you access them via the Website, Platform and/or as part of your use of the Service. You should check the policy of each site you visit and contact its owner or operator if you have any concerns or questions.

Security

Stannp has implemented technology and policies to safeguard your privacy from unauthorised access and improper use. Personal data is secured on computer servers in a controlled, secure environment, protected from unauthorised access, use or disclosure. When personal information (such as a credit card number) is transmitted to other websites, it is protected through the use of encryption, such as Secure Socket Layer (SSL) protocol.

Storage and Data Retention

We store the personal data of our UK and EEA based customers in the EEA. We do not currently transfer such data outside the EEA. If we ever need to transfer personal data outside the UK and/or EEA we will ensure that we have an appropriate adequacy ground to do so e.g., SCCs. We retain your data for no longer than is reasonable in line with the purposes for which it was originally collected. If you have an active account on our Platform, you can configure a retention policy yourself. If you do not configure it the default retention period for sensitive assets will be 3 years unless you fail to use your account at least once in any 12 month period in which case we will delete your account and associated data after such 12 months of non-use. Any user with an account can request their personal data to be removed at any time, however please note that (i) if the user account was a previous customer of Stannp, data may be anonymised rather than fully removed and (ii) any personal data appearing on sales invoices will be retained by Stannp for at least 3 years.

Cookies

  1. What are Cookies? Cookies are small text files that are placed on your device when you use the Website or Platform. Stannp's use of cookies is detailed below. Session cookies enable you to move from page to page within the Website and Platform and any information you enter will be remembered but is deleted when you close the page on that Website / Platform or after a short time. Persistent cookies allow us to remember your preferences and settings when you use the Website or Platform in the future.
  2. Disabling Cookies: The use of the cookies described above improves the functionality of our Website and Platform and your experience of using them. If you do not want these cookies to be served on your device, you are able to disable them by changing the settings on the Website, Platform or on your device. Please note that if you do decide to disable cookies you may not be able to access some of the Website or Platform, and some of the features of the Website or Platform may not function properly.
  3. Third Party Cookies: Third Party advertisers may place or read cookies on your browser or device when you use the Website or Platform. This Policy is applicable only to the use of cookies by Stannp and does not cover the use of cookies by any third parties (including advertisers or social media companies).
  4. More information: To find out more about how cookies work, how to manage and delete them and to see which ones have been set please visit www.aboutcookies.org or www.allaboutcookies.org.

Stannp uses cookies and similar technologies in the following ways when you use the Website or Platform: Stannp places a cookie with authentication tokens, dashboard configuration as well as a cookie to track a referrer website source to know if an ad or referral link has been used. Stannp also uses Google Analytics, Google Adwords and Hubspot, which each place their own tracking cookies, including for the purposes of tracking user behaviour on the Website / Platform.

Exercising your rights

You can contact us using the details set out in paragraph 9 below if you wish to: (i) access a copy of the personal data that we hold about you; (ii) correct any items of personal data that we hold about you; and/or (iii) have any items of personal data that we hold about you erased or object to our processing of such items of personal data.

Stannp Details

If at any time you would like to contact Stannp about your views on this Policy or any enquiry relating to your personal information, you can do so by sending an e-mail to us at GDPR@stannp.com or write to us at “Data Protection Query, Stannp Ltd, Unit 12 Taw Trade Park, Braunton Road, Barnstaple, Devon, England, EX31 1JZ”. You also have the right to make a complaint to the ICO by contacting them at any time.