V4, Effective 24 May 2018
1.1 We are committed to safeguarding the privacy of our website visitors and service users, including users of both our Base and CoachBot services.
1.2 This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.
1.3 In this policy, "we", "us" and "our" refer to Saberr Limited. For more information about us, see Section 16.
2. How we use your personal data
2.1 In this Section 2 we have set out:
(a) the general categories of personal data that we may process;
(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
(c) the purposes for which we may process personal data; and
(d) the legal bases of the processing.
2.2 We may process data about your use of our website and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking systems (see Section 14 below for more information about how this data is collected). This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.
2.3 We may process information in enquiries relating to our services, our prospective customer relationships and our customer relationships ("customer relationship data"). The customer relationship data may include your name, your employer, your job title or role, your contact details, and information contained in communications between us and you or your employer. The source of the customer relationship data is you or your employer; in some cases, the data may be provided to us by one of the coaches in our coaching network. The customer relationship data may be processed for the purposes of managing our relationships with prospects and customers, communicating with prospects and customers, keeping records of those communications and promoting our software and services. The legal basis for this processing is our legitimate interests, namely the proper management of our customer relationships.
2.4 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters ("notification data"). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. In the case of our newsletters, the legal basis for this processing is consent; in the case of other email notifications, the legal basis for this processing is our legitimate interests, namely the management of our software and systems and keeping users informed of issues relating to our software and systems.
2.5 We may process any information that you provide to us when completing questionnaires in Base or CoachBot ("questionnaire data"). The questionnaire data may be processed for the purpose of providing our services to customers. As part of these services, we may undertake profiling, using the questionnaire data relating to personality profiles, value profiles and relationship profiles to create reports for customers. Although we are controllers of the raw questionnaire data that you provide to us, the relevant customer will be the controller of the reports. The legal basis for this processing is legitimate interests, namely:
(a) the legitimate interests of our customers in using our services to improve team development and recruitment process; and
(b) our legitimate interests in the proper provision of our services to customers.
2.6 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
2.7 We may process any of your personal data where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
2.8 In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
2.9 Please do not supply any other person's personal data to us, unless we prompt you to do so.
3. Providing your personal data to others
3.1 If you complete a questionnaire in the course of using our services, we will not usually disclose your questionnaire data to our customer. We will however disclose to our customer reports based on the questionnaire data. Those reports are either based on processed (aggregated) data identified as being about you, or on anonymised data. It may in a particular case be possible to identify you through the report.
3.2 Personal information that we collect is stored on our web servers. We use cloud-based web services provided by Amazon Web Services.
3.3 If you enquire about coaching services, we may disclose your enquiry to one or more selected third party coaches for the purpose of enabling them to contact you so that they can offer, market and sell to you relevant services. Each coach will act as a data controller in relation to the supplied enquiry data.
3.4 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
3.5 In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
4. International transfers of your personal data
4.1 In this Section 4, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).
4.2 The servers of our customer relationship management system providers (Pipedrive and Intercom) are situated in the USA. Transfers of customer relationship data to these providers in the USA will be protected by appropriate safeguards, namely the Privacy Shield scheme. For details, see:
4.3 The servers of our email communications system provider (MailChimp) are also situated in the USA. Transfers of customer relationship data and notification data to this provider in the USA will be protected by appropriate safeguards, also the Privacy Shield scheme. For details, see:
4.4 For general information about the Privacy Shield scheme, see:
5. Retaining and deleting personal data
5.1 This Section 5 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
5.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
5.3 We will retain your personal data as follows:
(a) usage data will be retained for a period of 14 months following either collection or the last time the user uses the service;
(b) customer relationship data relating to customers will be retained for a minimum period of 24 months following the end of the year during which our relationship with the relevant customer was terminated, and for a maximum period of 36 months following that date;
(c) customer relationship data relating to non-customers will be retained for a minimum period of 12 months following the end of the calendar year during which it was collected, and for a maximum period of 24 months following that date;
(d) notification data will be retained for a minimum period of 30 days following the date of sending of a notification, and for a maximum period of 90 days following that date; and
(e) questionnaire data will be retained for the same period as the user account data of the relevant customer (i.e. for the period of our contract with the customer and for a limited period after the termination of that contract).
5.4 In the case of questionnaire data, we may effectively anonymise that data before the end of the retention period, rather than deleting the data.
5.5 Notwithstanding the other provisions of this Section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
6. Security of personal data
6.1 We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.
6.2 We will store all your personal data on secure servers, personal computers and mobile devices, and in secure manual record-keeping systems.
6.3 Data that is sent from your web browser to our web server, or from our web server to your web browser, will be protected using encryption technology.
6.4 You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
6.5 You should ensure that any password you create for use in connection with our services is not susceptible to being guessed, whether by a person or a computer program. You are responsible for keeping the password confidential and we will not ask you for your password (except when you log in to our services).
7.1 We may update this policy from time to time by publishing a new version on our website.
7.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
7.3 We may notify you of significant changes to this policy by email.
8. Your rights
8.1 In this Section 8, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
8.2 Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
8.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
8.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
8.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
8.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
8.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
8.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
8.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
8.10 To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,
and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
8.11 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
8.12 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
8.13 You may exercise any of your rights in relation to your personal data by written notice to us.
9. Third party websites
9.1 Our website includes hyperlinks to, and details of, third party websites.
9.2 We have no control over, and are not responsible for, the privacy policies and practices of third parties.
10. Updating information
10.1 Please let us know if the personal information that we hold about you needs to be corrected or updated.
11. Acting as a data processor
11.1 In respect of user account data of the personnel of our customers, we do not act as a data controller; instead, we act as a data processor.
11.2 Insofar as we act as a data processor rather than a data controller, this policy shall not apply. Our legal obligations as a data processor are instead set out in the contract between us and the relevant data controller.
12. About cookies
12.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
12.2 Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
12.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
13. Cookies that we use
(g) customer support - cookies are required to use our customer support widget.
14. Cookies used by our service providers
14.2 We use Google Analytics, Segment, Heap and HotJar to analyse the use of our website. These services providers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website.
14.3 Our analytics service providers' privacy policies are available at:
https://www.google.com/policies/privacy/ (Google Analytics)
15. Managing cookies
15.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);
(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
(c) http://www.opera.com/help/tutorials/security/cookies/ (Opera);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(e) https://support.apple.com/kb/PH21411 (Safari); and
(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
15.2 Blocking all cookies will have a negative impact upon the usability of many websites.
15.3 If you block cookies, you will not be able to use all the features on our website.
16. Our details
16.1 This website is owned and operated by Saberr Limited.
16.2 We are registered in England and Wales under registration number 08388093, and our registered office is at Saberr / Rocketspace, 40 Islington High Street, London, United Kingdom, N1 8EQ.
16.3 You can contact us:
(a) by post, to the postal address given above;
(b) using our website contact form;
(c) by telephone, on the contact number published on our website from time to time; or
(d) by email, using the email address published on our website from time to time.