1. Introduction

1.1 This privacy policy sets out the basis on which Sargent-Disc Ltd (company number: 02020919, registered office: First Floor, St Johns House, 16 Church Street, Bromsgrove, B61 8DN) (we, us or our) will process any personal data that we collect on or about you in relation to your use of our software services (such as Payroll, Payslip, Payscales, Digital Purchase Order or CrewStart ™) (Services). Please read the following privacy policy carefully to understand how we use and protect your personal information.

2. Your use of our Services

2.1 Your use of our Services will, at least initially, be subject to the authorisation of an entity which engages you for your services (a Contracting Entity) and in accordance with the applicable Terms of Use. Your personal data may be provided to us by you or by your Contracting Entity and we shall handle such data in accordance with the instructions of your Contracting Entity.

2.2 If you are entitled to continue to use our Services after your engagement by a Contracting Entity has come to an end, we shall store your personal data in accordance with this privacy policy and the applicable Terms of Use.

2.3 If you have any queries or complaints in relation to this privacy policy our contact details are as follows:

Address: Sargent-Disc Ltd, 5 – 7 Baring Road, Beaconsfield, Bucks, HP9 2NB.

Email: dataprotection@sargent-disc.com

Tel: +44 (0)1753 630300

If you are located in the European Economic Area (EEA), Sargent-Disc (Ireland) Ltd, incorporated in The Republic of Ireland under number 593567 whose registered office is at 99 St Stephens Green, Dublin 2, D02 V278, Ireland acts as our European Representative.

3. The information that we collect from you

3.1 We collect information that you provide to us when you use our Services. For example, this includes your log-in details, contact information and any other information relating to you which is uploaded to a Service.

3.2 We will collect any information contained in any correspondence between you and us. For example, if you contact us, we may keep a record of that correspondence. We may also ask you for information when you report a problem with our Services.

3.3 We may collect aggregated, anonymised information about users of our Services based on the information uploaded by you and by Contracting Entities. For example, we may compile information about the average rate of pay of certain types of contractor.

3.4 We may collect certain information about and how you use our Services. This may include your IP address, geographical location, browser type, referral source, length of use and similar information. Individual users will not be identifiable from this information. This information may be collected by a third party website analytics service provider on our behalf and may be collected using cookies. For more information on our use of cookies please refer to section 6 below.

4. Use of your information

4.1 We will only use the personal information that we collect from you in accordance with this privacy policy.

4.2 We may use your information for the following purposes:

4.2.1 to maintain your account in order that you may use our Services when your employment or engagement with a Contracting Entity ends and to transfer your account to any further Contracting Entity that you may be employed or engaged by;

4.2.2 to optimise the use and performance of our Services;

4.2.3 to send you general (non-marketing) commercial communications, such as information about the Services;

4.2.4 to provide customer service in relation to your use of our Services, to contact you, to deal with enquiries relating to use of our Services and to notify you about changes to our Services; and

4.2.5 to provide third parties with statistical information about our users but this information will not be able to be used to identify any individual user.

5. Disclosure of your information

5.1 Other than as expressly set out in this privacy policy or as otherwise required or permitted by law, we will not share, sell or distribute any of the information you provide to us without your consent.

5.2 We may disclose your personal information to:

5.2.1 your Contracting Entity;

5.2.2 any third party to whom disclosure is necessary to enable us to provide you with any services that you have requested (e.g. if you request approval of a purchase order from a third party);

5.2.3 in respect of Digital Production Office, our software partner LeBog Software GmbH in order to provide access to Digital Purchase Order services;

5.2.4 our parent company and other group companies, in relation to setup, support, maintenance and other services, this information may include name, demographic details, contact details, financial information, and other associated information;  and

5.2.5 any person to whom disclosure is necessary to enable us to enforce our legal rights, or to protect the rights, property or safety of our employees or where such disclosure may be permitted or required by law.

6. Cookies

6.1 We use cookies to ensure that you get the most out of the Services. Cookies are small amounts of information in the form of text files which we store on the device you use to access the Services. Cookies allow us to monitor your use of the software and simplify your use of the Services. For example, a temporary cookie is also used to keep track of your “session”. Without that temporary cookie (which is not stored after you quit your browser) you would have to log on every time you access a new page.

6.2 If you do not wish for cookies to be installed on your device, you can change the settings on your browser or device to reject cookies. For more information about how to reject cookies using your internet browser settings please consult the “Help” section of your internet browser (or alternatively visit http://www.aboutcookies.org). Please note that, if you do set your Internet browser to reject cookies, you may not be able to access all of the functions of the Services and your experience may be less satisfying without using cookies.

6.3 The names of the cookies used by the Services and the purposes for which these cookies are used are set out in the table below:

7. Security and data retention

7.1 We employ appropriate technological and operational security measures to protect against any unauthorised access to or any unlawful processing of any personal information about you that we hold. We will retain your information for as long as is necessary to provide any services to you, your Contracting Entity or for a reasonable period or as long as the law otherwise permits.

7.2 Data transmission over the internet is inherently insecure, and although we employ appropriate technological and organisational security measures to protect your data from unauthorised access we cannot guarantee the security of any data sent over the internet.

8. International data transfers

8.1 The personal information that we collect may be transferred to, and stored at, a destination outside the EEA or the UK, including countries, which have less strict, or no data protection laws, when compared to those in the EEA or the UK.

8.2 Whenever we transfer your information as described in the paragraph above, we will take steps which are reasonably necessary to ensure that adequate safeguards are in place to protect your personal information and to make sure it is treated securely and in accordance with this privacy policy. In these cases, we rely on approved data transfer mechanisms (such as standard contractual clauses) to ensure your information is subject to adequate safeguards in the recipient country. If you are located in the UK or the EEA, you may contact us for a copy of the safeguards which we have put in place to protect your personal information and privacy rights in these circumstances.

9. Legal Basis For Processing Your Personal Information

9.1 We will only process your personal information where we have a legal basis to do so. The legal basis will depend on the purposes for which we have collected and use your personal information. In almost every case the legal basis will be one of the following:

– Consent: For example, where you have provided your consent to receive certain marketing from us. You can withdraw your consent at any time, including by clicking on the “unsubscribe” link at the bottom of any marketing email we send you.

– Our legitimate business interests: Where it is necessary for us to understand our customers, promote our services and operate effectively as a provider of payroll, production accounting and production management services, provided in each case that this is done in a legitimate way which does not unduly affect your privacy and other rights.

– Performance of a contract with you (or in order to take steps prior to entering into a contract with you): For example, where we need to use your personal data in order to comply with our obligations under our Terms of Use.

– Compliance with law: Where we are subject to a legal obligation and need to use your personal information in order to comply with that obligation.

10. Your Rights

10.1 You have certain rights in relation to your personal information. These include: the right to object to the processing of your information for certain purposes, the right to access your personal information, and the ability to erase, restrict or receive a machine-readable copy of your personal information.

10.2 We will handle any request to exercise your rights in accordance with applicable law and any relevant legal exemptions. If you wish to exercise any of these rights please contact us using the contact above.

10.3 You may also have the right to complain to a data protection authority if you think we have processed your personal information in a manner which is unlawful or breaches your rights. If you have such concerns we request that you initially contact us (using the contact details above) so that we can investigate, and hopefully resolve, your concerns.

11. Changes to this privacy policy

11.1 We reserve the right to make changes to this privacy policy from time to time. Any such changes to this privacy policy will be posted to our website and if we consider it to be appropriate we will notify you of any material changes by e-mail. Any changes will come into effect the next time you use the Services after the changes have been notified. The date this privacy policy was last updated is set out below:

Date last updated: 14 January 2022