1 INTRODUCTION 

1.1 Important information and who we are 

Welcome to SilkFlo’s Privacy and Data Protection Policy (“Privacy Policy”). 

At SilkFlo (“we”, “us”, or “our”) we are committed to protecting and respecting your privacy and  Personal Data in compliance with the United Kingdom General Data Protection Regulation (“ GDPR”), the Data Protection Act 2018 and all other mandatory laws and regulations of the  United Kingdom. 

This Privacy Policy explains how we collect, process and keep your data safe. The Privacy Policy  will tell you about your privacy rights, how the law protects you, and inform our employees  and staff members of all their obligations and protocols when processing data. 

The individuals from which we may gather and use data can include: 

Customers 

Suppliers 

Business contacts 

Employees/Staff Members 

Third parties connected to your customers 

and any other people that the organisation has a relationship with or may need to contact. 

This Privacy Policy applies to all our employees and staff members and all Personal Data  processed at any time by us. 

1.2 Who is Your Data Controller

SilkFlo is your Data Controller and responsible for your Personal Data. We are not obliged by  the GDPR to appoint a data protection officer and have not voluntarily appointed one at this  time. Therefore, any inquiries about your data should either be sent to us on email at  [email protected] or sent in a letter to . 

You have the right to make a complaint at any time to the Information Commissioner’s Office  (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would,  however, appreciate the chance to deal with your concerns before you approach the ICO so  please contact us in the first instance. 

1.3 Processing Data on Behalf of a Controller and Processors’ responsibility to you 

In discharging our responsibilities as a Data Controller we have employees who will deal with  your data on our behalf (known as “Processors”). Therefore, the responsibilities described  below may be assigned to an individual, or may be taken to apply to the organisation as a  whole. The Data Controller and our Processors have the following responsibilities: 

Ensure that all processing of Personal Data is governed by one of the legal bases laid  out in the GDPR (see 2.2 below for more information on those bases); 

Ensure that Processors authorised to process Personal Data have committed  

themselves to confidentiality or are under an appropriate statutory obligation of  confidentiality; 

Implement appropriate technical and organisational measures to ensure a level of  security appropriate to the risk associated with the processing of Personal Data; 

Obtain the prior specific or general authorisation of the Controller before engaging  another Processor; 

Assist the Controller in the fulfilment of the Controller’s obligation to respond to  requests for exercising the data subject’s rights; 

Make available to the Controller all information necessary to demonstrate compliance  with the obligations laid down in the GDPR and allow for and contribute to audits,  including inspections, conducted by the Controller or another auditor mandated by the  Controller; 

Maintain a record of all categories of processing activities carried out on behalf of a  Controller; 

Cooperate, on request, with the supervisory authority in the performance of its tasks; 

Ensure that any person acting under the authority of the Processor who has access to  Personal Data does not process Personal Data except on instructions from the  

Controller; and 

Notify the Controller without undue delay after becoming aware of a Personal Data  Breach; 

2 LEGAL BASIS FOR DATA COLLECTION 

2.1 Types of Data / Privacy Policy Scope

Personal Data” means any information about an individual from which that person can be  identified. It does not include data where the identity has been removed (anonymous data). 

We may collect, use, store and transfer different kinds of Personal Data about you which we  have grouped together below. Not all of the following types of data will necessarily be  collected from you but this is the full scope of data that we collect and when we collect it from  you: 

Profile/Identity Data: This is data relating to your first name, last name, gender, date of  birth. 

Contact Data: This is data relating to your phone number, addresses, email addresses,  phone numbers. 

Marketing and Communications Data: This is your preferences in receiving marketing  information and other information from us. 

Billing Data: This is information relating to your debit and credit card information such  as the name attached to your payment details and your billing address. 

Financial Data: These are your banking details e.g. your account number and sort code. 

Transactional Data: This is information of details and records of all payments you have  made for our services or products. 

We also collect, use and share Aggregated Data such as We also collect use and share  Aggregated Data such as that partaining to the automation of business processes and related  metrics.. Aggregated Data could be derived from your Personal Data but is not considered  Personal Data in law as this data will not directly or indirectly reveal your identity. However, if  we combine or connect Aggregated Data with your Personal Data so that it can directly or  indirectly identify you, we treat the combined data as Personal Data which will be used in  accordance with this Privacy Policy. 

We may also aggregate data to enable research or analysis so that we can better understand  and serve you and others. For example, we may conduct research on your demographics and  usage. Although this aggregated data may be based in part on Personal Data, it does not  identify you personally. We may share this type of anonymous data with others, including  service providers, our affiliates, agents and current and prospective business partners. 

We do not collect any Special Categories of Personal Data about you (this includes details  about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation,  political opinions, trade union membership, information about your health, and genetic and  biometric data). Nor do we collect any information about criminal convictions and offences. 

2.2 The Legal Basis for Collecting That Data 

There are a number of justifiable reasons under the GDPR that allow collection and processing  of Personal Data. The main avenues we rely on are: 

Consent”: Certain situations allow us to collect your Personal Data, such as when you  tick a box that confirms you are happy to receive email newsletters from us, or ‘opt in’ to  a service. 

Contractual Obligations”: We may require certain information from you in order to  fulfil our contractual obligations and provide you with the promised service.

Legal Compliance”: We’re required by law to collect and process certain types of data,  such as fraudulent activity or other illegal actions. 

Legitimate Interest”: We might need to collect certain information from you to be able  to meet our legitimate interests – this covers aspects that can be reasonably expected as  part of running our business, that will not have a material impact on your rights,  

freedom or interests. Examples could be your address, so that we know where to  deliver something to, or your name, so that we have a record of who to contact moving  forwards. 

3 HOW WE USE YOUR PERSONAL DATA 

3.1 Our Uses 

We will only use your Personal Data when the law allows us to. Set out below is a table  containing the different types of Personal Data we collect and the lawful basis for processing  that data. Please refer to section 2.2 for more information on the lawful basis listed in the  table below. 

Examples provided in the table below are indicative in nature and the purposes for which we  use your data may be broader than described but we will never process your data without a  legal basis for doing so and it is for a related purpose. For further inquiries please contact us. 

3.2 Marketing and Content Updates 

You will receive marketing and new content communications from us if you have created an  account and chosen to opt into receiving those communications. From time to time we may  make suggestions and recommendations to you about goods or services that may be of  interest to you. 

3.3 Change of Purpose 

We will only use your Personal Data for the purposes for which we collected it, unless we  reasonably consider that we need to use it for another reason and that reason is compatible  with the original purpose. If you wish to get an explanation as to how the processing for the  new purpose is compatible with the original purpose, please contact us. 

If we need to use your Personal Data for an unrelated purpose, we will notify you and we will  explain the legal basis which allows us to do so. 

Please note that we may process your Personal Data without your knowledge or consent, in  compliance with the above rules, where this is required or permitted by law. 

4 YOUR RIGHTS AND HOW YOU ARE PROTECTED BY US 

4.1 What Control Do I Have Over SilkFlo’s Use Of My Personal Data? 

You may delete your account at any time – this will remove your account page from our systems and our related software. 

We guarantee this will delete all stored data.

Your account information will be protected by a password for your privacy and security. You  need to prevent unauthorized access to your account and personal information by selecting  and protecting your password appropriately and limiting access to your computer or device  and by signing off after you have finished accessing your account. 

You can access information associated with your account by logging into your account you  created with us. 

Your account information will be protected by a password for your privacy and security. You  need to prevent unauthorized access to your account and personal information by selecting  and protecting your password appropriately and limiting access to your computer or device  and by signing off after you have finished accessing your account. 

California Privacy Rights: Under California Civil Code sections 1798.83-1798.84, California  residents are entitled to ask us for a notice identifying the categories of personal customer  information which we share with our affiliates and/or third parties for marketing purposes,  and providing contact information for such affiliates and/or third parties. If you are a California  resident and would like a copy of this notice, please submit a written request to  [email protected] 

4.2 How Does SilkFlo Protect Customers’ Personal Data? 

We are concerned with keeping your data secure and protecting it from inappropriate  disclosure. We implement a variety of security measures to ensure the security of your  Personal Data on our systems, including We implement certain security measures to ensure  the security of your Personal Data on our systems, including adopting a secure protocol and  encrypting our databases.. Any Personal Data collected by us is only accessible by a limited  number of employees who have special access rights to such systems and are bound by  obligations of confidentiality. If and when we use subcontractors to store your data, we will not  relinquish control of your Personal Data or expose it to security risks that would not have  arisen had the data remained in our possession. However, unfortunately no transmission of  data over the internet is guaranteed to be completely secure. It may be possible for third  parties not under the control of SilkFlo to intercept or access transmissions or private  communications unlawfully. While we strive to protect your Personal Data, we cannot ensure  or warrant the security of any Personal Data you transmit to us. Any such transmission is done  at your own risk. If you believe that your interaction with us is no longer secure, please contact  us. 

4.3 Opting Out Of Marketing Promotions 

You can ask us to stop sending you marketing messages at any time by You can ask us to stop  sending you marketing messages at any time by clicking Unsubscribe.. 

Where you opt out of receiving these marketing messages, we will continue to retain other  Personal Data provided to us as a result of interactions with us not related to your marketing  preferences. 

4.4 How to Request your Data and the Process for Obtaining it 

You will not have to pay a fee to access your Personal Data (or to exercise any of the other  rights). However, if your request is clearly unfounded, we could refuse to comply with your  request.

We may need to request specific information from you to help us confirm your identity and  ensure you have the right to access your Personal Data (or to exercise any of your other  rights). This is a security measure to ensure that Personal Data is not disclosed to any person  who has no right to receive it. We may also contact you to ask you for further information in  relation to your request to speed up our response. 

5 YOUR DATA AND THIRD PARTIES 

5.1 Will We Share Your Data With Third Parties? 

We may share non-Personal Data with third parties. We may share your Personal Data with  subcontractors (only when necessary and with your consent) or affiliates (subject to  confidentiality obligations to use it only for the purposes for which we disclose it to them and  pursuant to our instructions). 

We may also share Personal Data with interested parties in the event that SilkFlo anticipates a  change in control or the acquisition of all or part of our business or assets or with interested  parties in connection with the licensing of our technology. 

If SilkFlo is sold or makes a sale or transfer, we may, in our sole discretion, transfer, sell or  assign your Personal Data to a third party as part of or in connection with that transaction.  Upon such transfer, the Privacy Policy of the acquiring entity may govern the further use of  your Personal Data. In all other situations your data will still remain protected in accordance  with this Privacy Policy (as amended from time to time). 

We may share your Personal Data at any time if required for legal reasons or in order to  enforce our terms or this Privacy Policy. 

5.2 Third-Party Links 

This Site may include links to third-party websites, plug-ins and applications. Clicking on those  links or enabling those connections may allow third parties to collect or share data about you.  We do not control these third-party websites and are not responsible for their privacy  statements. When you leave our Site, we encourage you to read the privacy policy of every  website you visit. 

6 HOW LONG WILL WE RETAIN YOUR DATA FOR? 

We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we  collected it for. We may retain your Personal Data for a longer period than usual in the event of a  complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship  with you. 

7 AGE LIMIT FOR OUR USERS 

You must not use SilkFlo unless you are aged 16 or older. If you are under 16 and you access SilkFlo  by lying about your age, you must immediately stop using SilkFlo. 

This website is not intended for children and we do not knowingly collect data relating to children. 

8 INTERNATIONAL TRANSFER OF DATA

Your information may be stored and processed in the US or other countries or jurisdictions outside  the US where SilkFlo has facilities. We are currently storing data in the EU and so, by using SilkFlo, you  are permitting and consenting to the transfer of information, including Personal Data, outside of the  US. 

9 NOTIFICATION OF CHANGES AND ACCEPTANCE OF POLICY 

We keep our Privacy Policy under review and will place any updates on this webpage. This version is  dated 1 April 2021. By using SilkFlo, you consent to the collection and use of data by us as set out in  this Privacy Policy. Continued access or use of SilkFlo will constitute your express acceptance of any  modifications to this Privacy Policy. 

10 INTERPRETATION 

All uses of the word “including” mean “including but not limited to” and the enumerated examples  are not intended to in any way limit the term which they serve to illustrate. Any email addresses set  out in this policy may be used solely for the purpose for which they are stated to be provided, and  any unrelated correspondence will be ignored. Unless otherwise required by law, we reserve the  right to not respond to emails, even if they relate to a legitimate subject matter for which we have  provided an email address. As a matter of common sense, you are more likely to get a reply if your  request or question is polite, reasonable and there is no relatively obvious other way to deal with or  answer your concern or question (e.g. FAQs, other areas of our website etc.). 

Our staff are not authorised to contract on behalf of SilkFlo, waive rights or make representations  (whether contractual or otherwise). If anything contained in an email from a SilkFlo address  contradicts anything in this policy, our terms or any official public announcement on our website, or  is inconsistent with or amounts to a waiver of any SilkFlo rights, the email content will be read down  to grant precedence to the latter. The only exception to this is genuine correspondence expressed to  be from the SilkFlo legal department.