Privacy and Cookie Policy Introduction Hello. We’re Sabio. We are committed to respecting your privacy and protecting your personal data. Sabio is made up of different trading companies, details of which can be found below. This privacy notice is issued on behalf of the Sabio Group, so when we mention “Sabio”, “we” “us” or “our” in this privacy notice, we are referring to the relevant company in the Sabio Group responsible for processing your data. Sabio Ltd is the controller and responsible for this website. This privacy and cookie policy (“privacy policy”) will inform you as to how we use, share and look after your personal data when you visit our websites (regardless of where you visit from), and which we may receive from other sources, and tell you about your privacy rights and how the law protects you. If you have questions regarding this privacy policy, including any requests to exercise your legal rights, please contact: The Legal Department Sabio Ltd 12th floor, Blue Fin Building, 110 Southwark Street, London, SE1 0SU Email: dataprotection@sabio.co.uk For the purposes of the General Data Protection Regulation, the lead supervisory authority for the Sabio Group is the Information Commissioner’s Office (ICO) in the UK. You have the right to make a complaint at any time to the ICO, but we would appreciate the chance to deal with your concerns before you approach the ICO, so please approach us in the first instance. Collection of Information Personal data, or personal information, 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). Website On each of your visits to our website, you agree that we may automatically collect the information below. We do this by using cookies, server logs and similar technologies. (Our cookie policy is set out below):
  • Technical data, including the internet protocol (IP) address used to connect your computer to the internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and
  • Profile and usage data including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time), information you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks and mouse-overs), and methods used to browse away from the page.
In order to access and use certain content on the website (including without limitation Sabio’s brochures, white papers, reports, ebooks, case studies, events and webinars) (together “Content”) we require you to provide us with:
  • Identity Data including your first name, last name and title; and
  • Contact Data including your postal address, email address and telephone numbers.
  • Marketing and Communications Data including your preferences in receiving marketing from us and your communication preferences.
If you apply for a job vacancy with us using our online application form, we require you to provide us with:
  • Identity Data including your first name, last name and title; and
  • Contact Data including your postal address, email address and telephone numbers.
  • Profile Data including your preferences for contact from us regarding future job vacancies, your current salary information, and the information contained in your CV and covering letter.
You may also give us information about you if you report any problems with the website. Third parties We may receive personal data about you from various third parties:
  • We receive Technical Data from analytics providers (such as Google Analytics) as set out in our Cookies policy below; and
  • We receive Identity Data and Contact Data from a data analyst – ContactBabel Limited.
We do not collect any sensitive personal data (also known as 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, genetic or biometric data). We don’t collect any information criminal convictions or offences. As we only sell products and services to other businesses, this website is not intended for children or individual consumers and we do not knowingly collect data relating to children or individual consumers. Use of Personal Data Most commonly, we will use your Personal Data in the following ways:
  • Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data. We have set out below, a description of all the ways we plan to use your personal data and which of the legal bases we rely on to do so:
Purpose/activity Type of data (described in more detail above) Lawful basis for processing personal data including basis of legitimate interest
To deliver website content to you when you have requested it from us. Identity Data Contact Data Marketing and Communications Data We have a legitimate interest in understanding the products and services prospective customers may be interested in, in order to develop our products and services.
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences Technical Data Profile and Usage Data We have a legitimate interest in defining types of customers for our products and services, to keep our websites updated and relevant, to develop our business and to inform our marketing strategy.
Marketing – to contact you about products, services and/or events which may be of interest to you* Identity Data Contact Data Profile Data We have a legitimate interest in developing our products and services and growing our business.
To register you as an applicant for a job vacancy and to process your application. Note: We use software to make automated decisions about your application (such as if you have applied for a role which requires travel and you have indicated that you are unwilling to travel, your application may automatically be rejected). Identity Data Contact Data Profile and Usage Data (a)        We have a legitimate interest in processing your application. (b)        If your application is successful, we will use your personal data to fulfil our legal obligations as an employer.
To administer our websites and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes. Profile Data We have a legitimate interest in administering our website and optimising its functionality.
  *If you do not want us to use your Personal Data in this way, you may contact us at marketing@sabio.co.uk to stop receiving marketing information from us. If you opt-out of receiving marketing information, this will not apply to our use of your personal data for the other purposes set out above. Sabio may disclose aggregate statistics about our Website visitors, customers and sales in order to describe our services to prospective partners, advertisers and other reputable third parties and for other lawful purposes, but these statistics will include no Personal Data. 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 at dataprotection@sabio.co.uk . 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. Disclosure of your personal data We may also share your personal data with any members of the Sabio Group for the purposes, and using the legal bases, set out above. Additionally we may share your Personal Data with the following selected third parties: analytics, search engine providers and other service providers that assist us in the improvement, operation and optimisation of our site. International transfers As we may share your personal data within the Sabio Group, this may involve transferring your data outside the European Economic Area (EEA). Whenever we transfer your personal data outside of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
  • we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
  • we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
  • where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
Data security Sabio has technological and operational security procedures in place which are designed to protect your personal data from loss, misuse, alteration or unintentional destruction. In addition, we limit access to your personal data to those employees, other staff and third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. Data retention The personal data you provide to us will be retained only for as long as necessary to fulfil the purposes for which the information was collected or as required by law. Thereafter, Sabio may destroy or delete the personal data or other information, or remove the means by which the personal data or other information can be associated with you, unless its retention is required to satisfy legal, regulatory, accounting or other business requirements. Your legal rights Under certain circumstances, you have rights under data protection laws in relation to your personal data: Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. Object to processing of your personal data where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. You also have the right to not to be subject to a decision about you based solely on automated processing, which produces legal effects concerning you (or similarly significantly affects you). Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. If you wish to exercise any of the rights set out above, please contact dataprotection@sabio.co.uk You will not normally have to pay a fee to access your personal data (or to exercise any of the other rights stated above), although we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of the other rights stated above). 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. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. Use of Cookies The website uses “cookies,” which are small files that the website places on your hard drive for identification purposes. A cookie is a piece of data that a website can send to your browser, which may then be stored on your computer or mobile device as an anonymous tag that identifies your computer but not you. Cookies are used to better serve you when you return to the website. You should note that cookies cannot read data on your hard drive. There are different types of cookies which are used to do different things. These include allowing you to navigate between pages on a website or the cookie remembers your preferences. Other cookies measure the number of visits and the most popular pages users visit on a particular website. Some cookies are session cookies which expire when you have finished your visit to a website and others are persistent cookies which will remain on your browser for a period of time. The information below explains more about the cookies we use and why we use them. When you visit the Website for the first time you will see a notice which informs you that the Website uses cookies. You may choose to accept or decline cookies. Simply click the ‘ok’ button to accept the use of Cookies. Most web browsers and devices can be set to notify you when you receive a cookie and you may prevent cookies from being sent by modifying your browser settings; if you do so, you may limit the functionality we can provide you when you visit our Website. Some of our business partners (e.g., tracking utility services) use cookies on our Website: Google Analytics Google Analytics is a web analytics service provided by Google, Inc. Google Analytics sets a cookie in order to evaluate your use of this website and compile reports for us on overall activity. Google stores the information collected by the cookie on servers in the United States. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. http://www.google.com/intl/en/policies/privacy/ ShareThis ShareThis offers online services and applications that allow users to share content on the Web more easily. They are based in the United States, based in Palo Alto, CA, with offices in New York and Cincinnati. See more at: http://sharethis.com/about/ In addition to the sharing service offered directly to users, the technology used to assist with user sharing also allows ShareThis to gather information, and enables ShareThis and their partner publishers and advertisers to use the value of the shared content and other information gathered through our technology to facilitate the delivery of relevant, targeted advertising. http://sharethis.com/privacy-manifesto LivePerson LivePerson is a publicly held American technology company that develops products for online messaging, marketing, and analytics, headquartered in New York City. The cookie is used so that your chat can continue across pages while you browse the site. https://www.liveperson.com/uk/policies/terms-of-use SalesGenius by CallidusCloud SalesGenius offers a SaaS based Sales and Marketing solution headquartered in Dublin, California. Cookies are used for form filling and for email tracking. https://www.calliduscloud.com/privacy-policy#3 Vimeo Vimeo offers an online video sharing platform and community through its website and is based in New York City, with offices in both Manhattan and Brooklyn, and additional offices in India and the Ukraine. Vimeo uses cookies on the embedded video playing on the Sabio website. https://vimeo.com/cookie_policy EasyWeb ATS EasyWeb ATS is a division of EasyWeb Group, a company dedicated to streamlining the recruitment process and is based in Northamptonshire, UK. EasyWeb ATS uses cookies on the Sabio website for the application of current vacancies. http://www.easywebgroup.co.uk/privacypolicy/ SessionCam SessionCam allows quick and easy identification of conversion problems by allowing an accurate visualization of customer behaviour. SessionCam is a privatley held company based in Norwich, UK. https://sessioncam.com/privacy-policy-cookies/ Further information If you would like further information on the use of cookies you may wish to visit www.allaboutcookies.org or review information on the categorisation of cookies which has been developed by the International Chamber of Commerce. Third party websites Any third party websites which you can link to via our website are not covered by this privacy policy and Sabio accepts no responsibility or liability for the use and protection of any information which you provide to such third party websites. You should exercise caution and read the privacy policy of the relevant third party website before providing any information (including any personal data). Group companies The following companies are the trading companies in Sabio Group:
Sabio Ltd (UK) Datapoint Global Services BV (NL)
Bright UK Limited (UK) Datapoint Global Services srl (IT)
Sabio Solutions (Singapore) Pte Ltd (SIN) Datapoint Global Services GmbH (GE)
Datapoint Iberica SA (ES) Datapoint Global Services SAS (FR)