Privacy Policy

This privacy policy (policy) informs you about how Anneal Ltd (we, us or Anneal) look after your personal data when you interact with us as one of our customers or suppliers (or as an employee or representative of same), visit us at our premises, visit or use our websites (regardless of where you visit them from) (our websites), including software applications such as the Anneal platform for engineering project, knowledge and communication management (Anneal), which you may access and use on a software as a service basis (being the Software Services). Any data that is collected through Anneal, or through the general provision of other paid services (the Services), shall be known as the Customer Data, and any data collected specifically through Anneal known as the Anneal Data.

It also informs you about how we will look after your personal data, and about your privacy rights and how the law protects you. It does not cover any third party website you have used to access our websites or the Software Services or any third party websites that you access from them.

It applies to all processing of personal data undertaken by Anneal, other than the processing of personal information in the context of recruitment and employment, which is dealt with under separate internal policies.

It is important that you read this policy so that you are fully aware of how and why we are using your data.

This policy also includes the general cookies and similar technologies policy for the Anneal website at Appendix 1 below, and our cookies and similar technologies policy in relation to the Anneal platform, at Appendix 2 below.

Before using the Services, you individually, or acting on behalf of the company who has paid for access to the Services, will need to have agreed to our standard customer terms.

If you are accessing Anneal you will also be required to agree to this policy, and to the terms of our separate end-user licence agreement (EULA) for individual users of Anneal.

WHO WE ARE

1. Contact Details

Our full details are:

Full Name of Legal Entity: Anneal Ltd, a company incorporated in Northern Ireland under registered company number NI674418

Postal Address: Unit 582 Moat House, 54 Bloomfield Avenue, Belfast, BT5 5AD

ICO Registration Number: ZB180307 (this is the number under which we are registered with the UK Information Commissioner’s Office as a fee paying data controller).

1.1 Under the UK General Data Protection Regulation or the EU General Data Protection Regulation (collectively GDPR) and other relevant data protection legislation, we act as both a data controller (i.e., where we make decisions) in relation to your personal data that we collect, as well as a data processor (i.e., where we process data broadly in accordance with your instructions).

When we act as a Data Processor: When as a user you use the Software Services to process personal data, or we process personal data on your behalf, whether through our provision of the Services to you or otherwise, we act as a data processor. Under these circumstances, the user may act as a data controller or data processor itself, and we will act as either a processor or a sub-processor. Whenever we act as a processor, or a sub-processor, we will be restricted in the manner and purpose for which we can use personal data (including where applicable in the manner outlined in this policy) and we will also be subject to other obligations under data protection legislation. However, the data controller is likely to be the company which has subscribed for our Software Services and controls the purposes for which the Anneal Data is processed.

When we act as a Data Controller: By contrast, when we collect personal data and determine the purposes and means of processing that personal data – for example, when we store account information for Anneal user account registration, administration, services access, or contact information as explained below – we act as a data controller.

1.2 Third-Party Links

Our websites and the Software Services may include links to third-party websites, widgets, plug-ins and applications (including various social media platforms). Clicking on those links or enabling those connections may allow third parties to collect or share data about you or allow you to import data from those third party applications or websites into the Anneal platform.

We do not control these third-party websites or applications and are not responsible for their privacy statements, although we have attempted to provide some high level details in relation to third party platforms with which our websites integrate in Appendix 2. When you leave our website or application, we encourage you to read the privacy policy of every third party website or application you visit.

2. WHAT KIND OF PERSONAL DATA DO ANNEAL PROCESS?

INFORMATION YOU SUPPLY TO US

2.1 General personal data - This is personal information about you that you share with us by online forms on our website, through email, through the post, on the telephone, when you register to use the Software Services, when you complete customer surveys, engage with our customer services team, engage Anneal to provide Services or by any other means.

Typically, when you generally interact with Anneal you may provide information about yourself, as well as other data about your business, including your full name, job title, billing address, business name, personal and/or business email address, telephone and/or mobile phone number and other contact details. You may provide similar information where you contact us or sign up to our newsletter.

Anneal Data:

When you sign up to use the Software Services you will be required to provide your name and email address, alongside other non-personal details. When using the Software Services you may also (but are not required to) upload other personal data relating to yourself or others, and will provide personal data when you report any technical or service issues in relation to our websites or Anneal, including relevant notes about any issues and how we responded to resolve these, as well as details of any payments you have made through our websites.

2.2 Financial Details: Where you are a supplier and provide us with your financial details in order to facilitate payments by us to you, we may collect financial details.

Financial details of our customers include credit card numbers, sort codes and account numbers and billing information, which we collect and process using third party PCI-compliant service providers. Such service providers are not permitted to store, retain, or use information you provide except for the sole purpose of credit card processing on our behalf.

Where you have separately provided us with your bank account details in order to facilitate payments by us to you these will be kept securely.

2.3 Verbal Information: If you provide verbal personal information that you give us consent to use you will have such consent confirmed back to you in writing.

2.4 Marketing Information: You may also communicate your preferences in receiving marketing from us and our third parties and your communication preferences (including details you provide when you opt-in to receive marketing communications from us).

2.5 Third Party Data: Where you are sharing personal data that does not directly relate to you (e.g. your representatives that legally act on your behalf), including where you use third party websites or applications to import detail into the Anneal platform, you must ensure you have the consent to do so and have shared this policy with that person/those people, including where you are acting to register other individuals on their behalf, and in accepting this policy and our associated terms of service for businesses (Terms of Service) and EULA for individual users, you accept and acknowledge on behalf of both yourself and the business on whose behalf you are using Anneal that you will do so.

IF YOU FAIL TO PROVIDE PERSONAL DATA

2.6 Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with products). In this case, we may not be able to fulfil any order you place with us, but we will notify you if this is the case at the time.

PERSONAL DATA WE COLLECT

2.7 Telephone Recordings - Telephone conversations may be recorded to for training or monitoring purposes.

2.8 CCTV Footage – We may use CCTV cameras on our premises and may record footage of you where you attend our premises in person, and use such footage as required in our legitimate interests, including to ensure the safety and well-being of our staff.

2.9 Technical Data from our Websites: We use certain technical services to gather technical data online whenever you use our websites including information about your device and your visits to our websites such as your IP address, geographical location, browser type, referral source, length of visit and pages viewed. Please see our cookies and similar technologies policy in Appendix 1 below for further details.

You are not personally identifiable from any of the technical data we collect using such services.

2.10 Technical Data from our Websites or Anneal: We also use certain technical services to gather certain technical and all usage data whenever you use Anneal, as detailed below:

Anneal

Specifically, any login data will be collected only via AuthO, a third party service authentication and authorisation provider, which captures details about login attempts. If you successfully login you will be personally identifiable from any such data, as it will be tied to your Anneal user account.

Please see our cookie and similar technologies policy in relation to Anneal in Appendix 2 below for further details.

PERSONAL DATA WE RECEIVE FROM THIRD-PARTIES

2.11 Social Media: publicly available information through social media sites, such as Facebook, LinkedIn, Twitter and Google. This includes where you have responded to a promotional item or offer from us through social media facilities, in which case we may receive profile information about you which can include your name, address, telephone number(s) and/or your business contact details. This information would be used to respond to your interest, to fulfil a request from you and/or to send you future information and offers, where you have given clear consent to do so.

2.12 Publicly Available Information: As a general Anneal customer, we may collect personal information about you from other publicly available sources. This can include your name, address and other publicly available information. As far as passible, we ensure that where any third-parties are involved in suppling such information, that they are compliant to do so. This may include credit reference agencies such as Experian, public registers such as the Companies House registry or the Electoral Register. You hereby consent to our collecting and storing all such data about you.

2.13 Anneal: Through the Software Services, users may collect, store and process personal data about you. We have requested that no Special Categories of personal data are collected through the Software Services, but otherwise we do not control or monitor users use or processing of personal data through the Software Services.

IMPORTANT – PLEASE NOTE: Our Terms of Service require users to refrain from uploading or processing any data using the Software Services in violation of applicable laws, including not to process any personal data without valid legal grounds, not to process any sensitive or special categories of data (such as financial information, medical data, information about religious or political affiliations etc) and not to infringe any third party’s other rights using the Software Services.

We require all of users to agree to adhere to these terms at all times, but do not actively monitor content uploaded or processed using the Software Services, and are not responsible for enforcing those terms. If you are reviewing this policy because you believe your or your organisation’s data has been used in violation of those terms, please contact us.

2.14 Other: from time to time, we may receive personal information from other sources. We will always endeavour to ensure such information is provided from reputable sources, who are GDPR compliant to do so.

KEEPING YOUR PERSONAL DATA UP TO DATE

2.15 It is important that the data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

3. WHAT INFORMATION IS NOT COLLECTED?

3.1 We do not intentionally collect sensitive personal data or special category data (including details about your race or ethnicity, religious or philosophical beliefs, medical information, sex life, sexual orientation, political opinions, trade union membership, genetic and biometric data, social security numbers). Nor do we collect any information about criminal convictions and offences.

3.2 As noted above, our Terms of Service include restrictions on any of users using the Software Services to collect such data (or financial information) but as noted we do not proactively monitor this and cannot be held responsible where users breach these restrictions.

3.3 If you're a child under the age of 16 (or are otherwise younger than the legal age limit required in the country in which you reside), you may not have a user account on Anneal. Anneal does not knowingly collect information from or direct any of our content specifically to children under relevant ages. If we learn or have reason to suspect that you are a user who meets these criteria, we will unfortunately have to close your user account. Please see our Terms of Service for information about user account termination. If you are a child aged between 16 and 18 using our Services or websites from the UK or European Union, you must have informed your parents or guardians of this, of the terms of this policy, and have their consent to do so.

4. HOW IS INFORMATION USED?

4.1 We will only use your personal data when the law allows us to. Most commonly, we will use your personal data (other than Anneal Data) in the following circumstances:

4.1.1 Where we need to perform the contract we are about to enter into or have entered into with you, to keep internal records for administration purposes related to such contracts, for the purposes contemplated in any separate terms of use for our websites that you have entered into, including for the purposes set out in the “Our Standard Business Operations” section below. This is the ground we rely upon to process Customer Data our customers upload when using our Services.
4.1.2 Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
4.1.3 Where we need to comply with a legal or regulatory obligation.

4.2 We only use Anneal Data in the following circumstances:

4.2.1 To operate, maintain and improve Anneal and its related features.
4.2.2 Where necessary to give you to access Anneal and related features, engage with the content or otherwise interact with Anneal.
4.2.3 To provide technical support or customer service.
4.2.4 To communicate with you about Anneal and any relevant updates.
4.2.5 For the purposes of detection and prevention of fraud or other security incidents.
4.2.6 Where we need to comply with a legal or regulatory obligation.

4.3 Generally, we do not rely on consent as a legal basis for processing your personal data other as set out below in relation to marketing and testimonials. We may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.

4.4 Our Standard Business Operations:

4.4.1 to provide the services and any other responsibilities that we contract to do so with you
4.4.2 To provide you with information that you request from us;
4.4.3 To confirm your identity as a natural living person; and
4.4.4 As part of our billing, payments and recovery processes.

We may also use contact information to notify you of any issues which might impact the provision of our Services to you or on your use of the Software Services.

4.5 Marketing

We maintain multiple contact lists (with email addresses and other information) to allow us to communicate with individuals who do business with us or who have expressed an interest in our Services.

We may contact you to respond to requests that you make, notify you of changes to the Services, for marketing purposes, or to otherwise inform you of information related to our business.

You will only receive marketing communications from us if you have opted to receive them. This includes where you have consented to being contacted by us by email or telephone. You can opt in over the phone, by email, or online.

Where you opt out of receiving marketing messages, this will not apply to personal data (other than Anneal Data) provided to us as a result of your engagement with us to provide Services to you.

We will never sell your personal data to any third party (as noted below).

4.6 Testimonials

We may post customer testimonials and comments on our websites or other platforms, which may contain personal data. We obtain each customer's consent via email prior to posting the customer's name and testimonial.

4.7 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.

4.8 Legal Requirements

We will keep and use your data in terms of any legal or regulatory requirements that we have and can use your data to protect our legal position, if legal action is required, including the recovery of any outstanding debts.

By way of further example, we will share your personal data with the relevant agencies and without notice, where we are requested to or suspect fraudulent activities, money laundering, terrorist related activities.

4.9 Anneal Data

Whilst we may have access to personal data stored on Anneal, i.e., what we call Anneal Data in these terms, we do not process such data otherwise than in accordance with your instructions. It belongs to you or your employer by whom you are authorised to use Anneal, and you are responsible for it, as well as for making sure that your content complies with our Terms of Service.

We do not access any information (including personal data contained in same) you have stored using your Anneal user account unless required to for security or maintenance, or for support reasons, or with the consent of the account owner, or process it other than to store the data securely as described herein, and then delete it as applicable, or as strictly required by law.

4.10 Website Administration and Customisation

We may use the information we collect about you (with the exception of Anneal Data) for a variety of website administration purposes, and customisation purposes. For example, we use your information to process your registration request, provide you with services and communications that you have requested, send you email updates and other communications, customise features and advertising that appear on our websites, deliver our websites content to you, measure Website traffic, measure user interests and traffic patterns, and improve our websites and the services and features offered via our websites.

4.11 Aggregated or Non-Identifying Information

Non-identifying information includes information collected from or about you that does not personally identify you – including aggregated information but excluding any specific Confidential Information (as defined in our Terms of Service). Anneal treats IP addresses, anonymised user tracking data, log file information, user agent strings, computer IDs, and related information as non-identifying information, except if applicable law suggest us to do otherwise.

We may use non-identifying information for any purpose, including combining it with third party data sources (including data obtained from offline sources and data obtained from our users using the Software Services) in our effort to improve the Software Services, or programmatically interrogating such data to improve our Software Services (for example suggesting functionality that may assist in performing particular engineering tasks logged on the platform) or sharing it as noted in Section 5 below.

Certain jurisdictions, including the European Union, may deem IP addresses and/or Unique IDs, to be personal data. Accordingly, for persons in such jurisdictions, our use of Non-Identifying Information as described in this policy should be assumed to include IP address and Unique ID data.

5. WHAT INFORMATION IS SHARED?

5.1 We do not disclose personal data outside Anneal, except in the situations listed in this section or in the section below on Compelled Disclosure, but may have to share your personal data with the categories of data processors or data controllers set out below for the purposes set out in in above or otherwise below:

5.1.1 with HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom or other jurisdictions in which we do business and to whose laws we are subject who require reporting of processing activities in certain circumstances (excluding private Customer Data and Anneal Data – unless we are subject to a Compelled Disclosure);
5.1.2 with third party purchasers, if we buy, sell or merge any business or assets of our business and are required to share data as part of the buying, selling or merger agreement or if our assets are acquired by a third-party, and data is transferred as part of the purchased assets. If any such change happens, we will ensure that it is under terms that preserve the confidentiality of your personal data, and we will notify you on our website or by email before any transfer of your personal data. Any purchaser would be bound by the terms of this policy and our Terms of Service;
5.1.3 with professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services, where they have a need to know same for any of the purposes set out above (excluding private Customer Data and Anneal Data which we would typically not share unless in seeking to understand our legal obligations in connection with any Compelled Disclosure request);
5.1.4 with sub-contractors such as consultancy staff whom we use to deliver the Software Services, facilitate sales activities in specific jurisdictions and assist us with other services relating to the Software Services, where they have a need to know same for any of the purposes set out above;
5.1.5 with reputable and trusted third-parties where we have asked them to contact you on our behalf, where you have given us consent, it is part of our contractual agreement, is a legal requirement or there is clear legitimate interest between us (these services may include sending you email, calling you by telephone, sending you information through the post etc.) (excluding private Customer Data, unless for the limited purposes described above, and Anneal Data);
5.1.6 with specific selected third parties, determined by us, if you breach any agreement with us, including so as to enforce our rights against you, including credit-reference agencies, debt-collection firms or service providers, solicitors or barristers and law enforcement agencies (if applicable) (excluding private Customer Data and Anneal Data); and
5.1.7 with service providers acting as processors based in the European Union or United Kingdom who provide IT and system administration services, including for the performance of our contract with you, as set out below: When we transfer your data to our service providers, we remain responsible for it:

* with email marketing services to send marketing emails where you have opted in to receiving them. You can unsubscribe directly from any mailing list using the unsubscribe links provided within emails (excluding private Customer Data and Anneal Data);
* with processors offering software tools, or EU or UK based external servers (including externally provided original and backup servers), that are used to store personal data provided by you on our behalf (our current servers are maintained by Amazon Web Services, whose privacy policies are available at https://aws.amazon.com/privacy/);
* processing credit card payments, such as Stripe, whose policies are available at: https://stripe.com/gb/privacy; and
* customer support ticketing platform (such as Intercom).

5.2 We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process the minimal personal data required for the specified purposes, in accordance with our instructions, where they have agreed to privacy restrictions similar to our own policy.

5.3 We do not share, sell, rent, or trade personal data with third parties for their commercial purposes.

5.4 We may share the kinds of aggregated, non-personally identifying we collect (as outlined above) with third parties, but that will never include any Confidential Information relating to your organisation’s specific projects, as defined in our Terms of Service.

5.5 We may also share personal data with your permission, so we can perform services you have requested.

6. IS SHARED INFORMATION TREATED DIFFERENTLY?

6.1 The Anneal Data (including your personal data) you contribute may be seen by other users under the corporate licence you have subscribed for with whom you have chosen to share your Anneal user account, and processed by the relevant data controller. If you do not want your personal data to be utilised by third parties, you should not use Anneal.

7. HOW IS MY INFORMATION SECURED?

7.1 Anneal takes all measures reasonably necessary to protect personal data from unauthorised access, alteration, or destruction, maintain data accuracy and help ensure the appropriate use of personal data. We follow generally accepted industry standards to protect the personal data we hold, both during transmission and once we receive it.

7.2 In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to duties of confidentiality.

7.3 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.

7.4 No method of transmission, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security. For more information on the measures we take to secure your personal data, please see our Security Policy.

8. HOW IS INFORMATION COLLECTED AND STORED GLOBALLY?

8.1 Information that we collect will be stored and processed in the United Kingdom in accordance with this policy. However, we understand that we have users from different countries and regions with different privacy expectations and local legal requirements, and we try to meet those needs and requirements.

8.2 We provide the same standard of privacy protection to all our users around the world, regardless of their country of origin or location, and we are proud of the levels of notice, choice, accountability, security, data integrity, access, and recourse we provide. We work hard to comply with the applicable data privacy laws wherever we do business.

Additionally, we require that if our vendors or affiliates have access to personal data, they must comply with applicable data privacy laws, including signing data transfer agreements such as EU standard contractual clause agreements, where required by law.

8.3 In particular:

8.3.1 we provide clear methods of unambiguous, informed consent at the time of data collection, when we do collect your personal data and if applicable. Where consent is not the applicable ground for processing, we will ensure that it has an appropriate ground for processing any personal data (including but not limited to contractual obligation or legitimate interest);
8.3.2 we collect only the minimum amount of personal data necessary, unless you choose to provide more. We encourage you to only give us the amount of data you are comfortable sharing;
8.3.3 we offer you simple methods of accessing, correcting, or deleting the data we have collected; and
8.3.4 we provide our users notice, choice, accountability, security, and access, and we limit the purpose for processing. We also provide our users a method of recourse and enforcement.

9. WHAT HAPPENS IF I HAVE A COMPLAINT?

9.1 If you have concerns about the way Anneal is handling your personal data, please let us know immediately. We want to help and there are several ways available that you can contact us. You may also email us directly at contact@anneal.co.uk with the subject line "Data Privacy". We will endeavour to respond within any timelines required under relevant law.

9.2 If you are a data subject based in the UK or European Union, you may 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), or other competent supervisory authority of an EU member state if the Services are accessed outside the UK but from another EU member state. We would appreciate the chance to deal with your concerns before you approach such bodies so would ask that you please contact us in the first instance.

10. HOW DO YOU RESPOND TO COMPELLED DISCLOSURE REQUIREMENTS?

10.1 Anneal may disclose personal data or other information we collect about you to law enforcement in response to a valid subpoena, court order, warrant, or similar governmental order, or when we believe in good faith that disclosure is reasonably necessary to protect our property or rights, or those of third parties or the public at large.

10.2 In complying with court orders and similar legal processes, Anneal strives for transparency. When permitted, we will make a reasonable effort to notify users of any disclosure of their information, unless we are prohibited by law or court order from doing so, or in rare, exigent circumstances.

11. HOW CAN I ACCESS MY OWN PERSONAL INFORMATION?

If you're already a user, you may access, update, alter, or delete your basic user profile information by editing your user profile or contacting us.

Under certain circumstances, where you are a citizen of the European Union or UK, you have rights under data protection laws in relation to your personal data under GDPR.

You have the right to:

* 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.
* Please 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 (or those of a third party) 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.
* 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.
* Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
* Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, 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.

Where you exercise one of your rights, we may need to request specific information from you to help us confirm your identity and ensure your right to exercise such 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.

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.

12. DATA RETENTION AND DELETION

Personal Data Generally

12.1 We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

12.2 To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

12.3 We will keep your personal data for the term you have consented to, the contracted term between us where there is a legitimate interest for us to remain in contact with you, or for the legally required period, whichever is the longest.

12.4 By law we have to keep basic information about any of our customers (including contact, identity, financial and transaction data) for six years after you cease being a customer for tax purposes. For the purposes of contract administration, we will also store all data as long as the contract you have placed through us endures and for the six year limitation period thereafter in case you raise any claims in relation to any Services you have purchased from us. This section does not apply to your personal data or Anneal Data.

12.5 In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you. Anneal will retain personal data on your behalf whilst either a) valid grounds for processing exist; or b) a maximum of 6 years following termination of your Anneal user account (excluding Anneal Data as noted below).

12.6 If you would like to cancel your Anneal user account and initiate deletion of your personal data, you may do so by contacting us at: contact@anneal.co.uk. As above, we will retain and use your information as necessary to comply with our legal obligations, resolve disputes, maintain security, and enforce our agreements, but barring legal requirements, the timeframe above will be observed for deletion.

Anneal Data

12.7 We will endeavour to delete any Anneal Data no later than 6 months after your corporate account being terminated, or you deleting such Anneal Data using your account. This is to synchronise deletion of such Anneal Data with our data deletion cycles, and to facilitate the potential provision of a service to you (as our customer) that may permit the restoration of your account, or of accidentally deleted Anneal Data, upon request and for payment of a fee. You should not that this is not guaranteed, and that Anneal Data may be, irrevocably, deleted more quickly.

13. HOW DO YOU COMMUNICATE WITH USERS?

13.1 We will use your email address to communicate with you, if you've given us the OK, and only for the reasons you’ve permitted. Emails by default are not disclosed with other users. This will not change how we contact you, as we always utilise your primary email address.

13.2 Depending on your email settings, Anneal may occasionally send notification emails about new features, requests for feedback, important policy changes, or to offer customer support. We also send marketing emails, including ones featuring, services and products offered by our commercial partners, but only with your consent. There's an unsubscribe link located at the bottom of each of the emails we send you.

13.3 Our emails might contain a pixel tag, which is a small, clear image that can tell us whether or not you have opened an email and what your IP address is. We use this pixel tag to make our email more effective for you and to make sure we’re not sending you unwanted email. If you prefer not to receive pixel tags, please opt out of marketing emails.

14. WILL YOUR PRIVACY POLICY CHANGE?

If there are material changes to this policy or in how we use your personal data, we will prominently post such changes prior to implementing the change. We encourage you to periodically review this policy to be informed of how we are collecting and using your information.

We keep this policy under regular review, for example, to reflect changing business circumstances and legal developments.

Although most changes are likely to be minor, it may change and if it does, these changes will be posted on this page and, where appropriate, notified to you when you next log on to use the Services. Otherwise, any changes shall be applicable without further notice.

This version of this policy was last updated on 7th February 2023 and historic versions can be obtained by contacting us.

15. HOW CAN I CONTACT Anneal?

Questions regarding our Privacy Policy or information practices should be directed to us via email to contact@anneal.co.uk.

16. LEGAL

This policy shall be governed by and interpreted in accordance with the laws of Northern Ireland and you irrevocably agree that the courts of Northern Ireland shall have exclusive jurisdiction to settle any dispute which may arise out of, under, or in connection with this policy.

This policy forms part of the EULA.

SCHEDULE 1 – GENERAL COOKIES AND OTHER TECHNOLOGIES POLICY (EXCEPTING ANNEAL)

1. WHAT SPECIFIC TECHNICAL DATA DO ANNEAL COLLECT?

1.1 Our websites use "cookies" and similar technologies, including HTML5 local storage on our websites and when providing the Services. A cookie is a file stored on your device that may be used to identify an individual as a unique user by storing certain personal preferences and user data. Anneal uses cookies and other technologies to identify your device, identify authorised users of the Anneal service, track affiliate referrals, complete online purchases through Anneal's billing system, and similar Website monitoring activities.

1.2 Anneal may also use web beacons, small graphic images or other web programming code (also known as "1x1 GIFs" or "clear GIFs"), which may be included in our web pages and email messages. Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a web page or e-mail can act as a web beacon. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to our websites, to monitor how users navigate our websites, to count how many e-mails that were sent were actually opened or to count how many particular articles or links were actually viewed.

1.3 Anneal may also use embedded scripts on our websites and in connection with the provision of its Services. “Embedded scripts” are programming code designed to collect information about your interactions with a website, such as the links you click on, and may assist our customers in providing us with information used to provide the Services. The code is temporarily downloaded onto your device from our web server, our customer's web server, or a third party service provider, is active only while you are connected to our websites containing the embedded script, and is deactivated or deleted thereafter.

1.4 Your web browser automatically sends information to every website you visit, including ours. For example, our server logs may receive and record information such as the pages you access on our websites, referring URLs, your browser type, your operating system, the date and time of your visit, and the duration of your visit to each page.

1.5 Log file information may also include a user agent string, a series of characters automatically sent with your Internet requests that provide information necessary for smooth Internet communications such as the operating system and browser you used. Similar to an IP address, a user agent string, by itself, does not identify you personally. However, when combined with other information, a user agent string might be used to identify the computer originating a message.

1.6 Anneal may assign your computer or mobile device a unique identification number (Unique ID) based on log file information when you access our websites Anneal may set a cookie on your device containing, amongst other things, the device's Unique ID. Anneal uses information generated from the Unique ID for purposes of improving our Services, primarily our ability to detect fraud. Anneal does not share the Unique ID or any associated data with unaffiliated third parties.

2. WHAT COOKIES / TRACKING CODE ARE USED BY ANNEAL?

2.1 Cookies

2.1.1 Anneal uses cookies to make interactions with our service easy and meaningful. We use cookies (and similar technologies, like HTML5 local storage) to keep you logged in, remember your preferences, and provide information for future development of Anneal.

2.1.2 A cookie is a small piece of text that our web server stores on your computer or mobile device, which your browser sends to us when you return to our site. Cookies do not necessarily identify you if you are merely visiting Anneal; however, a cookie may store a unique identifier for each logged in user. The cookies Anneal sets are essential for the operation of our websites, or are used for performance or functionality. By using our website, you agree that we can place these types of cookies on your computer or device. If you disable your browser or device’s ability to accept cookies, you will not be able to log in or use Anneal’s services.

2.2 Tracking

2.2.1 "Do Not Track" is a privacy preference you can set in your browser if you do not want online services to collect and share certain kinds of information about your online activity from third party tracking services. We do not track your online browsing activity on other online services over time and we do not permit third-party services to track your activity on our site beyond our basic Google Analytics tracking, which you may opt out of. Because we do not share this kind of data with third party services or permit this kind of third party data collection on Anneal for any of our users, and we do not track our users on third-party websites ourselves, we do not need to respond differently to an individual browser's Do Not Track setting.

2.2.2 If you are interested in turning on your browser’s privacy and Do Not Track settings, the Do Not Track website has browser-specific instructions.

2.2.3 Please see our section on email communication to learn about our use of pixel tags in marketing emails.

SCHEDULE 2 – ANNEAL – COOKIES AND OTHER TECHNOLOGIES POLICY

1. WHAT SPECIFIC TECHNICAL DATA DO Anneal COLLECT?

1.1 Our websites use "cookies" and similar technologies, including HTML5 local storage on our websites and when providing Anneal. A cookie is a file stored on your device that may be used to identify an individual as a unique user by storing certain personal preferences and user data. Anneal uses cookies and other technologies to identify your device, identify authorised users of the Anneal service, track affiliate referrals, complete online purchases through Anneal's billing system, and similar Website monitoring activities.

1.3 Your web browser automatically sends information to every website you visit, including ours. For example, our server logs may receive and record information such as the pages you access on our websites, referring URLs, your browser type, your operating system, the date and time of your visit, and the duration of your visit to each page.

1.4 Log file information may also include a user agent string, a series of characters automatically sent with your Internet requests that provide information necessary for smooth Internet communications such as the operating system and browser you used. Similar to an IP address, a user agent string, by itself, does not identify you personally. However, when combined with other information, a user agent string might be used to identify the computer originating a message.

1.5 Anneal may assign your computer or mobile device a unique identification number (Unique ID) based on log file information when you access our websites Anneal may set a cookie on your device containing, amongst other things, the device's Unique ID. Anneal uses information generated from the Unique ID for purposes of improving our Services, primarily our ability to detect fraud. Anneal does not share the Unique ID or any associated data with unaffiliated third parties.

2. WHAT COOKIES / TRACKING CODE ARE USED BY ANNEAL?

2.1 Cookies

2.2 Tracking

2.2.2 If you are interested in turning on your browser’s privacy and Do Not Track settings, the Do Not Track website has browser-specific instructions.

2.2.3 Please see our section on email communication to learn about our use of pixel tags in marketing emails.

3. WHAT COOKIES / TRACKING CODE ARE USED BY THIRD PARTIES?

3.1 We have set out a non-exhaustive list of the critical third-party services providers whose software and services we utilise in the provision of Anneal, and with whom your account might otherwise interact. These third-party service providers may use cookies in accordance with their applicable privacy policies. While we have provided links to the relevant privacy policies, you should refer to each third party’s respective website as these policies may be updated from time-to-time.

3.1.1 Auth0 – We use Auth0 for authentication and authorisation purposes when you access the Software Services. When you authenticate with Auth0, the authorisation server stores an Auth0 cookie in order to keep track of your Auth0 session.