This Privacy Notice sets out how Wax Digital Limited (“Wax Digital”, “we”, “us”, “our”) uses and protects any personal information that you (“you”, “your”) make available to us in connection with:
- Your use of any of our services.
- Your use of our website.
- Any communications you have with Wax Digital.
Wax Digital Limited is a limited company incorporated in England and Wales with registered number 4220636. Our registered office is at Grafton House, Grafton Street, Hyde, Cheshire, SK14 2AX.
Wax Digital is committed to ensuring that your privacy is protected and will only use your information in accordance with applicable data protection legislation, including the Data Protection Act 1998 and (once applicable) the General Data Protection Regulation (GDPR).
Should you provide us with personal information you can be assured that it will only be used in accordance with this Privacy Notice.
(1) What information do we collect?
We may collect, store and use the following kinds of personal information:
- Contact details: information that allows us to contact you directly such as:
- First name and surname.
- Job title.
- Work email address.
- Work landline number.
- Work mobile.
- Work postal address.
- Unique identifiers: such as usernames and passwords to access our services.
- Payment information: such as credit / debit card and bank account details so that we can make or receive payments, together with details of financial transactions between us and you.
- Records of your interactions with us: for example records of telephone conversations, letters, email exchanges and other correspondence, together with any usage data related to how you use our services.
- Other personal information that you choose to provide to us: for example, information that you voluntarily provide to us during the support process.
(2) Using your personal information
We may use your personal information for the following purposes:
|Purpose||Personal information used||Lawful basis on which we use your personal information|
|Providing our services||All the personal information we collect||This is necessary to fulfil our contracts with customers.|
If you are not a customer of ours, we believe you may have an interest in the specialist products and services we offer.
|Responding to support queries and other enquiries (including support requests made through Interaxions)||All the personal information we collect||This is necessary to fulfil our contracts with customers.|
If you are not a customer of ours, we have a legitimate interest in doing so to enable us to fulfil our contracts with customers.
|Issuing system messages||All the personal information we collect||We will only send you system messages that you have consented to receive in accordance with your selected preferences.|
|Making and receiving payments||Transaction and payment information||This is necessary to fulfil our contracts with customers or is otherwise done with your consent.|
|Staff training||All the personal information we collect||We have a legitimate interest in improving the services we provide.|
|Improving our services and our website||All the personal information we collect||We have a legitimate interest in improving the services we provide.|
|Letting you know about products and services we think may be of interest to you||All the personal information we collect (other than your payment information)||We have a legitimate interest in letting you know about our products and services.|
|Investigating fraud and debt collection||All the personal information we collect||We have a legitimate interest in preventing fraud and collecting debts.|
|The security of our IT systems||Your usage of our IT systems||We have a legitimate interest in keeping our IT systems secure.|
(3) Marketing communications
We will only send you marketing communications that we reasonably consider will be of interest to you.
If you wish to stop receiving any particular form of marketing you can update your preferences at any time by clicking the “unsubscribe” link at the bottom of emails you receive or contacting us as described in section 11.
(4) How we update your personal information
To ensure personal information held is as accurate and up to date as possible we will update your personal information held on our database within three working days of you informing us of any changes, or as part of an annual data audit we conduct.
To complete the annual data audit a third-party acts on behalf of Wax Digital to verify the personal details we hold about you via a telephone call to your head office switchboard, or by checking current publicly available sources of employee information, such as LinkedIn profiles and employers’ websites.
Data is exchanged with the third party via a highly secure file transfer protocol transmission. We have a non-disclosure agreement in place with the third party outlining that no data will be shared with any third party, and will be deleted once the data has been transferred back to Wax Digital.
(5) Retention of personal information and your rights
We will keep your personal information for as long as we need it for the relevant purposes described above. Where the information is collected in respect of your use of our services, this generally means for so long as you (or the customer who you were using our service on behalf of or in connection with) remains a customer of ours. Where you contact us with an enquiry not directly connected to the use of our service, this means until that query is resolved.
After the customer agreement has ended or the query has been resolved, we will keep your personal information for a reasonable period of time to maintain our records and comply with our legal obligations. This generally means retaining it for at least six years after the relevant contract has ended or enquiry been resolved.
If you would like your personal information to be permanently removed from our records, we would be happy to do this for you where possible. To do this you can contact us using the methods highlighted under section 11. We will review your request within three working days and process it in accordance with the timescales and our obligations under data protection law.
In addition to your “right to be forgotten”, you have the following rights in relation to your personal information:
- The right to access the personal information we hold about you and be informed about how it is being used.
- The right to opt-out of receiving marketing communications.
- The right to request the correction of inaccurate personal information that we hold about you.
- The right to request that we restrict our processing of your personal information.
(6) Disclosure of your personal information
Your personal information will never be disclosed to any third party other than:
- Our data auditors: for the purpose of our annual data audit (as described in section 4).
- Service providers and advisors: such as companies that host our service or support our IT, help us analyse the data we hold, process payments, send communications to you, provide us with legal or financial advice and generally help us to deliver our services.
- Affiliated companies within our corporate structure
- Purchasers of our business: in connection with any allegation of fraud or misconduct or where we are legally required to do so.
(7) Social media and other third party websites
We will never ask you to provide personal or sensitive information through a social media platform or other third party website. You are advised to use social media platforms wisely and communicate / engage upon them with due care and caution in respect of their own privacy and personal details.
Our website may use social sharing buttons which help you share content directly from our web pages to the social media platform in question. We may also include links to our profiles on social media sites or to other third party websites. You are advised that your use of social sharing buttons and of linked websites is at your own discretion, and that social media platforms and other websites may track your activity.
Wax Digital cannot be held responsible for the consequences of sharing items (be that links, pictures or other media) on a social network or in any other public forum.
Social media platforms and third party websites are subject to their own terms and conditions and privacy policies, which you should read before commencing use of those sites.
(8) Where we store your personal information
For personal data collected within the European Economic Area (“EEA”), the personal data collected is generally processed and stored within the EEA. In cases where we export your personal data outside the EEA, such export is based either on a decision by the EU Commission that the third country in question ensures an adequate level of protection, or on appropriate safeguards to ensure that your rights are protected. Examples of appropriate protection measures are approved code of conduct in the recipient country, standard contractual clauses, binding company internal rules or Privacy Shield.
By submitting your personal information, you agree to this transfer, storing or processing. Wax Digital will take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this Privacy Notice.
All information you provide to us is stored on our secure servers. It may be necessary to store this data on another server for a period of time should the main server be inoperable and whilst the main server issue is being resolved. If this occurs, Wax Digital customers will be informed through a specific communication which will include further details of that incident.
Wax Digital will take all steps reasonably necessary to ensure that your personal information is treated securely and has processes in place to help prevent unauthorised access to confidential information about you that is under our control.
In order to prevent unauthorised access or disclosure we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we hold about you, and we store your personal information on a highly secure server and email platform.
Wax Digital comply with internationally recognised standards such as ISO 27001 (more information is here: iso.org/isoiec-27001-information-security.html).
However, please note that whilst every effort has been made to ensure that a safe and secure email submission process exists, email is by its nature an insecure medium of communication and Wax Digital does advise those people who use email (including via email forms) that they do so at their own risk.
Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
(10) Updates to this Privacy Notice
We may update this Privacy Notice from time-to-time by posting a new version on our website. You should check this page occasionally to ensure you are happy with any changes. If not, please contact Wax Digital’s Data Protection Officer using the contact methods described in section 11.
(11) Further information
For further information on how your information is used, how we maintain the security of your information and your rights to access information we hold on you, or to make a request regarding your personal information, please contact:
- By email: email@example.com
- By post: Wax Digital, The Data Protection Officer, Grafton House, Grafton Street, Hyde, Cheshire SK14 2AX (marking your correspondence FAO The Data Protection Officer)
If you have an issue or complaint in respect of our handling of your personal information, you should contact us in the first instance. If we are unable to resolve your complaint, you are entitled to make a complaint to the Information Commissioner’s Office.
Last Updated: March 2020