Sunlight Technologies Limited (“Sunlight”, "We", “Us” and “Our”) remain fully committed to the protection of your and your Users’ privacy at all times. The information contained in this policy has been published to inform you of the way in which any Personal Data (as defined below) you provide us with or we collect from you will be used. Please read this information carefully in order to fully understand how we treat such Personal Data.
Please read this policy in conjunction with the Sunlight Terms and Conditions (“ST&C”). When you access or use Sunlight, you agree to our privacy policy and you consent to our collection, storage, use and disclosure of your Personal Data for the purpose of making Sunlight and/or the Service available to you, in accordance with this policy. Any capitalised terms not defined in this policy shall have the same meanings given to them in the ST&C.
We will collect, store, use and disclose Personal Data in accordance with all applicable laws relating to the protection of Personal Data, including the EU Data Protection Directive 95/46/EC, the EU General Data Protection Regulation 2016/679, the EU ePrivacy Directive 2002/58/EC as amended by Directive 2009/136/EC, as amended or superseded from time to time, and any national implementing legislation (“Data Protection Laws”).
For the purpose of Data Protection Laws, in relation to any Personal Data you or any Users submit to our platform, you will be the data controller and we will be a data processor of such Personal Data.
Sunlight Technologies Limited (“Sunlight”, "We", “Us” and “Our”) remain fully committed to the protection of your and your Users’ privacy at all times. The information contained in this policy has been published to inform you of the way in which any Personal Data (as defined below) you provide us with or we collect from you will be used. Please read this information carefully in order to fully understand how we treat such Personal Data.
Please read this policy in conjunction with the Sunlight Terms and Conditions (“ST&C”). When you access or use Sunlight, you agree to our privacy policy and you consent to our collection, storage, use and disclosure of your Personal Data for the purpose of making Sunlight and/or the Service available to you, in accordance with this policy. Any capitalised terms not defined in this policy shall have the same meanings given to them in the ST&C.
We will collect, store, use and disclose Personal Data in accordance with all applicable laws relating to the protection of Personal Data, including the EU Data Protection Directive 95/46/EC, the EU General Data Protection Regulation 2016/679, the EU ePrivacy Directive 2002/58/EC as amended by Directive 2009/136/EC, as amended or superseded from time to time, and any national implementing legislation (“Data Protection Laws”).
For the purpose of Data Protection Laws, in relation to any Personal Data you or any Users submit to our platform, you will be the data controller and we will be a data processor of such Personal Data.
“Personal Data” means any information relating to an identified or identifiable natural person; an identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
We may obtain and use the following Personal Data about you and anyone you chose to add to our platform:
Any correspondence we have with you and your Users should you or your Users contact us. Data you or your Users provide when you fill out forms on our Website, including but not limited to data you provide when you register to become a user of the Service. Data and information you or your Users submit or upload to Sunlight or the Service, including employee data (which may include, among other things, dates of birth, residential addresses, names, email addresses, telephone numbers, bank details). Details of transactions made by you through the Website. Responses to optional research surveys we ask you or Users to complete. Details of your or your Users’ visits to our Website, which includes without limitation location and traffic data, weblogs, resources you access and other communication data.
You will be submitting and providing Client Data which may contain Personal Data (and potentially Sensitive Personal Data of Users and third parties. “Sensitive Personal Data” means any data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic or biometric data, data concerning health, data concerning sex life or sexual orientation and data concerning the commission or alleged commission of any offence.
You represent and warrant that you
i) have the right to transfer such Personal Data (including Sensitive Personal Data, if applicable) to us for the purpose of receiving the Service; and
ii) are solely responsible for obtaining all required consents, authorisations and permissions from such Users and third parties and providing all required notifications to such Users and third parties (where applicable) to enable you to provide such information to us and to grant to us the rights set forth in this privacy policy and the Terms and Conditions. It is your responsibility to ensure that all such Users and third parties are aware of and accept the terms of this policy and that you have obtained explicit and informed consent of Users to our processing any of their Sensitive Personal Data in accordance with this policy and the EULA. You may not provide us with any Client Data or other information containing Personal Data of Users or third parties unless and until you have obtained all necessary consents, authorisations and permissions to do so.
You agree to indemnify us in accordance with Clause 13 of the Sunlight Terms and Conditions for any claims made by any Users arising from any unauthorised access or accidental loss, damage, corruption or disclosure of Client Data arising from or in connection with your and/ or our use or disclosure of Client Data.
We may obtain information about your and your Users’ computer, which includes your and your Users’ IP address, browser type and operating system where available. This accumulation of data is used to assist system administration.
We may also collect information regarding your or your Users’ browsing activity and interests through use of a cookie file. This cookie file is stored on the hard drive of your or your Users’ computer, and contains information that is transferred to your or your Users’ computer's hard drive. We use the collection of this data to help us improve the experience of users on our Website and Service, and to deliver a more personalised service with more relevant content. The collection of this data allows us to:
You can find more information about some of the individual cookies we use and the purposes for which we use by reading at our Cookie Policy.
Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies. You and your Users remain entitled to refuse cookies by adjusting your browser settings accordingly. Doing so however may restrict your and your Users’ access to certain areas within our Website or Service. Unless you or your Users adjust your/their browser settings to refuse cookies, our system will issue cookies when you/they log on to our Website.
The Personal Data we obtain from you and your Users (including, without limitation, Client Data) may be moved to and stored at a destination within the European Economic Area ("EEA"). Staff members operating within the EEA who work for or on behalf of us may process this information. Such staff members may, among other things, be involved in the processing of payment details, the provision of support services and the delivery of your and your Users’ request(s) for us to provide the Service.
Without limiting the foregoing, you agree that Personal Data we obtain from you and your Users (including, without limitation, Client Data) may be processed by our service providers based in, countries outside of the EEA for the purposes of providing you with the Service. Such countries may not have laws offering the same level of protection for Personal Data as those inside the EEA; however where such transfers of data occur, we will take steps to prevent the transfer of Personal Data without adequate safeguards being put in place and will ensure that your and your Users’ Personal Data collected in the EEA and transferred internationally is afforded the same level of protection as it would be inside the EEA. For further information on, or a copy of, the adequate safeguards adopted by us for the international transfer of Personal Data, please email dpo@sunlight.is.
We store the Personal Data you and your Users provide us with on our secure servers. In the event of us giving you or your Users (or you/they choosing) a password which grants you/them access to specific areas within our Website or Service, it remains your/their responsibility to maintain the confidentiality of this password. This includes the responsibility to refrain from sharing your/their password with other parties.
As the transmission of data via the Internet cannot be assumed completely secure, we cannot guarantee the security of any of your or your Users’ data transmitted to our Website or Service; you are therefore responsible for any risk associated with such transmission. We will however at all times take all reasonable steps to ensure the transmission of your and your Users’ data is executed as securely as possible, and upon receipt of your/their data we will continue at all times to enforce strict security procedures and features in an attempt to prevent any unauthorised access.
We will take reasonable steps to maintain appropriate technical and organizational measures to protect the Personal Data you provide to us against accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to your Personal Data. For more information, please have a look at ourSecurity Policy.
The Personal Data we hold about you and your Users may be used in any of the following ways:
We will never supply your or your Users’ Personal Data to third parties unless under the conditions stated beneath this section of our privacy policy. Notwithstanding the foregoing, you acknowledge and agree that we may aggregate and anonymize your, and your Users, Personal Data (excluding, for the avoidance of doubt, Sensitive Personal Data) and use and share such aggregated and anonymized Personal Data with third parties for statistical purposes and for the purpose of data analytics, product development, and/or Service improvement.
Disclosure of your and your Users’ Personal Data (including, without limitation, Client Data) to third parties will only occur in any of the following events:
You acknowledge and agree that we may also disclose Personal Data (including, without limitation, Client Data) with:
Our service providers have to follow our express instructions when processing the Personal Data you or your Users provide and must have in place appropriate technical and organisational security measures to safeguard such Personal Data, and we do not allow them to use this information for their own commercial purposes.
You retain the right to request us to refrain from processing your data for the purposes of marketing. To exercise such right, you may reply to any information we send you, detailing your request that we refrain from sending any marketing correspondence, or you can exercise this same right by contacting us electronically via email at info@sunlight.is. If at any time we intend to use your data for such marketing purposes however, it is standard practice for us to make you aware in advance of collecting such data.
We may at times provide links on our Website to third party websites, including without limitation those owned or managed by our partner networks, affiliates or advertisers. These websites have separate privacy policies, and we therefore cannot accept any responsibility for the content. As such, choosing to follow these links is a choice you make at your own risk, and we advise that you check these websites' individual privacy policies before submitting any personal data.
You retain at all times the right to access / amend / delete any Personal Data we hold about you or to exercise your right of data portability or to object to, or restrict, the purposes for which your Personal Data is processed on certain grounds. You may exercise this right by making a request in accordance with Data Protection Laws, by email at dpo@sunlight.is You may also lodge a complaint with the UK data protection regulator, the Information Commissioner should you be dissatisfied with the way that we handle your Personal Data.
You undertake to notify your Users of this privacy policy and of their rights under the Data Protection Law. We will provide you with reasonable assistance to enable you to comply and respond to a request, query or complaint from a User in relation to their Personal Data.
We will keep your and your Users’ Personal Data for the duration of the Service and in accordance with your instructions or for such periods as may be required by law.
If at any time we make a change to this policy, we will update this page to reflect such change. Where we feel it appropriate, we will notify you by email, however we recommend you review this page periodically to ensure you remain happy with the latest version.
We welcome any questions or comments in relation to this privacy policy and advise you to send any such communication info@sunlight.is.
%201.svg)
