TrakCel Limited's Gateway Service provides a single platform to enable users of the TrakCel Ocellos Platform to access multiple Ocellos sites from a single login area (Gateway Service). To enable us to provide the Gateway Service we need to collect and process certain information about you. This privacy policy sets out how TrakCel Limited uses and protects personal data that is collected as part of the Gateway Service.
TrakCel Limited is the controller and responsible for your personal data (collectively referred to as TrakCel, we, us or our in this privacy policy).
If you have any questions about this privacy policy, please contact us as follows:
Email: Data.protection@trakcel.com
Address: Compliance Officer, 11 Raleigh Walk, Waterfront 2000, Cardiff, Wales, CF10 4LN.
Personal data means any information about an individual from which that person can be identified. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
Identity Data includes first name, last name, username and password.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access the Gateway Service.
Usage Data includes information about how you interact with and use the Gateway Service. We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing the Gateway Service in order to analyse general trends in how users are interacting with it to help improve our service offering.
We use different methods to collect data from and about you including through:
Your interactions with us. You may give us your personal data by filling in an online form or by corresponding with us by post, phone, email or otherwise including:
subscribing to the Gateway Service;
giving us feedback or contacting us.
Automated technologies or interactions. As you interact with the Gateway Service, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.
The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:
Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you and our end customers the best and most secure experience.
Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example granting you use of the Gateway Service.
We have set out below, in a table format, a description of all the ways we plan to use the various categories of your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
| Purpose/Use | Type of data | Legal basis |
|---|---|---|
| To register you as a user of the Gateway Service | (a) Identity | Performance of a contract with our end customer and with your consent. |
| To enable you to access and use the Gateway Service. | (a) Identity |
(a) Performance of a contract with our end customer and with your consent. (b) Necessary for our legitimate interests. |
|
To manage our relationship with you which includes: (a) Notifying you about changes to our terms or privacy policy. (b) Dealing with your requests, complaints and queries. |
(a) Identity |
(a) Performance of a contract with our end customer and with your consent. (b) Necessary for our legitimate interests. |
| To administer and protect our business and the Gateway Service (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data). |
(a) Identity (b) Technical |
(a) Necessary for our legitimate interests. (b) Necessary to comply with a legal obligation. |
| To use data analytics to improve Gateway Service, customer relationships and experiences. |
(a) Technical (b) Usage |
Necessary for our legitimate interests. |
We do not use your personal data for marketing purposes.
The Gateway Services operates on the Salesforce infrastructure. Details of the cookies that we use can be found at:
https://help.salesforce.com/s/articleView?id=experience.networks_cookies.htm&type=5
Subject to the remainder of this paragraph, we do not disclose your personal data to third parties. We reserve the right to share your personal data with a third party to whom we may choose to sell, transfer or merge parts of our business or our assets. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
The Gateway Services are hosted within the Salesforce environment.
Whilst you may access the Gateway Service from outside the UK, we do not transfer your data to any third party outside the UK. If this should change, we will notify you of this and we will always ensure that a similar degree of protection is afforded to you by ensuring that we have appropriate safeguards in place. This includes applicable agreements such as the standard contract clause model agreements and the UK international data transfer agreement.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. 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 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.
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
You have a number of rights under data protection laws in relation to your personal data. These rights include:
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 could 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 your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month.
You have the right to make a complaint to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). However, before doing so please make sure you have first made your complaint to us or asked us for clarification if there is something you do not understand.
We keep our privacy policy under regular review. This version was last updated on the date set out above. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new email address.
The Gateway Service site may include links to third-party websites, plug-ins and applications. In addition, by using the Gateway Service you will then access third party Ocellos sites. These sites will be subject to their own privacy policy. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements.