10. Public Privacy Notice

1. Data Protection

This document makes reference to Data Protection Legislation, encompassing the Data Protection Act 2018 (‘DPA 2018’), United Kingdom General Data Protection Regulation (‘UK GDPR’), and the Privacy and Electronic Communications (EC Directive) Regulations 2003 (‘PECR’). Additionally, where applicable, it includes the General Data Protection Regulation (Regulation (EU) 2016/679) (‘EU GDPR’). Any subsequent or replacement legislation will also be considered in effect.

Your location may necessitate the application of additional laws. Unless indicated otherwise, Parser will process your Personal Data in compliance with the aforementioned Data Protection Legislation. For details on local regulations that might pertain to your jurisdiction, consult the section on Local Data Protection Legislation below.

Parser serves as the Data Controller for the Personal Data we process, except when stated otherwise. In specific circumstances, we may function as a Data Processor, processing data as instructed by our clients, who in such cases will be the Data Controller.

We are registered with the Information Commissioner’s Office (ICO) in the UK under registration number A9087381. Further information on regulatory authorities that may be relevant in your jurisdiction can be found in the Contact Us section below.

We have designated a Data Protection Officer (DPO) responsible for overseeing internal compliance, advising on data protection matters, and serving as a liaison between data subjects and supervisory authorities. For methods to contact our DPO, please refer to the Contact Us section below.

2. The information we collect and when

The Personal Data detailed below is gathered during our interactions with you and as part of Parser’s business activities.

Should you be a potential client, or an employee, contractor, or associated party of Parser’s clients, contractors or suppliers, your information may have been initially collected by a third party and subsequently shared with us. If so, the third party will have provided you with the necessary disclosure at the time Parser obtained your information.

We adhere to Data Protection Legislation when collecting Personal Data, ensuring we only collect data that we have a legitimate use for. The Personal Data that may be gathered includes:

– Names

– Addresses

– Phone numbers

– Email addresses

– Gender

– Employment details

– Photographs

– Survey responses

– Usage Data (IP address, browser information, etc.)

Cookies and Tracking Technologies may also be used in further interactions with you, and additional data such as transaction records and service usage may be collected.

There is no legal or contractual mandate to provide us with your Personal Data. However, certain basic information is necessary for efficient and effective engagement with prospective clients or service users.

Parser does not intend to collect or process Special Category Personal Data, also known as ‘sensitive data’ (like political beliefs, ethnicity, etc.), for the lawful purposes outlined herein. Nevertheless, we might inadvertently receive such data through freetext comments, emails, support tickets, or other communications. We advise all service users to refrain from sharing Special Category Personal Data unless absolutely required. Should we receive Special Category Personal Data without a lawful basis for its retention, the data will be securely deleted in accordance with Parser’s Retention Schedule.

3. Cookies, Analytics and Tracking Technologies

We employ cookies and similar tracking mechanisms to monitor interactions on our Service and gather specific information. Technologies such as beacons, tags, and scripts are utilized for data collection and analysis to enhance our Service.

You have the option to configure your browser to reject all cookies or notify you when a cookie is sent. However, declining cookies may limit some functionalities of our Service.

We deploy both Session and Persistent Cookies for the reasons stated below:

Necessary / Essential Cookies
Type: Session Cookies
Managed by: Us
Purpose: These Cookies are critical for accessing features on the Website and for user authentication to mitigate fraudulent account activity. Without these, requested services cannot be delivered.

Cookies Policy Acceptance
Type: Persistent Cookies
Managed by: Us
Purpose: These Cookies confirm users’ acceptance of cookies on the Website.

Functionality Cookies
Type: Persistent Cookies
Managed by: Us
Purpose: These Cookies store preferences like login details or language settings, negating the need to reset them during future visits.

Tracking and Performance Cookies
Type: Persistent Cookies
Managed by: Third Parties
Purpose: These Cookies collect data on Website traffic and user behavior. The data may indirectly identify you since it is generally linked to a pseudonymous device identifier. They may also be used to evaluate new features or functionalities.

For further information on our cookie usage and your available choices, please consult our Cookies Policy.

Google Analytics, a service provided by Google, monitors and reports on our Service’s traffic. Google may share this data with its other services and utilize it for personalizing its advertising network. You can prevent Google Analytics from collecting your activity data by installing the Google Analytics opt-out browser add-on.

For Google’s privacy practices, please refer to the following link: Google Privacy Terms

4. How we use your information

We will only use your Personal Data when the law allows us to do so.  We will have provided you with our lawful basis for processing your Personal Data at the point the information was initially collected from you. We will not store, process or transfer your data unless we have an appropriate lawful reason to do so.

Under Data Protection Legislation, the lawful bases we rely on for processing your information are: 

– UK GDPR Article 6(1)a – your consent. You are able to remove your consent at any time. You can do this by contacting our DPO using the contact details provided in the TBC section below;

– UK GDPR Article 6(1)b – We have a contractual obligation;

– UK GDPR Article 6(1)c – We have a legal obligation; 

– UK GDPR, Article 6(1)d – In order to protect the vital interests of You or a third party;

– UK GDPR, Article 6(1)e – We have a public interest; or,

– UK GDPR Article 6(1)f) – We have a legitimate interest.

We may use your information for the following purposes:

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 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.

5. Who we might share your information with

We may share your Personal Data with other organisations in the following circumstances:

– From time to time, we may need to share your Personal Data with other Parser entities or Affiliates within the Parser group (see Introduction section above for more information) for operational purposes;

– If the law or a public authority says we must share the Personal Data;

– If we need to share Personal Data in order to establish, exercise or defend our legal rights – this includes providing Personal Data to others for the purposes of detecting and preventing fraud or other unlawful activities as well reducing credit risk; or

– From time to time, employ the services of other parties for dealing with certain processes necessary for the operation of our services. 

We use Service Providers, or Data Processors, who are third parties who provide elements of services for us. Examples of these Data Processors include, but are not limited to:

– Our customer relationship management (CRM) platform;

– Our accountancy platform;

– Our document management platform; and,

– Our communication platforms.

We have Data Processor Agreements in place with our data processors. This means that they cannot do anything with your Personal Data unless we have instructed them to do it. They will not share your Personal Data with any organisation apart from us or further sub-processors who must comply with our Data Processor Agreement. They will hold your Personal Data securely and retain it for the period we instruct. 

6. How long we keep your information for

We retain a record of your Personal Data in order to provide you with a high quality and consistent service. We will always retain your Personal Data in accordance with the Data Protection Legislation and never retain your information for longer than is necessary. Parser follows a Retention Schedule which outlines how long Parser will retain your Personal Data. Parser considers the retention period to begin from the point at which Parser last contacted you or otherwise reviewed your record to determine whether it was still active. Unless otherwise required by law, your data will be retained for the period specified in the summarised table below and then securely deleted in accordance with our internal policies and procedures.

7. How we keep you updated on our products and services

As a business contact, we will send you relevant news about our services in a number of ways including by email, but only if we have a legitimate interest to do so. Where we do not have a legitimate interest we will not send you communications unless we have asked for your consent.

We make every effort to ensure that we only send such communications to those acting in a business capacity and do not send such materials to consumers via personal email addresses if it is clear they are not acting in such a capacity or have not otherwise provided their consent.

All email communications will have an option to unsubscribe and so if you wish to amend your marketing preferences, you can do so by following the link in the email and updating your preferences. Alternatively, you can contact our DPO using the contact details provided in the Contact Us section below.

8. Giving your reviews and sharing your thoughts

When using our services, you may be able to share information through social networks like Facebook and Twitter. For example, when you ‘like’, ‘share’ or review our Services. When doing this, your Personal Data may be visible to the providers of those social networks and/or their other users. Please remember it is your responsibility to set appropriate privacy settings on your social network accounts so you are comfortable with how your information is used and shared on them.

Our Service may contain links to other websites that are not operated by us. If You click on a third party link, You will be directed to that third party’s site. We strongly advise You to review the Privacy Notice of every site You visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

9. Your rights over your information

Right to be informed about our collection and use of Personal Data

You have the right to be informed about the collection and use of your Personal Data. We ensure we do this with our internal data protection policies and through our external website Privacy Notice (https://parserdigital.com/privacy-policy/). These are regularly reviewed and updated to ensure these are accurate and reflect our data processing activities.

Right to access your Personal Data
You have the right to access the Personal Data that we hold about you in many circumstances, by making a request. This is sometimes termed a ‘Subject Access Request’. If we agree that we are obliged to provide Personal Data to you (or someone else on your behalf), we will provide it to you or them free of charge and aim to do so within 1 month from when your identity has been confirmed.

Before we can process your Subject Access Request, we may need to ask you for proof of identity and sufficient information about your interactions with us so that we can locate your Personal Data.

If you would like to exercise this right, please contact us by contacting the Data Protection Officer using the contact details provided in the Contact Us section below.

Right to correction of your Personal Data
If any of the Personal Data we hold about you is inaccurate, incomplete or out of date, you may ask us to correct it.

If you would like to exercise this right, please contact us by contacting the Data Protection Officer using the contact details provided in the Contact Us section below.

Right to restrict processing
You have the right to ask us to restrict the processing of your Personal Data. For example, this may be because you have issues with the accuracy of the data we hold or the way we have processed your data. The right is not absolute and only applies in certain circumstances.

If you would like to exercise this right, please contact us by contacting the Data Protection Officer using the contact details provided in the Contact Us section below.

Right to erasure
You have the right to have Personal Data erased. This is also known as the ‘right to be forgotten’. The right is not absolute and only applies in certain circumstances. 

If you would like to exercise this right, please contact us as by contacting the Data Protection Officer using the contact details provided in the Contact Us section below.

Right to portability
The right to portability gives you the right to receive Personal Data you have provided to a controller in a structured, commonly used and machine readable format. It also gives them you the right to request that a controller transmits this data directly to another controller.

If you would like to exercise this right, please contact us by contacting the Data Protection Officer using the contact details provided in the Contact Us section below.

Right to object
You have the right to object to our processing of some or all of the Personal Data that we hold about you. This is an absolute right when we use your data for direct marketing, but may not apply in other circumstances where we have a compelling reason to do so, e.g., a legal obligation.

If you would like to exercise this right, please contact us by contacting the Data Protection Officer using the contact details provided in the Contact Us section below.

Rights related to automated decision making
Automated decision-making takes place when an electronic system uses Personal Data to make a decision without human intervention. 

At present, Parser does not intend to make any automated decisions when processing your Personal Data.

You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.

If you would like to exercise or learn more about this right, please contact us by contacting the Data Protection Officer using the contact details provided in the Contact Us section below.

For more information about your privacy rights
The Information Commissioner’s Office (ICO) regulates data protection and privacy matters in the UK. They make a lot of information accessible to consumers on their website and they ensure that the registered details of all data controllers such as ourselves are available publicly. You can access them here https://ico.org.uk/for-the-public.

You can make a complaint to the ICO (or the relevant applicant supervisory authority as identified in the Local Data Protection Legislation Contact Us) at any time about the way we use your information. However, we hope that you would consider raising any issue or complaint you have with us first. Your satisfaction is extremely important to us, and we will always do our very best to solve any problems you may have. 

10. Security

Data security is of great importance to Parser. We have put in place appropriate technical and organisational measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.   

We take security measures to protect your information including:

– Limiting access to our buildings and resources to only those that we have determined are entitled to be there (by use of passes, key card access and other related technologies);

– Binding our employees, contractors and other representatives to a contractual duty of confidentiality;

– Managing a data security breach reporting and notification system which allows us to monitor and communicate information on data breaches with you or with the applicable regulator when required to do so by law;

– Implementing access controls to our information technology; and,

– We use appropriate procedures and technical security measures (including strict encryption, anonymisation and archiving techniques) to safeguard your information across all our computer systems, networks, websites, mobile apps, offices and stores;

Further information on our security measures can be found in our information security, data protection and IT-related policies. Parser is accredited to the ISO 27001 information security standard.

11. International Transfers

Your Personal Data is processed at the Company’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to Devices located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction. Where this occurs, Parser will ensure that:

– the security and confidentiality of your Personal Data is secure at all times;

– any Data Controller receiving your Personal Data has entered into an agreement with Parser which contains standard data protection clauses as required by UK and/or EU GDPR or there is an alternative appropriate safeguard in place governing the transfer; and,

– any Data Processor receiving your Personal Data has entered into an agreement with Parser which contains the required Data Processor clauses as well as standard data protection clauses as required by UK and/or EU GDPR or there is an alternative appropriate safeguard in place governing the transfer.

Where you are based in the UK or EU and we were required to transfer your Personal Data out of the UK or EU to countries not deemed by the ICO or European Commission (as relevant) to provide an adequate level of Personal Data protection, the transfer will be based on safeguards that allow us to conduct the transfer in accordance with the Data Protection Legislation, such as the specific contracts containing standard data protection clauses approved by the ICO or European Commission (as relevant) providing adequate protection of Personal Data.

12. Local Data Protection Legislation

Unless otherwise stated, UK Data Protection Legislation applies to the processing of your Personal Data. Depending on your location, additional Local Data Protection Legislation might also apply:

13. Californian Data Protection Legislation

Unless otherwise stated, UK Data Protection Legislation applies to the processing of your Personal Data. Depending on your location, Californian Data Protection Legislation might also apply. We will not discrimate against you because you have exercised any of your privacy rights under Californian Data Protection Legislation.

Your Rights under the CCPA
Under this Privacy Notice, and by law if You are a resident of California – and where you are not a job applicant, employee/contractor, or employee/contractor of another company interacting with us in your job role – You have the following rights:

– The right to notice. You must be properly notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.

– The right to access / the right to request. The CCPA permits You to request and obtain from the Company information regarding the disclosure of Your Personal Data that has been collected in the past 12 months by the Company or its subsidiaries to a third-party for the third party’s direct marketing purposes.

– The right to say no to the sale of Personal Data. You also have the right to ask the Company not to sell Your Personal Data to third parties. You can submit such a request by visiting our “Do Not Sell My Personal Information” section or web page.

– The right to know about Your Personal Data. You have the right to request and obtain from the Company information regarding the disclosure of the following:

The categories of Personal Data collected

The sources from which the Personal Data was collected

The business or commercial purpose for collecting or selling the Personal Data

Categories of third parties with whom We share Personal Data

The specific pieces of Personal Data we collected about You

Exercising Your CCPA Data Protection Rights
In order to exercise any of Your rights under the CCPA, and if you are a California resident – and where you are not a job applicant, employee/contractor, or employee/contractor of another company interacting with us in your job role – You can contact us using the contact details provided in the Contact Us below or visit our “Do Not Sell My Personal Information” section or web page.

Before we can process your Request for your Personal Data under CCPA, we may need to ask you for proof of identity and sufficient information about your interactions with us so that we can locate your Personal Data. We will use information you provide to us to verify your request. If we cannot initially verify your identity, we may request additional information to complete the verification process, such as, for example, a copy of your driver’s license. You can designate an agent to make a request on your behalf by either: 

– having your agent send us a letter, signed by you, certifying that the agent is acting on your behalf and showing proof that they are registered with the California Secretary of State; or,

– by you and the agent executing and sending us a notarized power of attorney stating that the agent is authorized to act on your behalf. 

Please note that we may still require you to verify your identity before we process a request submitted by your agent.

The Company will disclose and deliver the required information free of charge within 45 days of receiving Your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonable necessary and with prior notice.

Do Not Sell My Personal Data
We do not sell Personal Data. However, the Service Providers we partner with (for example, our advertising partners) may use technology on the Service that “sells” Personal Data as defined by the CCPA law.

If you wish to opt out of the use of your Personal Data for interest-based advertising purposes and these potential sales as defined under CCPA law, you may contact us using the contact details provided in the Contact Us below.

Please note that any opt out is specific to the browser You use. You may need to opt out on every browser that you use.

Website

You can opt out of receiving ads that are personalized as served by our Service Providers by following our instructions presented on the Service:

– From Our “Cookie Consent” notice banner;

– From Our “CCPA Opt-out” notice banner;

– From Our “Do Not Sell My Personal Information” notice banner; or,

– From Our “Do Not Sell My Personal Information” link.

The opt out will place a cookie on Your computer that is unique to the browser You use to opt out. If you change browsers or delete the cookies saved by your browser, you will need to opt out again.

Mobile Devices
Your mobile device may give you the ability to opt out of the use of information about the apps you use in order to serve you ads that are targeted to your interests:

– “Opt out of Interest-Based Ads” or “Opt out of Ads Personalization” on Android devices

– “Limit Ad Tracking” on iOS devices

You can also stop the collection of location information from Your mobile device by changing the preferences on your mobile device.

“Do Not Track” Policy as Required by California Online Privacy Protection Act (CalOPPA)

Our Service does not respond to Do Not Track signals.

However, some third party websites do keep track of Your browsing activities. If You are visiting such websites, You can set Your preferences in Your web browser to inform websites that You do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of Your web browser.

Your California Privacy Rights (California’s Shine the Light law)
Under California Civil Code Section 1798 (California’s Shine the Light law), California residents with an established business relationship with us can request information once a year about sharing their Personal Data with third parties for the third parties’ direct marketing purposes.

If you’d like to request more information under the California Shine the Light law, You can contact us using the contact details provided in the Contact Us below.

California Privacy Rights for Minor Users (California Business and Professions Code Section 22581)
Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact us using the contact details provided in the Contact Us below. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.

California Business and Professions Code section 22581 allow California residents under the age of 18 who are registered users of online sites, services or applications to request and obtain removal of content or information they have publicly posted.

To request removal of such data, and if you are a California resident, You can contact us using the contact details provided in the Contact Us below, providing the email address associated with Your account.

Be aware that Your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.

14. Supervisory Authorities

PARSER is regulated by the Information Commissioner’s Office (ICO) in the UK. Depending on your location, the regulation of the processing of your Personal Data might also involve one or more of the following supervisory authorities:

If you are based in a location not listed above, please consider the supervisory authority relevant to your processing to be the Information Commissioner’s Office (ICO) in the UK unless otherwise stated. 

You can make a complaint to the relevant supervisory authority at any time about the way we use your information. However, we hope that you would consider raising any issue or complaint you have with us first using the contact details provided in the Contact Us section below. Your satisfaction is extremely important to us, and we will always do our very best to solve any problems you may have. 

15. Contact Us

If you would like to exercise one of your rights as set out above, or you have a question or a complaint about this Privacy Notice, the way your Personal Data is processed, please contact our DPO by one of the following means:

By email: dpo@parserdigital.com

By post: FAO Data Protection Officer, The Scalpel, 18th Floor, 52 Lime Street, London, EC3M 7AF

16. Changes to Our Privacy Notice

Thank you for taking the time to read our Privacy Notice.

We may change this Privacy Notice from time to time (for example, if the law changes). We recommend that you check this Privacy Notice regularly to keep up-to-date.

This Notice was last updated on 2023-12-01