This privacy policy explains how we use any personal information we collect about you when you use this website. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting www.draycir.com (our “Site”) you are accepting and consenting to the practices described in this policy.

1. Who We Are
We are Draycir Limited, a company registered in England and Wales with registered number 04376912 and registered address of 95 Princess Road East, Leicester, LE1 7DW.

Where you have provided your information directly via our Site then we are the Controller of your personal data for the purposes of the applicable data protection legislation.

Where we provide services to your company and we process personal data as part of that service we act as a processor and the terms on which we process that data is set out in the applicable agreement with your company.

Draycir collects personal information when you place an order for our products or services. We will use this information to provide the product or services requested.

2. The Basis On Which We Process Your Data
We process personal data in accordance with this policy on one of the following bases:

• Where necessary for the performance of a contract with you or to take steps to enter into a contract, such as the administration of your account and/or to provide services to you.

For other purposes not covered above:

• Where we have sought your consent and you have provided consent, on the basis of that consent; or
• Where we have not sought your consent, on the basis of our legitimate interests we have assessed that these are not overridden by your interests. These legitimate interests are as follows:
  – In order to provide our services to our customers and carry out supporting functions such as financial administration and customer support.
  – To market our products and services to customers and potential customers.
  – To comply with any legal or regulatory obligations that apply to us.

3. Why We Collect Information About You
We collect data about you for the following purposes:

• In order to fulfil our contracts with you or the organisation that you work for, for example, we will do so to complete an order or provide support services.
• To better understand our customers and give them appropriate and targeted information, offers, and other communications and in order to provide our customers with better and personalised experiences with our company.
• To provide you with appropriate and targeted marketing communications and to provide you with information and offers relevant to you.

4. What Information Do We Collect About You?
We gather and use certain information about individuals in order to provide products and services and to enable certain functions on this website. We also collect information when you voluntarily complete customer surveys, sign up for a webinar, provide feedback and participate in competitions.

We may collect the following information:

• Name, job title and company name
• Contact information including email address and telephone number
• Demographic information such as country
• Website usage data using cookies
• Other information relevant to client enquiries such as the type of product or service you are interested in

5. How Will We Use The Information About You?
The information we collect about you will be used to process your order and manage your account.

We may use this data:

• For our internal records.
• To improve products and services we provide.
• To contact you in response to a specific enquiry.
• To carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us.
• To provide you with information about other goods and/or services we offer that are similar to those that you have already purchased or enquired about.
• To notify you about changes to our service.
• To ensure that content from our Site is presented in the most effective manner for you and for your computer.
• To administer our Site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
• To improve our Site to ensure that content is presented in the most effective manner for you and for your computer.
• To allow you to participate in interactive features of our service, when you choose to do so.
• As part of our efforts to keep our Site safe and secure.
• To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you.
• To make suggestions and recommendations to you and other users of our Site about goods or services that may interest you or them.
• For marketing purposes: We would like to send you information about products and services of ours that may be of interest to you. Where we have a relevant and appropriate relationship with us, for example as an employee of a partner company of Draycir’s or a user of our products, the processing of personal data for direct marketing may be regarding as being carried out for legitimate interests. If we do not have a legitimate interest in contacting you, then we will ensure that we have gained your consent before contacting you.
• We may record telephone conversations for training purposes.
• We reserve the right to repeat comments about our products made in communications with us for marketing purposes, these will be on an anonymous basis unless we have obtained your consent.

6. Disclosure of Your Information
Other than as set out below, your information will not be sold, shared or provided to any third party:

We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries.

We may share your information with any third parties expressly named as receiving your data at the time your data was provided.

7. Cookies
A cookie is a piece of data stored on your hard drive to collect log information and visitor behaviour information.

We may use cookies to:

• Analyse our web traffic using an analytics package. Aggregated usage data helps us improve the website structure, design, content and functions.
• Test content on our website. For example, 50% of our users might see one piece of content, the other 50% a different piece of content.
• Store information about your preferences. The website can then present you with information you will find more relevant and interesting.
• To recognise when you return to our website, we may show your relevant content, or provide functionality you used previously

You can choose to set your browser not to accept cookies and the following websites www.aboutcookies.org or www.allaboutcookies.org provide advice on how to remove cookies from your browser. However, you may find that in some cases some of our website features may not function as a result.

8. Where We Store Your Personal Data
The data that we collect from you will be processed and stored within the European Economic Area (“EEA”) except that we may disclose some personal data to our group companies located outside the EEA in order to provide certain software development and/or support services. These transfers will be made using appropriate safeguards (such as a data processing agreement). Please contact us if you have any questions about this.

All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology. 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 a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

9. Support Services
In some circumstances we may request access to your desktop to allow us to provide a remote diagnostic and support service. Where you consent to this activity you agree that we may have access to data on the applicable equipment. Some of this may be personal data. To the extent that we access personal data in this manner we only use it to provide the services that you have requested from us and for no other purposes. The personal data that we may require as part of the support activity is requesting a copy of the Draycir product audit logs. The audit logs may contain personal data, however the purpose of the audit logs are to help diagnose any issues. The audit logs are securely retained to assist with any further issues, however the audit logs can be deleted upon request. If we are unable to resolve the issue we may request a copy of your database, where following the completion of our investigation we will delete the database copy.

10. Your Rights
Regarding of the conditions for processing your data, you have the right at any time to stop us from contacting you for marketing purposes. If you do not wish to be contacted for marketing purposes, you can use the unsubscribe link at any time on our marketing emails.

Alternatively you can contact us using the details set out in section 15 below.

You have the following additional rights:

• The right to request access to the personal data that we hold about you;
• The right to request rectification of the personal data that we hold about you;
• The right to request erasure of the personal data that we hold about you;
• The right to request restriction of processing about you;
• The right to object to processing; and
• The right to data portability.

If you wish to invoke any of the above rights, please notify us using the contact details set out in Section 15 below.

Where our processing of personal data is based on your having given consent, you have the right to withdraw that consent at any time. If you wish to invoke this right, please notify us using the contact details set out in Section 15 below.

You have the right to lodge a complaint with a supervisory authority. In the United Kingdom, the supervisory authority is the Office of the Information Commissioner, full contact details for which can be found at https://ico.org.uk/global/contact-us/

11. Links From Our Website
This website may contain links to other sites. Please be aware that we are not responsible for the privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of each and every web site that collects personally identifiable information. This privacy statement applies solely to information collected by this website.

12. Notification of Changes
If we decide to change our privacy policy, we will post those changes on our website so our users are always aware of what information we collect, how we use it, and under circumstances, if any, we disclose it. If at any point we decide to use personally identifiable information in a manner different from that stated at the time it was collected, we will notify users by way of an email. Users will have a choice as to whether or not we use their information in this different manner. We will use information in accordance with the privacy policy under which the information was collected.

13. Spindle Document Capture Mobile App
Where you use the Spindle Document Capture Mobile App (” Mobile App”), the following sections will apply in substitution of the corresponding sections of the above parts of the privacy policy. All other sections of the privacy policy will apply to the Mobile App.

13a. The Basis on Which We Process Your Data
The Mobile App process personal data in accordance with this policy on one of the following bases:

• Where necessary for the performance of a contract with you or to take steps to enter into a contract, such as the administration of your account and/or to provide services to you.
• For our legitimate interests in order to provide our services to our customers and carry out supporting functions such as customer support.

13b. Why We Collect Information About You
The Mobile App collects data about you for the following purposes:

• In order to fulfil our contracts with you or the organisation that you work for.

13c. What Information Do We Collect About You?
The Mobile App collects the following information:

• Contact information including email address
• Images you have chosen to take using the Mobile App.
• Images you have chosen to add to the Mobile App from your mobile phone gallery

The Mobile App will require access to the following device services in order to collect the above information in accordance with this privacy policy:

• Mobile network,
• Camera,
• Internet.
• Storage (internal/external).

13d. How Will We Use the Information About You?
The information we collect about you will be used to manage your account.

We may use this data:

• In order to identify the individual accessing the Mobile App.
• To access the images taken using the Mobile App from Spindle Document Capture Pending Tray.
• As part of our efforts to keep our Mobile App safe and secure.
  
  13e. Disclosure of Your Information
  Your information will not be sold, shared or provided to any third party.

14. Spindle Proof of Delivery Mobile App
Where you use the Spindle Proof of Delivery Mobile App (”POD App”), the following sections will apply in substitution of the corresponding sections of the above parts of the privacy policy. All other sections of the privacy policy will apply to the POD App.

14a. The Basis on Which We Process Your Data
The Mobile App process personal data in accordance with this policy on one of the following bases:

• Where necessary for the performance of a contract with you or to take steps to enter into a contract, such as the administration of your account and/or to provide services to you.
• For our legitimate interests in order to provide our services to our customers and carry out supporting functions such as customer support.

14b. Why We Collect Information About You
The Mobile App collects data about you for the following purposes:

• In order to fulfil our contracts with you or the organisation that you work for.

14c. What Information Do We Collect About You?
The Mobile App collects the following information:

• Contact information – your email address
• Images you have chosen to upload using the POD App.
• Your precise location from location sources such as GPS, cell towers, and Wi-Fi.

The Mobile App will require access to the following device services in order to collect the above information in accordance with this privacy policy:

• Mobile network
• Camera
• Internet
• Storage (internal/external)
• Location services

14d. How Will We Use the Information About You?
The information we collect about you will be used to manage your account.

We may use this data:

• In order to identify the individual accessing the POD App.
• To access the images uploaded using the POD App from Spindle Self Serve.
• As part of our efforts to keep our POD App safe and secure.

14e. Disclosure of Your Information
We may need to disclose specific personal data to third party software providers in order for them to provide support and maintenance services on the Application

15. Spindle Document Distribution Gmail Device
Where you use the Spindle Document Distribution gmail device, the following sections will apply in substitution of the corresponding sections of the above parts of the privacy policy. All other sections of the privacy policy will apply to the Spindle Document Distribution gmail device.

15a. The Basis on Which We Process Your Data
The Spindle Document Distribution gmail device processes personal data in accordance with this policy on the following bases:

• For our legitimate interests in order to provide our services to our customers and carry out supporting functions such as customer support.

15b. Why We Collect Information About You
The Spindle Document Distribution gmail device collects data about you for the following purposes:

In order to send emails on your behalf as instructed by the user.

15c. What Information Do We Collect About You?
The Spindle Document Distribution gmail device collects the following information:

• Contact information – your email address – this is accessed during processing of distribution but is not stored.

The Spindle Document Distribution gmail device will require access to the following device services in order to collect the above information in accordance with this privacy policy:

• Gmail API
• App Script API

15d. How Will We Use the Information About You?
The information we collect about you will be used to manage your account.
We may use this data in order to provide support and maintenance services on the Application.

15e. Disclosure of Your Information
We may need to disclose specific personal data to third party software providers in order for them to provide support and maintenance services on the Application.

16. Spindle Document Distribution Browser Extension
This Extension allows Spindle Document Distribution users to send PDF files directly to Spindle Document Distribution from chromium browsers without the need to download and save the file. Once installed the extension will create a button on a PDF file that is viewed within a browser. A user can then click on the button and the extension sends the file through to the Spindle Document Distribution client application. Draycir are neither the Controller nor the direct Processor of any data.

16a. Sensitive personal information
PDF files handled by the Extension may contain data within them that is deemed personal. However, the Spindle Document Distribution Browser Extension does not collect or store any data about you. All data is kept only within your local network.

17. How To Contact Us
You can contact us in connection with any matter set out in this policy using the following details:

• By telephone on 0116 255 3010
• By email support@draycir.com
• Or write to us at Draycir Ltd, 95 Princess Road East, Leicester, LE1 7DW

ICO Registration Number: Z2920326

This privacy policy was updated on 6th August 2024. (v6).