- Who are we?
- We are Lucidx Ltd . We are a tech company providing digital marketing services to our global client base. Our processing is based primarily on the use of publicly available data to identify sales prospects for our clients. As such your privacy is important to us, we take our responsibilities seriously and will always respond quickly and courteously to any request. You can contact us using the details below.
- By email to our Data Protection Officer: email@example.com
By post to Our registered office The Dell, Cookham Dean,Maidenhead,Berkshire, SL6 9UF.
- By telephone on: 01628 476240
- Our GDPR Policy
- We are committed to safeguarding the privacy and accuracy of the personal
data of Our website visitors, service users and email recipients.
- This policy applies where we are acting as a Controller with respect to the personal data of our website visitors, service users, email recipients and personal data collected from public sources; in other words, where we determine the purposes and means of the processing of that personal data.
- This policy also applies where we determine the purpose and means of the processing jointly with our clients and other companies, or where we are acting as a Processor, working on behalf of our clients to process data as required by them.In this policy, “We”, “Us” and “Our” refer to Lucidx Ltd – trading as SoPro.
- Any reference to a Data Subject means a natural person whose personal data is processed by us as a Data Controller, Joint Controller or as a Data Processor, in other words, you.
- We are committed to safeguarding the privacy and accuracy of the personal
- How We use Your personal data
- We want to be clear with you about how we use your data so in this section we talk about the general categories of personal data that we may process and in the case of personal data that we did not obtain directly from you we’ll tell you where we got your data and the purposes for which we may process your data; finally, and very importantly we’ll explain the legal bases of the processing which applies to us and you.
- The General Categories of Personal Data That We May Process:
- Usage Data. We may process data about Your use of our website and services (“Usage Data“). The Usage Data may include Your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the Usage Data is Google Analytics as well as our analytics tracking system. This Usage Data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services, and tailoring any communication with you. We of course use this data to help us run our business as well as we can.
- Account Data. We may process Your Account Data (“Account Data“). The Account Data may include your name, email address, company information, and other contact and other related information we may collect about you. The source of the Account Data is generally you or your employer. The Account Data may be processed for the purposes of providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is the performance of a contract between you and us [or your employer] and/or taking steps, at your request, to enter into such a contract. In some cases we may also rely on Legitimate Interest as our lawful basis where we use your data for marketing purposes or in order to operate our business and improve our services.
- Service Data. We may process your personal data that are provided in the course of the use of our services (“Service Data“). The Service Data may include name, email address, telephone number, and other related information. The source of the Service Data is you or your employer. The Service Data may be processed for the purposes of providing our services and communicating with you. The legal basis for this processing is the performance of a contract between You and Us and/or taking steps, at your request, to enter into such a contract.
- Enquiry Data. We may process information contained in any enquiry You submit to us regarding goods and/or services (“Enquiry Data“). The Enquiry Data may be processed for the purposes of us offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is consent which may be withdrawn by You at any time by contacting us or contract and/or legitimate interest where your requests represents an invitation to send you information about our services.
- Notification Data. We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“Notification Data“). The Notification Data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent which may be withdrawn by you at any time by contacting Us.
- Correspondence Data. We may process information contained in or relating to any communication that you send to Us (“Correspondence Data“). The Correspondence Data may include your name, email address and the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The Correspondence Data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
- Public Data. We may process information found on public social networking profiles (“Public Data“) and other from other publicly available sources. This data may include name, employment information, career information. education details, job title, and other relevant information. Public Data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you and/or your employer. The legal basis for this processing is our legitimate interests, namely the administration of our business, to develop our business, and in order for us to make a profit.
- Legal Claims Data. We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. (“Legal Claims Data”) The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
- Professional Use Data. We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. (“Professional Use Data”). The legal basis for processing Legal Claims Data is our legitimate interests, namely the proper protection of Our business against risks.
- Third Party Data. We may process any of your personal data where we purchase this data from a third party. This includes name, address, email, phone number, other contact details, employment details etc… Where we purchase data we will ensure that the supplier has the appropriate lawful basis in place and is GDPR compliant. We will also ensure that we have appropriate evidence of consent where necessary or have an alternative appropriate lawful basis and GDPR compliance processes in place to allow us use your data.
- In addition to the specific purposes for which we may process your personal data we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
- Our Legitimate Interest
- Our lawful bases for processing includes our Legitimate Interest to process your data. In this regard we have carefully considered your rights and expectations of privacy and our rights [and the rights of our clients] to run our business. We have considered the impact on your privacy as a result of our processing of your data and completed a balancing assessment to consider the impact on the data subjects involved and also completed a Data Protection Impact Assessment to ensure we take appropriate precautions with all data. These Legitimate Interest and Data Protection Impact Assessments helped us ensure that the rights of the data subjects are not unduly impacted and that processing of data in this way is acceptable.
- 11.Source of your Personal Data
- We use a range of sources to provide our services including public domain and social media sources. Our approach is based on carefully targeting business contacts with offers that we believe they will be interested in. We carefully select representatives from businesses and then only send relevant offers. Where we source data from other third parties, we will ensure these companies are GDPR compliant and that your rights are at all times protected.
- 13.Sharing Your personal data with others
- In addition we may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) (together known as “Group Companies”) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.
- We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
- We may also disclose your personal data to our suppliers, partners and other carefully managed third parties as required to operate our company and provide our services. Where this is the case, we will always ensure appropriate technical and administrative controls are in place.
- As you would expect, in addition to the specific disclosures of personal data set out above, we may disclose your personal data where such disclosure is necessary for compliance with a binding legal obligation.
- 15.International transfers of Your personal data
- In this section we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (“EEA”). We and Our other Group Companies have offices and facilities in Macedonia where your personal data may be processed. Transfers to Macedonia will be protected by appropriate technical and administrative safeguards included in our Terms of Contract for data processing agreed between us and our Macedonian counterparts which of course includes the standard clauses required under GDPR.
- Remember that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
- 17.Retaining and deleting personal data
- This section sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data. Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
- Notwithstanding the other provisions of this section we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
- By using Our website and agreeing to this policy, You consent to Our use of
- By using Our website and agreeing to this policy, You consent to Our use of
- 21.Automated Processing
- We may use automated processing and decision making to verify your contact details and to determine whether to contact you as part of a prospecting campaign on behalf of our clients. This decision making is simply used to determine whether the campaign is likely to be of interest to you and to verify your contact details.
- 23.The Rights of Data Subjects
- In this section we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
- Your principal rights under data protection law are:
- The right to be informed
- the right to access
- the right to rectification
- the right to erasure
- the right to restrict processing
- the right to object to processing
- the right to data
related to automated decision making including profiling
- the right to complain to a supervisory
- the right to withdraw
- The Right To Access. You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, We will supply to You a copy of Your personal data upon request and within one month of verification of Your identity (We may extend the time within which We must provide the information by a further two months if the request is particularly complex or if there are numerous requests and We will let You know if this is the case. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
- The Right to Rectification. You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about You completed. If the request is accepted by us, the rectification will be completed within one month (may be extended by us by a further two months if complex).We will use all reasonable endeavours to notify any third party with whom we have shared the data of any rectifications made.
- The Right to Erasure (also known as the “Right to be Forgotten”). In some circumstances you have the right to the erasure of your
personal data without undue delay. However, there are exclusions of the right to erasure. We will use all reasonable endeavours to notify any third party with whom we have shared the data of any actioned erasure requests.
- The Right to Restrict Processing. In some circumstances you have the right to restrict the processing of your personal data. Where processing has been restricted, we may continue to store your personal data. However, we will only otherwise process it: with your consent or for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest. We will use all reasonable endeavours to notify any third party
with whom we have shared the data of any restriction placed on the processing of Your data.
- The Right to Object to Processing. You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for certain tasks.
If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override Your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
- The Right to Data Portability. To the extent that the legal basis for our processing of your personal data is:
- consent; or
- that the processing is necessary for the performance of a contract to which you are party or in order to take steps at Your request prior to entering into a contract
- such processing is carried out by automated means,
- You have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
- Rights related to automated decision-making including profiling. We do not use automated decision making (including profiling) when processing your data.
- Right to Complain. If you consider that our processing of your personal information infringes data protection laws, you should first contact us. If you are dissatisfied with the outcome, you have a legal right to lodge a complaint with a Supervisory Authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
By email at: firstname.lastname@example.org
By telephone on: 01628 476240
- If you remain unsatisfied by our response you may complain to the Information Commissioners offices at the following address:
- 26.Information Commissioner’s Office
- 28.Amendments to this policy
- We may update this policy from time to time by publishing a new version on our website.
- You should check this page occasionally to ensure you are happy with any changes to this policy.
- We may notify You of changes to this policy by email.
Lucidx Ltd (“We”) are committed to protecting and respecting your privacy.
Definitions and interpretation
collectively all information that you submit to Lucidx via the Website. This definition incorporates, where applicable, the definitions provided in the Data Protection Laws;
a small text file placed on your computer by this Website when you visit certain parts of the Website and/or when you use certain features of the Website. Details of the cookies used by this Website are set out in the clause below (Cookies);
Data Protection Laws
any applicable law relating to the processing of personal Data, including but not limited to the Directive 96/46/EC (Data Protection Directive) or the GDPR, and any national implementing laws, regulations and secondary legislation, for as long as the GDPR is effective in the UK;
the General Data Protection Regulation (EU) 2016/679;
Lucidx, or us
Lucidx, a company incorporated in England and Wales with registered number 144 whose registered office is at Brockley Grove, London, SE4 1EB;
UK and EU Cookie Law
the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended by the Privacy and Electronxic Communications (EC Directive) (Amendment) Regulations 2011;
User or you
any third party that accesses the Website and is not either (i) employed by Lucidx and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to Lucidx and accessing the Website in connection with the provision of such services; and
the website that you are currently using, http://lucidx.co.uk/, and any sub-domains of this site unless expressly excluded by their own terms and conditions.
- a.the singular includes the plural and vice versa;
- c.a reference to a person includes firms, companies, government entities, trusts and partnerships;
- d.“including” is understood to mean “including without limitation”;
- e.reference to any statutory provision includes any modification or amendment of it;
- 4.For purposes of the applicable Data Protection Laws, Lucidx is the “data controller”. This means that Lucidx determines the purposes for which, and the manner in which, your Data is processed.
- 5.We may collect the following Data, which includes personal Data, from you:
- b.IP address (automatically collected);
- c.web browser type and version (automatically collected);
- d.email address;
How we collect Data
- 6.We collect Data in the following ways:
- a.data is given to us by you;
- b.data is received from other sources; and
- c.data is collected automatically.
Data that is given to us by you
- 7.Lucidx will collect your Data in a number of ways, for example:
- a.when you contact us through the Website, by telephone, post, e-mail or through any other means;
- b.when you register with us and set up an account to receive our products/services;
- c.when you complete surveys that we use for research purposes (although you are not obliged to respond to them);
- d.when you enter a competition or promotion through a social media channel;
- e.when you elect to receive marketing communications from us;
- f.when you use our services;
Data that is received from third parties
- 8.Lucidx will receive Data about you from the following third parties:
- b.Google Adwords;
Data that is received from publicly available third parties sources
- 9.We will receive Data about you from the following publicly available third party sources:
Data that is collected automatically
- 10.To the extent that you access the Website, we will collect your Data automatically, for example:
- a.we automatically collect some information about your visit to the Website. This information helps us to make improvements to Website content and navigation, and includes your IP address, the date, times and frequency with which you access the Website and the way you use and interact with its content.
- b.we will collect your Data automatically via cookies, in line with the cookie settings on your browser. For more information about cookies, and how we use them on the Website, see the section below, headed “Cookies”.
Our use of Data
- 11.Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Website. Specifically, Data may be used by us for the following reasons:
- a.improvement of our products / services;
- b.transmission by email of marketing materials that may be of interest to you;
- c.contact for market research purposes which may be done using email, telephone, fax or mail. Such information may be used to customise or update the Website;
- 12.We may use your Data for the above purposes if we deem it necessary to do so for our legitimate interests. If you are not satisfied with this, you have the right to object in certain circumstances (see the section headed “Your rights” below).
- 13.For the delivery of direct marketing to you via e-mail, we’ll need your consent, whether via an opt-in or soft-opt-in:
- a.soft opt-in consent is a specific type of consent which applies when you have previously engaged with us (for example, you contact us to ask us for more details about a particular product/service, and we are marketing similar products/services). Under “soft opt-in” consent, we will take your consent as given unless you opt-out.
- b.for other types of e-marketing, we are required to obtain your explicit consent; that is, you need to take positive and affirmative action when consenting by, for example, checking a tick box that we’ll provide.
- c.if you are not satisfied about our approach to marketing, you have the right to withdraw consent at any time. To find out how to withdraw your consent, see the section headed “Your rights” below.
- 14.When you register with us and set up an account to receive our services, the legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
- 15.We may use your Data to show you Lucidx adverts and other content on other websites. If you do not want us to use your data to show you Lucidx adverts and other content on other websites, please turn off the relevant cookies (please refer to the section headed “Cookies” below).
Who we share Data with
- 16.We may share your Data with the following groups of people for the following reasons:
- a.our employees, agents and/or professional advisors – to obtain advice from professional advisers;
Keeping Data secure
- 17.We will use technical and organisational measures to safeguard your Data, for example:
- a.access to your account is controlled by a password and a user name that is unique to you.
- b.we store your Data on secure servers.
- 18.Technical and organisational measures include measures to deal with any suspected data breach. If you suspect any misuse or loss or unauthorised access to your Data, please let us know immediately by contacting us via this e-mail address: email@example.com.
- 19.If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
- 21.Even if we delete your Data, it may persist on backup or archival media for legal, tax or regulatory purposes.
- 22.You have the following rights in relation to your Data:
- a.Right to access – the right to request (i) copies of the information we hold about you at any time, or (ii) that we modify, update or delete such information. If we provide you with access to the information we hold about you, we will not charge you for this, unless your request is “manifestly unfounded or excessive.” Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.
- b.Right to correct – the right to have your Data rectified if it is inaccurate or incomplete.
- c.Right to erase – the right to request that we delete or remove your Data from our systems.
- d.Right to restrict our use of your Data – the right to “block” us from using your Data or limit the way in which we can use it.
- e.Right to data portability – the right to request that we move, copy or transfer your Data.
- f.Right to object – the right to object to our use of your Data including where we use it for our legitimate interests.
- 23.To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Data (where consent is our legal basis for processing your Data), please contact us via this e-mail address: firstname.lastname@example.org.
- 24.If you are not satisfied with the way a complaint you make in relation to your Data is handled by us, you may be able to refer your complaint to the relevant data protection authority. For the UK, this is the Information Commissioner’s Office (ICO). The ICO’s contact details can be found on their website at https://ico.org.uk/.
- 25.It is important that the Data we hold about you is accurate and current. Please keep us informed if your Data changes during the period for which we hold it.
Links to other websites
Changes of business ownership and control
- 28.We may also disclose Data to a prospective purchaser of our business or any part of it.
- 29.In the above instances, we will take steps with the aim of ensuring your privacy is protected.
- 31.All Cookies used by this Website are used in accordance with current UK and EU Cookie Law.
- 32.Before the Website places Cookies on your computer, you will be presented with a message bar requesting your consent to set those Cookies. By giving your consent to the placing of Cookies, you are enabling Lucidx to provide a better experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of the Website may not function fully or as intended.
- 33.This Website may place the following Cookies:
Type of Cookie
Strictly necessary cookies
These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
- 34.You can find a list of Cookies that we use in the Cookies Schedule.
- 35.You can choose to enable or disable Cookies in your internet browser. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser.
- 36.You can choose to delete Cookies at any time; however you may lose any information that enables you to access the Website more quickly and efficiently including, but not limited to, personalisation settings.
- 37.It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your internet browser if you are unsure about adjusting your privacy settings.
- 38.For more information generally on cookies, including how to disable them, please refer to aboutcookies.org. You will also find details on how to delete cookies from your computer.
- 41.Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.
- 42.This Agreement will be governed by and interpreted according to the law of England and Wales. All disputes arising under the Agreement will be subject to the exclusive jurisdiction of the English and Welsh courts.
31 May 2018
Below is a list of the cookies that we use. We have tried to ensure this is complete and up to date, but if you think that we have missed a cookie or there is any discrepancy, please let us know.
We use the following strictly necessary cookies:
Description of Cookie
We use this session cookie to remember you and maintain your session whilst you are using our website.
We use the following analytical/performance cookies:
Description of Cookie
We use this cookie to help us analyse how users use the website
We use the following targeting cookies:
Description of Cookie
We use this cookie to enable us to show you adverts while you are browsing our website and other websites on the internet