the basis on which any personal data we collect from you, or that you provide to us, will be processed by us, whether you are a
visitor to the site or a customer that subscribes to our services online or over the phone.
Who we are
Aberdeen, Scotland, AB15 4ZT, company number SC115090. Millstream is the data controller and is part of the PROACTIS Holdings
Plc group of companies.
Where we got your information
We collect and process the following information about you either from your use of our site, or your correspondence with us by phone or email:
Information you give us. We collect and store the personal information that you submit through the site
or by corresponding with us by phone, email or otherwise. This includes information that you provide when you register to
use our site or subscribe to any of our services. The information you give us may include your name, postal address, email
address, telephone number, details of any comments you provide to us, payment information and any documents you may upload
containing your personal information. We may also collect and process records of any correspondence and communications with
us and telephone calls may also be recorded.
Information we collect about you. We also collect and store the following information regarding each of your visits to our site:
technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your
login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and
information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our
site (including date and time), products and / or services you viewed or searched for, page response times, download
errors, length of visits to certain pages, page interaction information (such as scrolling, clicks and mouse-overs),
and methods used to browse away from the page.
What we need and why we need it
We may use information we hold about you in the following ways:
Information you give us. We will use this information:
to carry out our obligations arising from any agreements entered into between you and us and to provide you with the information,
products and services that you request from us;
to notify you about changes to any of our services;
to communicate with you to gain feedback on our products or services in order to improve them;
to ensure that content from our site is presented in the most effective manner for you and for your computer;
to administer your attendance at training courses;
to respond to any queries you may raise via LiveChat on our website;
to administer any contest or other promotional feature that you may enter with us and to notify winners; and
to provide you with information about other goods and services we offer that are similar to those that you have already purchased
or enquired about, as further detailed in the 'Marketing' section below.
Information we collect about you. We will use this information:
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 or mobile
as part of our efforts to keep our site safe and secure; and
to make suggestions and recommendations to you about services that may interest you.
Our legal basis for using your information
The legal grounds on which we rely to use your information are:
To allow us to perform our contract with you: When you purchase services from us, a contract between you and us will have
been entered into. In order for us to fulfil our obligations under such contract, we will need to collect and process your personal information,
including payment information. Failure to provide the requisite personal information on sign-up and payment information on entering into the
contract or objecting to this type of processing / exercising your deletion rights will mean that we cannot provide our services to you.
To allow us to exercise our legitimate interests as a data controller: We rely on our legitimate interests as a data controller
to process the personal information that you provide to us on feedback forms or through any contest or promotional feature that we may run, and
to process personal information that we collect from you when you use our site. It is in our legitimate interests as a business to process the
above information in to order administer our site, to ensure that content from our site is presented to you effectively and securely, and to run
contests and other promotional features.
We may use your personal information to contact you about other goods and services we offer that are similar to those that you have already purchased
or enquired about. You will be given an option to opt-out of such marketing when you subscribe to a service.
We and other companies within our group (for full details, see www.proactis.com) may also use your personal information to contact you about other
goods and services, provided you have given your consent.
You may withdraw your consent to the use of any of your personal information for marketing purposes, at any time by contacting us at
firstname.lastname@example.org. You will also be given the opportunity in each marketing communication to opt-out of future marketing communications.
Your payment information
If you sign up to purchase our Quarterly Plan subscription and consent to auto-renewal subscriptions (as set out in our Product Terms and Conditions),
your payment information (such as credit or debit card details) and other information that we need to process your payment will be collected and
stored by us and / or the payment processors with which we work.
We use your payment information to charge the applicable sum to your payment card and renew your purchase, in order to provide the services that you
subscribe to (including any Add Ons that you may request) and to perform the contract between you and us.
How long we hold your data
With the exception of auto-renewal Quarterly Plan subscriptions, we do not retain your payment information, and this information will be immediately
deleted once your payment is processed.
Where you have signed up for an auto-renewal Quarterly Plan subscription, our payment processors will retain your payment information and store it
until you cancel your auto-renewal subscription. If you cancel your auto-renewal subscription, we will delete your payment information as soon as
possible once your last payment is processed.
We will only hold your information for as long as it is required for the purposes for which it was obtained. There may be instances where we keep
your personal information for longer periods for legal and regulatory purposes, such as to comply with our audit or revenue reporting obligations.
If you are not a customer and we have collected information about you, this will be deleted within 2 years.
Storage of your information, international data transfers and security
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 your password with anyone.
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 prevent unauthorised access.
Disclosure of Your Information
We won’t share your information with third parties, save as follows:
with our payment processors for the purposes of processing your payment;
with third party analytics suppliers that work with us for the purposes of producing aggregate statistics about customers, sales, traffic
patterns and related site information – we use this information for the purposes detailed above and the third party suppliers use this information
to inform their own analytics products and services;
if you have opted-in to receive targeted marketing via Facebook, we will upload data onto Facebook for that purpose;
with other members of our group for the purposes of marketing and only where you have provided your consent, as described above; and
with our event and training suppliers to allow us to deliver training, information sharing and events that you have opted to take part in.
We do not use your personal data to undertake any automated decision-making.
You have certain rights in relation to your personal information that is processed by us. These rights are listed below. These rights are not
absolute and apply subject to certain conditions, as set out in applicable data protection laws. Your rights may include:
the right to access personal data held by us about you;
the right to require us to rectify any inaccurate personal data held by us about you;
in certain circumstances, the right to require us to erase personal data held by us about you;
in certain circumstances, the right to restrict our processing of personal data held by us about you;
in certain circumstances, a right to receive personal data which you have provided to us in a structured, commonly used and machine readable
format. You may also have the right to require us to transfer this personal data to another organisation, at your request;
the right to object to our processing of personal data held by us about you (including for the purposes of sending marketing materials to you); and
the right to withdraw your consent, where we are relying on it to use your personal data (for example, to provide you with marketing information about our services and products).
You can exercise these rights be contacting us using the details set out above.
Changes to this policy
Concerns or complaints
Information Commissioner's Office using the details set out on its website, which is currently: https://ico.org.uk/global/contact-us/.