1.1 Hyperexponential Ltd (“we” or “us”) takes the privacy of your information very seriously. Our Privacy Notice is designed to tell you, the user of our services about our practices regarding the collection, use and disclosure of personal information which may be provided to us via our websites, SaaS platform, associated apps and other digital products we provide or collected through other means such as an online form, email, or telephone communication.
1.2. In this notice “you” refers to any individual whose personal data we hold or process (other than our staff).
1.3 In this notice references to the “Service” are references to any website, app or other means by which you provide personal data to us or access our services.
1.4 This notice is governed by applicable data or privacy legislation (including the EU General Data Protection Regulation (the “GDPR”), retained EU law version of the GDPR (“UK GDPR”) and Data Protection Act 2018). This notice may be updated from time to time and you should check this page regularly for any updates. Changes to this notice are effective when they are posted on this page.
Personal data we collect as controller
2.1 As a data controller, we may collect, hold or process the following personal data (information that can be uniquely identified with you) about you:
2.1.1 log-in details and information you provide when registering or creating an account with the Service including contact information (“Login Information”) we will use this information to ensure that our users can access our Service securely and to verify who is using the Service;
2.1.2 contact information we collect from you as customer either about you or your employees (for example, names, email addresses, information about your role within our customer’s organisation) (“Contact Information”) which we will use to communicate with you;
2.1.3 a record and details of any correspondence or communication between you and us or relating to any complaint submitted to us (“Communication Information”);
2.1.4 details of your visits to the Service, the resources and pages that you access and any actions you perform (“Technical Information”) which we will use to monitor and improve performance and reliability and to analyse the use of our Service for development purposes;
2.1.5 information we may hold for the purposes of marketing such as your email address (“Marketing Information”) which we use to communicate with you about our Service;
2.1.6 information you submit when using the Service including replies to any surveys or questionnaires that we may use for research, product and service development, marketing and business development purposes (“Statistical and Survey Information”).
2.2 We process all of the data listed above on the basis of our legitimate interest in supplying services to our customer, and developing the Service.
2.3 Generally we will collect personal data directly, but we may obtain data from third parties from time to time. If we do obtain your personal data from a third party your privacy rights under this notice are not affected and you are still able to exercise the rights contained within this notice.
2.4 You do not have to supply any personal information to us but the Service will not be operable without providing data to us.
2.5 You may withdraw our authority to process your personal data (or request that we restrict our processing – see below – ‘your privacy rights’) at any time and we will cease processing your data as soon as possible but we will be entitled to complete processing actions we are then undertaking and we may need to withhold some personal data for legal or other reasons (see below).
Personal data we hold as a data processor
3.1 There is certain information we collect that we hold as ‘data processor’. This may include the name, address, age and other personal information relating to customers or clients of our customer. We may host this data to allow our clients to run certain actuarial and analytical models.
3.2 Our customer is the data controller for this data and we are processing this data on our customer’s behalf. Our terms require that our customer processes this data in accordance with applicable data protection legislation. If you, as a data subject whose data is controlled by our customer, require us to cease processing or delete such data or if you otherwise would like to exercise your rights as a data subject please contact our customer to make the relevant request.
3.3 In our terms with our customers this is defined as ‘Hosted Data’ and in our terms with customers we set out in accordance with the GDPR our obligations to the customer in relation to the Hosted Data we hold or process.
3.4 Key information about Hosted Data we process as processor is set out below:
Who are the relevant data subjects?
The data subjects are customers or, clients of our customers, whose information is hosted in our Service and processed in the Service using our customer’s actuarial models in order to analyse risk.
What is the subject matter of this personal data?
Name, age, address, marital status, health status and history, employment status and other information relevant for the purposes of our customers risk model.
For how long is the relevant personal data processed and retained? (duration)
The data will be retained for so long as our customer keeps this data with us.
If our customer unsubscribes from the Service, we will delete all the Hosted Data we hold within 30 days or later with the consent of our customer who is the controller of this data.
How is the relevant personal data processed? (Nature and purpose)
The personal data will be stored in our servers and may be applied to risk models and algorithms developed by our customer in order to ascertain the risk associated with a given product or policy and calculate an appropriate price to the relevant risk or policy.
What are the obligations and rights in relation to the relevant personal data?
If we are a data processor on behalf of our customer we will process the data in accordance with our agreement with our customer.
If we are the data controller we will process the data in accordance with this notice.
Cookies and IP Address
4.1 A cookie is a piece of data stored locally on your computer and contains information about your activities on the Internet. The information in a cookie does not contain any personally identifiable information you submit to our websites (“Site”).
4.4 If you choose not to accept the cookies then essential functionality of our Service will not be available and you will be unable to use the Service.
4.5 An Internet Protocol (IP) address is a number assigned to your computer by your Internet Service Provider (ISP), so you can access the Internet. We may use your IP address to diagnose problems with our server, report aggregate information, and determine the fastest route for your computer to use in connecting to our Site, and to administer and improve the Site.
5.1 Our current data retention policy is to delete or destroy (to the extent we are able to) the personal data we hold about you in accordance with the following:
Category of personal data: Length of retention
Personal data processed in relation to a contract between us and our customer: 7 years from either the end of the contract, being the length of time following a breach of contract in which a contract party is entitled to make a legal claim
Personal data held on marketing or business development records: 5 years from the last date on which you have interacted with us
Hosted data: 30 days from the end of the contract between us and our customer or later with the consent of our customer who is the controller of this data.
5.2 For any category of personal data not specifically defined in this notice, and unless otherwise specified by applicable law, the required retention period for any personal data will be deemed to be 7 years from the date of receipt by us of that data or (if later) the end of the relevant contract, arrangement or interaction with that person.
5.3 The retention periods stated in this notice can be prolonged or shortened as may be required (for example, in the event that legal proceedings apply to the data or if there is an on-going investigation into the data).
5.4 We review the personal data (and the categories of personal data) we are holding on a regular basis to ensure the data we are holding is still relevant to our business and is accurate. If we discover that certain data we are holding is no longer necessary or accurate, we will take reasonable steps to correct or delete this data as may be required.
5.5 If you wish to request that data we hold about you is amended or deleted, please see below (‘your privacy rights’), which explains your privacy rights.
Sharing your information
6.1 We do not disclose any personal data you provide to any third parties other than as follows:
6.1.1 we may host personal data with third party hosting partners;
6.1.2 our product development and IT technical support providers may have access to personal data;
6.1.3 certain other third party suppliers such as website developers, marketing and business development service providers may have access to certain personal data supplied by our customers or prospective customers, but we will not share your data with such suppliers without your permission supplied by employees of our customers when using the Service;
6.1.4 where we carry out research to gain an insight into the use of our services, the results of this research (but not the personal data itself) may be transferred to interested third parties;
6.1.5 if we are under a duty to disclose or share your personal data in order to comply with any legal obligation (for example, if required to do so by a court order or for the purposes of prevention of fraud or other crime);
6.1.6 in order to enforce any terms and conditions or agreements for our services that may apply;
6.1.7 we may transfer your personal information to a third party as part of a sale of some or all of our business and assets to any third party or as part of any business restructuring or reorganisation, but we will take steps with the aim of ensuring that your privacy rights continue to be protected;
6.1.8 to protect our rights, property and safety, or the rights, property and safety of our users or any other third parties. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
6.2 Our server infrastructure is provided by Amazon Web Services. Please note that Amazon Web Services store and process data in accordance with UK and EU law by operating in accordance with data processing terms in accordance with GDPR and ‘model clauses’ approved by the EU’s Article 29 Working Party. More information can be found at the following link: http://aws.amazon.com/compliance/eu-data-protection/.
6.3 Other than as set out above, we shall not disclose any of your personal information unless you give us permission to do so. If we do supply your personal information to a third party we will take steps to ensure that your privacy rights are protected and that third party complies with the terms of this notice.
7.1 We will take all reasonable steps to ensure that appropriate technical and organisational measures are carried out in order to safeguard the information we collect from you and protect against unlawful access and accidental loss or damage. These measures may include (as necessary):
7.1.1 protecting our servers by both hardware and software firewalls;
7.1.2 locating our data processing storage facilities in secure locations;
7.1.3 encrypting all data stored on our server with an industry standard encryption method that encrypts the data between your computer and our server so that in the event of your network being insecure no data is passed in a format that could easily be deciphered;
7.1.4 ensuring that all communication with our servers is encrypted through Secure Sockets Layer (SSL), an industry standard encryption method that encrypts data between your computer and our servers so that in the event of your network being insecure no data is passed in a format that could easily be deciphered;
7.1.5 when necessary, disposing of or deleting your data so it is done so securely;
7.1.6 regularly backing up and encrypting all data we hold.
7.2 We will ensure that our employees and staff are aware of their privacy and data security obligations. We will take reasonable steps to ensure that the employees/staff of third parties working on our behalf are aware of their privacy and data security obligations.
7.3 This notice and our procedures for handling personal data will be reviewed as necessary.
7.4 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 the Service. Once we have received your information, we will use the procedures and security features referred to in this notice to try to prevent unauthorised access.
Your privacy rights
8.1 With respect to your personal data, you have the right to:
8.1.1 request that your personal data will not be processed;
8.1.2 ask for a copy of any personal data that we have about you;
8.1.3 request a correction of any errors in or update of the personal data that we have about you;
8.1.4 request that your personal data will not be used to contact you for direct marketing purposes;
8.1.5 request that your personal data will not be used for profiling purposes;
8.1.6 request that your personal data will not be used to contact you at all;
8.1.7 request that your personal data be transferred or exported to another organisation, or deleted from our records; or
8.1.8 at any time, withdraw any permission you have given us to process your personal data
8.2 All requests or notifications in respect of your above rights may be sent to us in writing at the contact details listed below.
8.3 We will endeavour to comply with such requests as soon as possible but in any event we will comply within one month of receipt (unless a longer period of time to respond is reasonable by virtue of the complexity or number of your requests).
9.1 If personal data we hold about you is subject to a breach or unauthorised disclosure or access, we will report this to our data protection manager or officer (if an officer has been appointed) or the Information Commissioner’s Office (ICO) (as necessary).
9.2 If a breach is likely to result in a risk to your data rights and freedoms, we will notify you as soon as possible.
10.1 Our Service may contain links and references to other services and websites. Please be aware that this notice does not apply to those services or websites.
10.2 We cannot be responsible for the privacy policies and practices of sites and services that are not operated by us, even if you access them via the Service. We recommend that you check the policy of each site you visit and contact its owner or operator if you have any concerns or questions.
Transferring your information outside the UK or EEA
11.1 As part of the services provided to you the information you provide to us may be transferred to, processed and stored at, countries or international organisations outside of the UK and European Economic Area (“European Area”).
11.2 Our server infrastructure is provided by Amazon Web Services and is currently based in the European Area (although servers may from time to time be based in other countries). Please note that if Amazon Web Services transfer and store data outside of the European Areathey will do so in accordance with European Arealaw. More information can be found at the following link: http://aws.amazon.com/compliance/eu-data-protection/.
11.3 We have customers who have offices and users who are outside of the European Areaor access our services from outside the European Areaand in those circumstances personal data may be transferred outside of the European Area.
11.4 We will not transfer the personal data of UK and EEA data subjects in a systematic way outside of the European Areaother than as described above but there may be circumstances in which certain personal information is transferred outside of the European Area, in particular:
11.4.1 if you use our Service while you are outside the European Area, your information may be transferred outside the European Areain order to provide our Service;
11.4.2 we may communicate with individuals or organisations outside of the European Areain providing our Service, those communications may include personal information (such as contact information);
11.5 From time to time your information may be stored in devices which are used by our staff outside of the European Area (but staff will be subject to our cyber-security policies).If we transfer your information outside of the European Area, and the country or organisation to whom we transfer this information has not been deemed by the EU Commission or UK Secretary of State (as the case may be) to have adequate data protection laws, we will provide appropriate safeguards and we will be responsible for ensuring your privacy rights continue to be protected as outlined in this notice. If you would like to obtain details of the safeguards we have put in place then please contact us using the contact details at the end of this notice.
Notification of changes to the contents of this notice
We will post details of any changes to our policy to help ensure you are always aware of the information we collect, how we use it, and in what circumstances, if any, we share it with other parties.
If at any time you would like to contact us with your views about our privacy practices, or with any enquiry or complaint relating to your personal information or how it is handled, you can do so via the following email address: email@example.com
If we are unable to resolve any issues you may have or you would like to make a further complaint, you can contact the Information Commissioner’s Office by visiting http://www.ico.org.uk/ for further assistance.