Saltwater Consulting is committed to protecting and respecting your privacy. This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed. Please read this policy carefully to understand our practices regarding how we treat your personal data.
By visiting Saltwater Consulting (“Website”), you accept and consent to the practices described in this policy. If you do not accept the terms of this policy, please refrain from using the Website. This policy is in direct response to the requirements of the General Data Protection Regulation 2016/679 (GDPR).
Your personal data is ultimately controlled by Saltwater Consulting Ltd, a company registered in Ireland (Registration Number, 668911) whose registered office is at 161 Lower Rathmines Road, Dublin 6, D06C8P3, Ireland.
Unless prohibited by law or other applicable regulatory requirements your personal information may be shared with any affiliate company within our group.
Our Data Protection Officer can be contacted using the following email address: firstname.lastname@example.org or alternatively by writing to the address above and marking it for the attention of the Data Privacy Officer.
Information we may collect and hold about you
We may collect and process the information you have provided us with, such as your name, email address, mailing address, and contact details.
You provide us with information about yourself by:
- Filling in forms on the Website;
- Contacting us by phone, email or physical mail;
- Asking us to contact you in relation to services we provide;
- Subscribing to our mailing lists, newsletters or bulletins;
- Completing any surveys we send you;
- Booking a seminar or event run by us;
- Visiting our offices;
- Ordering products or services from us;
- Requesting downloads of documentation or software;
- Requesting support related to software or services;
- Interacting with us on social media platforms (such as LinkedIn or Twitter); or
- Reporting a problem with our Website.
When you visit our Website, we may also collect information about you, including, but not limited to, your IP address, approximate location (town/city level), time of access, the browser you use, your operating system, the pages you visit and what website you came from.
We may ask you to complete surveys that we use for research purposes.
We may use legal public sources to obtain information about you. We only obtain information from third parties when permitted by law.
Retention of your information
If we are providing services to you, we will retain your personal information for the duration of the services and for six years thereafter, unless otherwise agreed.
Complaints and Feedback
If you have an existing, open agreement for services with us and you make a complaint or provide other feedback in a format other than those described below, we retain a record of your complaint or feedback for the life of the agreement plus 24 months or until such time as the complaint has been satisfactorily resolved. If you are in contact with us during the course of a sale or as part of negotiations for a sale, we will keep a record of previous complaints or feedback until a purchase is made, or for six months when no purchase is made.
If you choose to provide us with feedback:
- For service feedback surveys, we retain your data for a maximum of 24 months.
- For Score surveys, product surveys, and general marketing surveys, we retain your data for a maximum of 24 months.
- Data collected through event registration, events requirements, and market research, will be retained for a maximum of 24 months; and
- Where you provide us with ‘quotable feedback’, for which we ask your permission, we will retain and use the data for up to 5 years in the format in which you granted permission (for example, if you requested anonymity, or agreed to us assigning the feedback to you at a certain company).
We review and delete or destroy personal data on a regular basis. If we are unable, using reasonable effort, to delete or destroy the personal data, we ensure that it is encrypted or protected by other security measures so that it is not readily available or accessible by us.
How we use your information
In addition to using your information to fulfil our contract with you, we may also use your information in the following ways (provided, you have given consent where required):
- To monitor our website and improve our products and services;
- To provide you with information about other goods and services we offer that we feel may be of interest to you because they are similar to what you’ve already purchased or asked about;
- To let you know about changes to our services;
- To administer the Website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- To enable us to comply with any legal or regulatory requirements.
If you agree to advertising cookies, the LinkedIn Insight and Google Analytics cookies tie your IP address to any member accounts you have on their respective platforms. Google / LinkedIn do not tell us who you are, but as they can identify you we have included key information about this use of your data here.
These cookies track what URLs are of interest to you – so that we can give you relevant information on our services by targeting advertisements. The data we have access to is hashed to the point where we won’t be able to profile you based on your visit, but it can be used to distribute ads based on services you are interested in. The profiling data on users is removed within seven days to help keep your visits anonymous. LinkedIn and Google do not share that personal data with Saltwater Consulting, but rather give reports as to how many web visits can be tied back to a member account on LinkedIn and/or Google, which gives us the capability to advertise to you on the given platforms.
LinkedIn uses techniques to identify you as the same user across different devices, regardless of whether you’re logged in to LinkedIn or not. For more on how these work, see here. LinkedIn will also use the data to optimise the systems of LinkedIn and its affiliates (specifically to improve relevance algorithms) and find LinkedIn members probabilistically, provided that LinkedIn and its affiliates will:
- Prior to optimizing LinkedIn’s systems, remove the direct association to personal identifiers to avoid identifying you;
- Not allow other advertisers or third parties to target advertising based on this information; and
- Not create or enhance individual behavioural profiles based on this information.
The basis on which we collect your information
We collect much of your information on the grounds of:
- Legitimate interests (for example, to send you direct marketing about products and services similar to those you have purchased from us or negotiated or enquired about, or to help us administer the website); and
- Fulfilment of a contract (for example, to provide you with products or services you have purchased from us).
If you choose to refuse sharing personal information with us we may be unable to fulfil our contractual obligations in the event that we do business with you.
Where we rely on legitimate interests, our legitimate interests are the promotion of the products and services offered by Saltwater Consulting and the provision of information with respect to products and services you have already purchased from us or in which you have expressed an interest in purchasing.
If we are unable to rely on legitimate interests, fulfilment of a contract, or any other grounds, we will request consent from you for the processing. This will be the case if, for example, you download any documentation from us and we would like to send you marketing information about our products and services, or if we ask for your consent to non-essential cookies. If you give us your consent, you can withdraw it at any time by clicking on the link in the email we send you, or by emailing email@example.com, or by changing your preference in our Cookies tool (see our Cookies Policy).
Sharing your information
We might, from time to time, share your personal information with any member of our affiliated companies, including any affiliated companies who are involved in the provision of service.
We may disclose your personal information to third parties:
- If the third party contracts with us to provide certain services you have requested and needs your personal information to do so;
- If we sell or buy any of our business or assets – we may disclose your personal data to the prospective buyer or seller;
- If Saltwater Consulting, or substantially all of its assets, are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets; or
- If we are under a duty to disclose or share your personal data to comply with any legal obligation; or to protect the rights, property, or safety of Saltwater Consulting, our customers, or others.
We Do Not Sell Personal Information
For more information, please see the “Your Rights” section below or contact us at firstname.lastname@example.org.
Where we store your personal data
The personal data that we collect from you may be transferred to and stored outside the European Economic Area (“EEA”) and transferred from there to another location outside the EEA. It may also be processed by staff outside the EEA who work for us or for one of our suppliers. These staff may, among other things, fulfil your order, process your payment, or provide support services.
If you would like to know more about the basis on which we may transfer your data outside the EEA where a finding of adequacy hasn’t been made, please contact email@example.com.
We have appropriate security measures to prevent your personal data from unauthorised access, use, alteration, disclosure, or loss.
Security of your Data
Saltwater Consulting has a thorough information security policy in place. As a result, Saltwater Consulting has implemented specific measures such as admission controls, system access controls, data access controls, transmission controls, input controls, job controls, availability controls, and segregation controls in order to ensure adequate protection of personal data. This includes specific measures such as the use of anti-virus applications, proper training protocols, systematic access management, and DDoS mitigation technologies.
Saltwater Consulting active approach to protect the integrity of the data includes, but is not limited to, technical and organisational measures such as proper system administration, regular backup procedures, the use of authentication codes, signature procedures, network controls, and proper training of employees and relevant third parties.
There are a number of rights available to people under the different global privacy laws, including GDPR and the South African Personal Privacy of Information Act (POPIA). These include:
- Access to your data and information about what data we hold, its source;
- Purposes of processing your data and information on where this is shared or sold;
- Rectification of your data where it is inaccurate;
- The right to be forgotten / to request that data is deleted;
- The right to restrict the processing of data;
- Data portability;
- The right to object;
- The right to non-discrimination;
- The right to opt-out of the sale of your data; and
- Rights relating to automated decision-making;
Access to your data
We will provide the information you request as soon as possible and in any event:
- Within one month of receiving your request is made under the right of access under GDPR;
- If we need more information to comply with your request, we will let you know.
Correction of your data
If you believe the personal data we hold about you is inaccurate or incomplete, you can ask us to rectify it. We will make the correction within one month unless we don’t feel the change is appropriate for us to make, In that case, we’ll let you know why. We will also let you know if we need more time to comply with your request.
Right to be forgotten
In some circumstances, you have the right to ask us to delete the personal data we hold about you when:
- we no longer need your personal data for the purpose for which we collected it;
- we have collected your personal data on the grounds of consent and you withdraw that consent;
- you object to the processing and we don’t have any overriding legitimate interests to continue processing the data about you;
- we have unlawfully processed your personal data (i.e. we have failed to comply with GDPR or POPIA); and
- the personal data has to be deleted to comply with a legal obligation.
There are certain situations in which we are entitled to refuse to comply with a request. If any of those apply, we’ll let you know.
Right to restrict processing
In some circumstances, you are entitled to ask us to stop processing your personal data. But, while this means we must stop actively processing your personal data, we don’t have to delete it. This right is available if:
- you believe the personal data we hold isn’t accurate – we’ll cease processing it until we can verify its accuracy;
- you have objected to us processing the data– we’ll stop processing it until we have determined whether our legitimate interests override your objection;
- if the processing is unlawful; or
- if we no longer need the data but you would like us to keep it because you need it to establish, exercise, or defend a legal claim.
Where Saltwater Consulting acts as a Data Controller, you have the right to ask us to provide your personal data in a structured, commonly- used and machine-readable format so that you are able to transfer the personal data to another data controller. This right only applies:
- to personal data you provide to us;
- when processing is based on your consent or for the performance of a contract (i.e., the right does not apply if we process your personal data on the grounds of legitimate interests); and
- if the processing is automated.
We’ll respond to your request as soon as possible and in any event within one month. If we need more time, we’ll let you know.
Right to object
You are entitled to officially object to us processing your personal data:
- if the processing is based on legitimate interests or performance of a task in the public interest or exercise of official authority;
- for direct marketing purposes (including profiling); and/or
- for the purposes of scientific or historical research and statistics.
We will stop processing your data if you have ground for objecting unless we can show that there are legitimate compelling grounds that override your interests, rights, and freedoms or the processing is for the establishment, exercise or defence of legal claims.
Right to Non-discrimination
Saltwater Consulting shall not discriminate against any person who exercises their rights under the GDPR or any other applicable data privacy legislation.
This includes, but is not limited to:
- denying services;
- charging different rates for services;
- providing different levels of quality in our services.
If Saltwater Consulting offers any financial incentives for the collection or use of personal information, including but not limited to the sale of personal information or the deletion of personal information, it shall notify consumers and provide the option for consumers to opt-in. Such an opt-in may be revoked at any time by the consumer.
If you would like to exercise any of your rights in respect of your personal data, please contact us at firstname.lastname@example.org or write to us at 161 Lower Rathmines Road, Dublin 6, D06C8P3, Ireland
Our website may contain links to our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check their policies before you submit any personal data to them.
If you have any concerns about the ways in which we process your personal data, you are entitled to report those concerns to the relevant supervisory authority in your jurisdiction.