Your privacy matters to us.
Sanrai is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using this website, then you can be assured that it will only be used in accordance with this privacy statement.
Sanrai may change this policy from time to time by updating this page. You should check this page occasionally to ensure that you are happy with any changes. This policy is effective from 1st July 2018.
What data do we collect
The information we collect about you depends on which of our Services you’re using, but we’ll only collect your personal information where necessary. Information we may collect includes:
- your name, address, postcode, email address, date of birth, telephone number, payment details and details of the Service(s) you are using
- information about your use of our Services, including details of your internet protocol (IP) address, device type and identifier, operating system, browser version, cookie data, the content you viewed and details of your navigation around the Services
- location data from your IP address or by accessing global positioning functionality on your device (e.g. GPS)
- other data from time to time, to help us provide you with improved products and services – for example when we ask you to fill in a form or questionnaire
- other data to review compliance with the our terms and conditions and/or otherwise as required by law
When and how do we collect data
We (or our authorised third parties) may collect information about you:
- when you contact us with an enquiry, request or other feedback
- when you participate in interactivity (for example, when you submit an entry to a competition or prize draw, or you vote in one of our polls)
- when you request to be sent marketing communications such as updates or newsletters
- in monitoring your use of our Services
- when you disclose your personal information to us or otherwise through the Services
- from third party suppliers who have confirmed they are authorised to pass your information to us in accordance with your legal rights e.g. referrals
We may combine information you provide to us in one way, with others. This includes the use of our Services or information that is either publicly available or received from other reputable sources. It’s your responsibility to ensure that any data that you provide to us is accurate and kept up to date.
How we use your data
We will only use your personal data as the law permits us to do. Typically, we use personal data for the following reasons:
- where we need the data to perform the contract to which you are a party, or with your consent, in the setting up of a contract
- where we need to comply with legal obligations placed on Sanrai
- where it is necessary for our legitimate interests (or those of an authorised third party) and your interests or rights do not override our interests
In rare occasions, we reserve the right to use your information when:
- we need to protect your interests or someone else’s interests
- when it is needed in the public interest or for official purposes
We also act on behalf of our Clients in the capacity of a Data Processor. When working as a Data Processor, Sanrai will be acting on the instruction of its client.
If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you (such as providing a benefit or service) or we may be prevented from complying with our legal obligations.
The legal basis for processing your information
Sanrai has five available lawful bases for processing information:
- Consent: the individual has given clear consent for you to process their personal data for a specific purpose
- Contract: the processing is necessary for a contract you have with the individual, or because they have asked you to take specific steps before entering into a contract.
- Legal obligation: the processing is necessary to comply with the law (not including contractual obligations)
- Vital interests: the processing is necessary to protect someone’s life.
- Legitimate interests: the processing is necessary for your legitimate interests or the legitimate interests of a third party unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests
Legitimate interests pursued by us and our clients include activities that promote the Service of the business included consulting, development, marketing and any other products or Services provided by Sanrai.
We also consider there to be a legitimate interest in promoting Sanrai and its Services to potential suppliers, partners, subcontractors, job applicants and industry professionals.
When we share information and who is it shared with
We may pass data we hold on you to other parties as follows:
- to third parties authorised by us and acting on our behalf, such as our employees, contractors, suppliers and/or agents, to administer the Services provided to you. These third parties are only allowed access to your information as needed to perform functions of the Services or to provide services to us. They’re not allowed to use it for any other purpose
- as part of general statistical reporting in regards to user behavior, sales patterns, marketing performance, traffic volumes and related matters. This information will not include information that may lead for you to be identified personally
- where relevant, a name and profile information may be published if you choose to comment on content on our website
- other instances as required by law or where it is necessary to administer the working relationship with you or where there is legitimate interest to us
- in the event of the sale, or potential sale, of the business to another entity involved or within the group. If there are changes to our business (such as a re-organisation or restructuring), your personal information will remain subject to this privacy notice (as amended from time to time). However, where your personal information is transferred to a new owner following a merger or acquisition it may be subject to a different privacy notice. We, or the new owner, will provide notice to you before any of your personal information becomes subject to a different privacy notice.
We require all third parties to respect the security of your data and to treat it in accordance with the law.
We may transfer your personal information outside the EU.
If we do, you can expect protection in respect of your personal information.
Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe
- Where we use providers based in the United States, we try to ensure they are a member of Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US
- Other appropriate safeguards have been put in place, as described in the privacy notice for the applicable Service
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
How long do we retain data for?
We keep your personal data for only as long as necessary, which in some cases is longer than in others. The length of the retention period depends on the purpose for which it was obtained and the nature the data.
We may need to keep some data to ensure we can deal with any complaints you might make about our Services.
If you ask us to stop processing your data, we need to retain enough information about you so we can ensure we stop including you in marketing activities.
We may have legal or regulatory duty to retain certain information for a minimum period (for example to comply with HMRC tax rules).
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What are your rights
Any personal information you provide us will be handled in accordance with applicable data protection laws including the General Data Protection Regulation (GDPR). We are committed to delivering the rights that individuals are entitled to under data protections laws in the UK. These include:
- the right to request a copy of the personal information we hold about you: To do this please contact us making it clear that you are requesting a copy of the data and full details of the information you require. You may be asked to provide us with proof of identity for security purposes
- the right to object to your personal information being used for direct marketing: When required we will request you consent before undertaking marketing and you have the option to opt out of any email communications we send
- the right to object to your personal information being processed where the legal basis is our own legitimate interests as a business (see above). We will comply within a reasonable period of time unless there is a lawful reason for not doing so
- the right to rectification: You may request that we correct inaccurate and/or complete and incomplete personal information
- the right to withdraw consent: Where we are processing information on the basis that you have given consent, you may withdraw your consent at any time
- the right to erasure: Unless there is lawful basis for us retaining certain information, can ask that we delete all personal information we hold on you where there is no good reason for us to continue processing the information
- the right to data portability: In some circumstance, you may ask that we provide your personal information to you in a structured, commonly used and machine readable format and transferred to another provider of the same or similar service as us
Sanrai as a Data Controller
Sanrai International LLC is a company registered in the United States with registered office at 1701 North St Suite 40-2 Endicott, NY 13760 USA.
If you wish to contact us about our privacy notice, or any other matter relating to personal information usage, please email us at [email protected]