1. Introduction
1.1 Phasecraft Limited is a company registered in England and Wales (company number: 11211343) with its registered address at 77 Charlotte Street, London, England, W1T 4PW ("Phasecraft", "we", "our", or "us").
1.2 Phasecraft operates the https://www.phasecraft.io/ website (the "Phasecraft Website"), which provides information about our products and services, allows users to contact us and sign up for information and updates about our products and services and access and sign up for our products and services (the “Phasecraft Services”).
1.3 This privacy policy sets out how we collect, store, process, transfer, share and use data that identifies or is associated with you (“personal information”) when you access and browse the Phasecraft Website and/or Phasecraft Services. It also describes how we process the personal information of our suppliers and job candidates.
1.4 If you have any questions about this privacy policy or how we use your personal information, please contact us using the details in paragraph 2 below.
2. Who is responsible for your personal information
2.1 Phasecraft is the data controller of the personal information about you that we hold and use as set out in this privacy notice. This means that we determine and are responsible for how your personal information is used.
2.2 If you have any questions, comments and requests regarding this privacy notice or how we use your personal information, please contact us at support@phasecraft.io.
3. Personal information we collect about you and how we use it
3.1 We collect personal information that you voluntarily submit directly to us when you use the Phasecraft Website and/or Phasecraft Services. This can include information you provide to us when you make a request on the Phasecraft Website and/or Phasecraft Services, correspond with us by phone, e-mail or otherwise, subscribe for our marketing communications, or use some other features of the Phasecraft Website and/or Phasecraft Services.
3.2 Like all online services, we also collect certain personal information about you automatically when you use the Phasecraft Services in order to understand how the Phasecraft Website and/or Phasecraft Services is used and how we can improve it.
3.3 We may also collect and process certain personal information about you if you are employed by or represent a supplier of services to Phasecraft.
3.4 We will also collect and process certain personal information about you if you are a candidate and apply for employment and/or a contractor or consultant role with us.
3.5 We have set out the categories of personal information we collect and how we use them in detail below.
Personal information you submit to us
3.6 We will indicate to you if the provision of certain personal information is mandatory or optional. If you choose not to provide any personal information marked as mandatory, we may not be able to respond to your queries or provide other services to you.
Personal details including first name, last name, username or similar identifier, email address, job title, phone number, unique device identifiers.
Payment information (such as bank account details, where this relates to an identifiable individual).
We use this information to:
- set up your account on the Phasecraft Website/ Phasecraft Services to enable you to share content with users on the Phasecraft Website/ Phasecraft Services;
- coordinate the delivery of the services requested and otherwise the fulfilment of our obligations under agreements with customers;
- personalize the products displayed to you;
- support internal reporting and management;
- protect our business interests and legal rights, including in connection with legal claims, compliance, regulatory, auditing, investigative and disciplinary purposes, including prevention and detection of crime, and ethics and compliance reporting requirements;
- protect the security of our premises, assets, systems, and intellectual property and enforce company policies, including protecting Phasecraft from fraud and verifying the individuals with which Phasecraft interacts as appropriate;
- respond to legitimate requests by government or law enforcement authorities;
- support business transactions or reorganizations, or in connection with the disposal of our assets; and
- monitor use of our services, and oversee, improve and protect our products, content, services and websites, both online and offline.
We use this information to send service-related communications, coordinate responses to customer support queries, respond to queries and comments, and identify and improve errors or problems with the service or products.
We use this information to follow up on business leads and introduce interested businesses to our products and services.
This processing is for the performance of a contract and to take steps prior to entering into a contract with you.
The processing is necessary for our legitimate interests, namely to communicate with you, respond to and appropriately investigate and act on specific information requests made by you.
We obtain consent to the receipt of marketing in respect of our products and services.
Personal details including first name, last name, email address, company and job title, contact phone number, IP address.
Personal information contained in electronic communications.
Payment information (such as bank account details, where these relate to an identifiable individual).
We use this information:
- to prepare commercial materials including, but not limited to, contracts, record keeping and supplier reports;
- to ensure and coordinate the receipt of products and/or services;
- for accounting and fraud-prevention purposes, including to manage budgeting, facilitate group-level financial audits and file group-level tax returns and accounts;
- to administer supplier engagements and communicate further with them; and
- to fulfil payments to suppliers.
The processing is necessary for our legitimate interests, namely to administer our supplier relationships and safeguard our business and assets.
Personal details including first name, last name, phone number, email address and address.
Qualifications information including resumes or curriculum vitae, references; and published articles or speeches.
Recruitment information including role applied for; time and date application was submitted; information contained in CVs and resumes; interview evaluations and appraisals; and communications with candidates.
Current / prospective job role information including employing entity; business unit; place of work; date of hire; job title; nature of duties and responsibilities;
Prospective salary and benefits-related information including compensation and salary data.
We use this information to:
- review and determine job applications; and
- undertake and coordinate strategic decisions regarding recruitment and hiring of candidates.
The processing is necessary to allow us to decide whether to enter into a contract of employment or other type of contract with you or where it is necessary for our legitimate interests to enable us to manage the recruitment process, assess and confirm a candidate’s suitability for employment and decide to whom to offer a job.
Personal information we collect automatically
- We also automatically collect personal information indirectly about how you access and use Phasecraft Website and/or Phasecraft Services, and information about the device you use to access Phasecraft Website and/or Phasecraft Services.
- We may link or combine the personal information we collect about you and the information we collect automatically. This allows us to provide you with a personalised experience regardless of how you interact with us.
- We may anonymise and aggregate any of the personal information we collect (so that it does not directly identify you). We may use anonymised information for purposes that include testing our IT systems, research, data analysis, improving the Phasecraft Website and Phasecraft Services and developing new services and features. We may also share such anonymised and aggregated information with others.
- We typically collect this information through a variety of tracking technologies, including cookies, server-side tracking and similar tracking technologies. For more detailed information about the cookies we use, including details of how to opt-out, please see our Cookies Notice.
We may collect analytics data or use third-party analytics tools such as Google Analytics to help us measure traffic and usage trends for the services and to understand more about the demographics of our users. You can learn more about Google's practices here and view its opt-out options here.
Data collected may include:
- Approximate location Information or your IP address, including longitude, latitude, date and time (the precision of this data varies greatly and is determined by factors controlled by your device or mobile service providers);
- Information about how you access and use the Phasecraft Website/Phasecraft Services, the time you access the Phasecraft Website/Phasecraft Services and how long you access them for, the approximate location that you access the Phasecraft Website/Phasecraft Services, the site from which you came and the site to which you are going when you leave, the pages you visit, the links you click, your interactions on the Phasecraft Website/Phasecraft Services and other actions you take on the Phasecraft Website/Phasecraft Services.
- Log files and information about your device. We also collect information about the tablet, smartphone or other electronic device you use to connect to the Phasecraft Website/Phasecraft Services. This information can include details about the type of device, manufacturer, unique device identifying numbers, operating systems, browsers and applications connected to the Phasecraft Website/Phasecraft Services through the device, your mobile network, your IP address and your device's telephone number (if it has one).
We use this information to:
- help us measure traffic and usage trends for the Phasecraft Website/ Phasecraft Services and to understand more about the demographics of our users, which supports product, website and service delivery, improvement and development activity, both online and offline (including identification of errors); and
- maintain the security and integrity of our website and services.
Where required by law, we will only process your personal data in this way to the extent that you have given us your consent to do so via our cookie consent banner.
You can learn more about Google's practices and opt-out options via Google's own resources.
4. How long we keep your personal information
4.1 We will store the personal information we collect for no longer than necessary for the purposes set out and in accordance with our legal obligations and legitimate business interests.
4.2 To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and the applicable legal requirements.
5. Recipients
As required in accordance with how we use your personal information, we may share your personal information with the following:
Our group companies
Service providers, such as providers of web hosting or other technical services such as analytic services or communication services.
Law enforcement, regulators and other parties for legal reasons. We may share your personal information with third parties as required by law or if we reasonably believe that such action is necessary to (i) comply with the law and the reasonable requests of law enforcement; (ii) detect and investigate illegal activities and breaches of agreements; and / or (iii) exercise or protect the rights, property or personal safety of Phasecraft, its users or others.
The processing purposes described in section 3 above also apply to our sharing of personal information with group companies and their processing of personal information.
These third-party vendors and other service providers perform services for us or on our behalf.
These recipients will use your personal information in the performance of their regulatory or law enforcement role, or to advise us in connection with a potential claim or regulatory enforcement action.
The legal bases for processing your personal information in section 3 above also apply to our sharing of personal information with group companies.
These service providers will use your personal information as processors on our instructions.
The lawful basis we rely on for sharing personal information with these recipients is that the processing is either necessary to comply with a legal obligation to which we are subject or, where there is no applicable legal obligation to share this data, that the sharing is necessary for our legitimate interests, namely enforcing our rights or complying with requests from regulatory authorities.
6. Storing and transferring your personal information
6.1 Security. We implement appropriate technical and organisational measures to protect your personal information against accidental or unlawful destruction, loss, change or damage. All personal information we collect will be stored on our secure servers. We will never send you unsolicited emails or contact you by phone requesting your ID, password, credit or debit card information or national identification numbers.
6.2 International Transfers of your personal information. We may transfer your personal information to Phasecraft Inc., a group company, in connection with the activities described in this privacy policy. All such transfers are governed by a contract incorporating the appropriate model clauses approved by the UK Information Commissioner’s Office and European Commission. For more information about the measures taken to safeguard your personal information and obtain a copy of the relevant contract terms, you may contact us at support@phasecraft.io
7. Your rights in respect of your personal information
7.1 If you are resident in the UK or EEA, in accordance with applicable privacy law you have the following rights in respect of your personal information that we hold:
-
Right of access. You have the right to obtain:
- confirmation of whether, and where, we are processing your personal information;
- information about the categories of personal information we are processing, the purposes for which we process your personal information and information as to how we determine applicable retention periods;
- information about the categories of recipients with whom we may share your personal information; and
- a copy of the personal information we hold about you.
- Right to data portability. You have the right, in certain circumstances, to receive a copy of the personal information you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal information to another person.
- Right to rectification. You have the right to obtain rectification of any inaccurate or incomplete personal information we hold about you without undue delay.
- Right to erasure. You have the right, in some circumstances, to require us to erase your personal information without undue delay if the continued processing of that personal information is not justified.
- Right to restriction. You have the right, in some circumstances, to require us to limit the purposes for which we process your personal information if the continued processing of the personal information in this way is not justified, such as where the accuracy of the personal information is contested by you.
- Right to withdraw consent. Where we rely on your consent for processing your personal information, you have the right to withdraw your consent. Withdrawal of your consent will not affect the lawfulness of the processing of your personal information before you withdrew your consent.
7.2 You have a right to object to any processing based on our legitimate interests. There may, depending on the particular circumstances, be compelling reasons for continuing to process your personal information despite your objection, and we will assess and inform you if that is the case. You can object to marketing activities for any reason.
7.3 If you wish to exercise one of these rights, please contact us using the contact details at the top of this privacy policy.
7.4 We will not charge you a fee for complying with your request to exercise one of these rights, other than where the request is manifestly unfounded or excessive (such as if you submit a number of repeated requests), in which case we may charge you a reasonable fee to cover our administrative costs.
7.5 You have the right to complain to us regarding our use of your personal data and can do so by contacting us by email at privacy@phasecraft.io. You also have the right to lodge a complaint to your national data protection authority. If you are in the UK, your local data protection authority is the Information Commissioner's Office, which can be contacted using the details at https://ico.org.uk/global/contact-us/. If you are in the EEA, further information about how to contact your local data protection authority is available at https://edpb.europa.eu/about-edpb/about-edpb/members_en.
8. Links to third party sites
8.1 The Phasecraft Website and Phasecraft Services may, from time to time, contain links to and from third party websites, including those of other users, our partner networks, advertisers, partner merchants, news publications, social media platforms, retailers 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 their policies. Please check the individual policies before you submit any information to those websites.
9. Our policy towards children
9.1 The Phasecraft Website and Phasecraft Services are not directed at persons under 16 and we do not knowingly collect personal information from children under 16. If you become aware that your child has provided us with personal information, without your consent, either directly or by other means, then please contact us using the details below so that we can take steps to delete such information and terminate any account your child has created with us.
10. Changes to this privacy policy
10.1 We may update this privacy policy from time to time and so you should review this page periodically. When we change this privacy policy in a material way, we will update the "last modified" date at the end of this privacy policy. Changes to this privacy policy are effective when they are posted on this page.
11. Notice to you
11.1 If we need to provide you with information about something, whether for legal, marketing or other business-related purposes, we will select what we believe is the best way to get in contact with you. We will usually do this through email or by placing a notice on the Phasecraft Website.