Privacy Policy
New Comma is committed to ensuring that your personal data is safeguarded at all times. When you visit our website or participate in our events, we may collect information, which may include Personal Data. For the purposes of General Data Protection Regulation (GDPR), we shall be the controller for this Personal Data – this means that we decide what Collected Data is processed and why.
1. INTRODUCTION
1.1 Important information and who we are
Welcome to New Comma Ltd’s Privacy and Data Protection Policy (“Privacy Policy”). At New Comma Ltd (“we”, “us”, or “our”) we are committed to protecting and respecting your privacy and Personal Data in compliance with the United Kingdom General Data Protection Regulation (“GDPR”), the Data Protection Act 2018 and all other mandatory laws and regulations of the United Kingdom.
This Privacy Policy explains how we collect, process and keep your data safe. The Privacy Policy will tell you about your privacy rights, how the law protects you, and inform our employees and staff members of all their obligations and protocols when processing data.
The individuals from which we may gather and use data can include: Customers
- Suppliers Business
- Contacts
- Employees/Staff Members
- Third parties connected to your customers
and any other people that the organization has a relationship with or may need to contact.
This Privacy Policy applies to all our employees and staff members and all Personal Data processed at any time by us.
1.2 Your Data Controller
New Comma Ltd is your Data Controller and responsible for your Personal Data. We are not obliged by the GDPR to appoint a data protection officer and have not voluntarily appointed one at this time. Therefore, any inquiries about your data should either be sent to us by email to [email protected] or by post to Kemp House, 128 City Road, London, EC1V 2NX, United Kingdom.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
1.3 Processing data on behalf of a Controller and processors’ responsibility to you
In discharging our responsibilities as a Data Controller we have employees who will deal with your data on our behalf (known as “Processors”). The responsibilities below may be assigned to an individual or may be taken to apply to the organization as a whole. The Data Controller and our Processors have the following responsibilities:
- Ensure that all processing of Personal Data is governed by one of the legal bases laid out in the GDPR (see 2.2 below for more information); l
- Ensure that Processors authorized to process Personal Data have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality;
- Implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk associated with the processing of Personal Data;
- Obtain the prior specific or general authorization of the Controller before engaging another Processor;
- Assist the Controller in the fulfilment of the Controller's obligation to respond to requests for exercising the data subject's rights;
- Make available to the Controller all information necessary to demonstrate compliance with the obligations laid down in the GDPR and allow for and contribute to audits, including inspections, conducted by the Controller or another auditor mandated by the Controller;
- Maintain a record of all categories of processing activities carried out on behalf of a Controller;
- Cooperate, on request, with the supervisory authority in the performance of its tasks;
- Ensure that any person acting under the authority of the Processor who has access to Personal Data does not process Personal Data except on instructions from the Controller; and
- Notify the Controller without undue delay after becoming aware of a Personal Data Breach.
2. LEGAL BASIS FOR DATA COLLECTION
2.1 Types of data / Privacy policy scope
“Personal Data” means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of Personal Data about you which we have grouped together below. Not all of the following types of data will necessarily be collected from you but this is the full scope of data that we collect and when we collect it from you:
- Profile/Identity Data: This is data relating to your first name, last name, gender, date of birth.
- Contact Data: This is data relating to your phone number, addresses, email addresses, phone numbers.
- Marketing and Communications Data: This is your preferences in receiving marketing information and other information from us.
- Billing Data: This is information relating to your debit and credit card information such as the name attached to your payment details and your billing address.
- Financial Data: These are your banking details e.g. your account number and sort code.
- Transactional Data: This is information of details and records of all payments you have made for our services or products.
- Technical Data: This is your IP address, browser type and version, time zone setting and location, operating system and platform, and other technology on the devices you use to engage with us.
- Customer Support Data: This includes feedback and survey responses.
- Usage Data: information about how you use our website, products and services.
We also collect, use and share Aggregated Data such as statistical or demographic data for various purposes. For instance, we might aggregate your usage data to calculate the percentage of users accessing a specific feature on our platform.
Examples of the Aggregated Data we collect include:
User Behaviour Analysis: We aggregate data related to user interactions with our platform, such as pages visited, duration of visits, and features utilized. This assists us in identifying usage patterns, improving user experience, and guiding the development of new features.
Content Engagement Metrics: To better understand which types of content resonate with our audience, we collect aggregated data on content engagement. This includes metrics like view counts, likes, shares, and time spent on different content pieces. These insights inform our content strategy and help us deliver more relevant and engaging material to our users. Demographic Insights: We gather anonymized demographic information, such as age ranges, geographical locations, and areas of interest. This aggregated data is crucial in tailoring our services and content to suit the diverse needs of our user base. Performance Metrics: We aggregate usage statistics to ensure the reliability and efficiency of our platform. This encompasses data on system performance, load times, and error rates, enabling us to maintain a high-quality service and address technical issues promptly.
Aggregated Data could be derived from your Personal Data but is not considered Personal Data in law as this data will not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Privacy Policy.
We may also aggregate data to enable research or analysis so that we can better understand and serve you and others. For example, we may conduct research on your demographics and usage. Although this aggregated data may be based in part on Personal Data, it does not identify you personally. We may share this type of anonymous data with others, including service providers, our affiliates, agents and current and prospective business partners.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
2.2 The Legal Basis for Collecting That Data
There are a number of justifiable reasons under the GDPR that allow collection and processing of Personal Data. The main avenues we rely on are:
- “Consent”: Certain situations allow us to collect your Personal Data, such as when you tick a box that confirms you are happy to receive email newsletters from us, or ‘opt in’ to a service.
- “Contractual Obligations”: We may require certain information from you in order to fulfil our contractual obligations and provide you with the promised service.
- “Legal Compliance”: We’re required by law to collect and process certain types of data, such as fraudulent activity or other illegal actions.
- “Legitimate Interest”: We might need to collect certain information from you to be able to meet our legitimate interests - this covers aspects that can be reasonably expected as part of running our business, that will not have a material impact on your rights, freedom or interests. Examples could be your address, so that we know where to deliver something to, or your name, so that we have a record of who to contact moving forwards.
3. HOW WE USE YOUR PERSONAL DATA
3.1 Our data uses
We will only use your Personal Data when the law allows us to.
Set out below is a table containing the different types of Personal Data we collect and the lawful basis for processing that data.
Please refer to section 2.2 for more information on the lawful basis listed in the table below.
Examples provided in the table below are indicative in nature and the purposes for which we use your data may be broader than described but we will never process your data without a legal basis for doing so and it is for a related purpose. For further inquiries please contact us.
| Activity | Type of data | Legal Justification | Lawful basis for processing data |
|---|---|---|---|
| When a customer signs up, we collect their personal data which is required to build their profile on the platform. This enables us to help them connect with relevant collaborators and opportunities through New Comma. | Profile/Identity Data, Contact Data | Necessity | We need to process this data so we can allow users to create their profiles on the website, and so that we can render the services we provide to these users. |
| We collect billing and transactional data to enable the provision of job opportunities and marketplace sales on New Comma. Users will pay to post jobs on the platform, and also pay for services obtained through the storefronts or events listed on the platform. | Billing Data, Transactional Data | Legitimate, Interest Necessity | We need to process this data to be able to offer our job boards, storefronts and events services. This data is captured when there are charges for the various services available on the platform. |
3.2 Marketing and content updates
You will receive marketing and new content communications from us if you have created an account and chosen to opt into receiving those communications. From time to time we may make suggestions and recommendations to you about goods or services that may be of interest to you.
3.3 Change of purpose
We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
4. YOUR RIGHTS AND HOW YOU ARE PROTECTED BY US
4.1 Your legal rights
Under certain circumstances, you have the following rights under data protection laws in relation to your personal data:
- Right to be informed. You have a right to be informed about our purposes for processing your personal data, how long we store it for, and who it will be shared with. We have provided this information to you in this policy.
- Right of access. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it (also known as a "data subject access request"). See section 4.5 below for more details on how you can make a data subject access request.
- Right to rectification. You have a right to request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Right to erasure. You have the right to ask us to delete or remove personal data where there is no good reason for us continuing to process it, where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Right to object. You can object to the processing of personal data we hold about you. This effectively allows you to stop or prevent us from processing your personal data. Note that this is not an absolute right and it only applies in certain circumstances, for example:
- Where we are processing your personal data for direct marketing purposes.
- Where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.
- In some cases, we may continue processing your data if we can demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Right to restrict processing. You have the right to request the restriction or suppression of their personal data. Note that this is not an absolute right and it only applies in certain circumstances:
- If you want us to establish the data's accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Right to data portability. You have the right to request the transfer of your personal data to you or to a third party. If you make such a request, we will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
If you wish to make a request under any of these rights, please contact us at [email protected].
4.2 Your control over New Comma Ltd’s use of your Personal Data
You may delete your account at any time – this will remove your account page from our systems and our related software. We guarantee this will delete all stored data. However, it's important to note that content or information related to your account may still appear in search engine results for a period of time. This is because search engines index information and our control over their indexing processes is limited. Even after your account is deleted from New Comma, search engines may retain cached copies of your profile information.
You can access information associated with your account by logging into your account you created with us. Your account information will be protected by a password for your privacy and security. You need to prevent unauthorized access to your account and personal information by selecting and protecting your password appropriately and limiting access to your computer or device and by signing off after you have finished accessing your account.
California Privacy Rights: Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of personal customer information which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to [email protected].
4.3 How New Comma Ltd protects customers' Personal Data
We are concerned with keeping your data secure and protecting it from inappropriate disclosure. We implement a variety of security measures to ensure the security of your Personal Data on our systems, including Adopting Secure Protocols: We use industry- standard secure protocols across our platform to protect data in transit. This includes the implementation of HTTPS with strong encryption, ensuring that all data exchanged between your device and our servers is secure and protected from interception.
Database Encryption: Where sensitive data is stored, it is encrypted to provide an additional layer of security. This means that even in the unlikely event of unauthorized access, the data remains unreadable and secure. Regular Security Audits and Updates: We conduct regular security audits of our systems and promptly apply necessary updates and patches. This proactive approach helps us to stay ahead of potential vulnerabilities and keep our defenses robust against emerging threats. Access Control and Authentication Measures: Access to personal data within our systems is strictly controlled. We employ robust authentication measures and limit access to sensitive data to authorized personnel only, ensuring that your information is accessed only for legitimate purposes.
Data Backup and Recovery Plans: To protect against data loss, we have comprehensive backup and recovery procedures in place. Regular backups of all data are conducted, and we have robust mechanisms to restore data in the event of a system failure or data breach.
Compliance with Data Protection Regulations: We adhere to relevant data protection laws and regulations, ensuring that our data handling practices are compliant and uphold the highest standards of privacy and security. By implementing these measures, we strive to provide a secure environment for your personal data, protecting it against unauthorized access, disclosure, alteration, and destruction.
At NewComma, your privacy and security are our top priorities. Any Personal Data collected by us is only accessible by a limited number of employees who have special access rights to such systems and are bound by obligations of confidentiality. If and when we use subcontractors to store your data, we will not relinquish control of your Personal Data or expose it to security risks that would not have arisen had the data remained in our possession. However, unfortunately no transmission of data over the internet is guaranteed to be completely secure. It may be possible for third parties not under the control of New Comma Ltd to intercept or access transmissions or private communications unlawfully. While we strive to protect your Personal Data, we cannot ensure or warrant the security of any Personal Data you transmit to us. Any such transmission is done at your own risk. If you believe that your interaction with us is no longer secure, please contact us.
4.4 Opting out of marketing promotions
You can ask us to stop sending you marketing messages at any time by You can ask us to stop sending you marketing messages at any time by clicking the unsubscribe button in the emails you receive from us, or by sending an email to [email protected] requesting to be removed from our mailing list..
Where you opt out of receiving these marketing messages, we will continue to retain other Personal Data provided to us as a result of interactions with us not related to your marketing preferences.
4.5 How to request your data and the process for obtaining it
You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, if your request is clearly unfounded, we could refuse to comply with your request.
We may need to request specific information from you to help us confirm your identity and ensure you have the right to access your Personal Data (or to exercise any of your other rights).
This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
5. YOUR DATA AND THIRD PARTIES
5.1 Sharing your data with third parties
We may share non-Personal Data with third parties. We may share your Personal Data with subcontractors or affiliates, subject to confidentiality obligations to use it only for the purposes for which we disclose it to them and pursuant to our instructions.
We may also share Personal Data with interested parties in the event that New Comma Ltd anticipates a change in control or the acquisition of all or part of our business or assets or with interested parties in connection with the licensing of our technology.
If New Comma Ltd is sold or makes a sale or transfer, we may, in our sole discretion, transfer, sell or assign your Personal Data to a third party as part of or in connection with that transaction. Upon such transfer, the Privacy Policy of the acquiring entity may govern the further use of your Personal Data. In all other situations your data will still remain protected in accordance with this Privacy Policy (as amended from time to time).
We may share your Personal Data at any time if required for legal reasons or in order to enforce our terms or this Privacy Policy.
5.2 Third-Party Links
This Site may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you.
We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Site, we encourage you to read the privacy policy of every website you visit.
6. HOW LONG WE RETAIN YOUR DATA
We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for. We may retain your Personal Data for a longer period than usual in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
7. AGE LIMIT FOR OUR USERS
You must not use New Comma Ltd unless you are aged 16 or older. If you are under 16 and you access New Comma Ltd by lying about your age, you must immediately stop using New Comma Ltd.
This website is not intended for children and we do not knowingly collect data relating to children.
8. INTERNATIONAL TRANSFER OF DATA
Your information may be stored and processed in the US or other countries or jurisdictions outside the US where New Comma Ltd has facilities. By using New Comma Ltd, you are permitting and consenting to the transfer of information, including Personal Data, outside of the US.
9. NOTIFICATION OF CHANGES AND ACCEPTANCE OF POLICY
We keep our Privacy Policy under review and will place any updates here. This version is dated 1 December 2023.
By using New Comma Ltd, you consent to the collection and use of data by us as set out in this Privacy Policy. Continued access or use of New Comma Ltd will constitute your express acceptance of any modifications to this Privacy Policy.
10. INTERPRETATION
All uses of the word "including" mean "including but not limited to" and the enumerated examples are not intended to in any way limit the term which they serve to illustrate. Any email addresses set out in this policy may be used solely for the purpose for which they are stated to be provided, and any unrelated correspondence will be ignored. Unless otherwise required by law, we reserve the right to not respond to emails, even if they relate to a legitimate subject matter for which we have provided an email address. You are more likely to get a reply if your request or question is polite, reasonable and there is no relatively obvious other way to deal with or answer your concern or question (e.g. FAQs, other areas of our website, etc.).
Our staff are not authorized to contract on behalf of New Comma Ltd, waive rights or make representations (whether contractual or otherwise). If anything contained in an email from a New Comma Ltd address contradicts anything in this policy, our terms or any official public announcement on our website, or is inconsistent with or amounts to a waiver of any New Comma Ltd rights, the email content will be read down to grant precedence to the latter. The only exception to this is genuine correspondence expressed to be from the New Comma Ltd legal department.
11. TERMS OF USE
Please also see our Terms of Use (https://home.newcomma.com/terms) which set out the terms, disclaimers, and limitations of liability governing your use of New Comma Ltd.
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