Introduction

The following privacy policy explains the personal data we collect from you, why we collect it, who we disclose it with (including those parties outside of the EU/EAA), how we use it and how we protect it. We recommend that you read the whole statement.

If at any time you are concerned or have questions about how we might be handling your data, please contact gdpr@sdsd.com

Personal data we collect directly from you

We collect personal data directly from you through our licensed products (Matrix, V-Platform, MAMS, Charter Party Editor and bespoke applications and integrations developed by the SDSD), on our website landing pages and over the phone. We use the data you provide for the following purposes:

To fulfil our contract with you or your employer to provide you with services you have requested, and in particular:

• To issue credentials that allow you to access and operate your SDSD software product.
• To contact you about your license or subscription and to provide customer support services to you.
• To invoice you for any SDSD software product or services you have contracted to, and to collect payments.

For our own legitimate interests in:

• Maintaining our own records and databases.
• Monitoring use of our products and services to ensure usage is in accordance with our terms and conditions of use.
• Providing our customers with information about other SDSD products and services.
• Informing prospective customers about our products and services.

Other sources of personal data

We also collect personal data from other sources which include:

• Publicly available sources such as company websites
• Information generated by your usage of our products and services.

The data we collect in this way includes the following:

Name and contact data, including first and last name, email address, job title, work   postal address and similar contact data.

Demographic, including country and city

We use this personal data for the following purpose:

• For our own legitimate interests in monitoring usage of our websites and services.
• Informing prospective customers about our products and services and marketing communications.

 Who has access to your personal data?

We do not sell your personal information to third parties.

SDSD transfers personal data to the following recipients:

• Companies who we appoint under contract to host our services.
• Companies or individuals who we appoint to provide services to SDSD.
• Actual or potential business partners who need access to personal data to evaluate or carry out a business relationship or to conclude a transaction with SDSD.

Transfers to other countries outside the EAA

Some of our subsidiaries that process personal data on our behalf are located outside the European Economic Area. Such subsidiary company staff members may, among other things, be involved in the processing of payment details, marketing, data entry, the provision of support services and the delivery of your requests for us to provide a service.

These are:

• SDSD Prestige Limited who process personal data on our behalf in Nigeria
• SDSD Pte Limited who process personal data on our behalf in Singapore, Vietnam and India
• SDSD Labs Sdn Bhd who process personal data on our behalf in Malaysia

Some of our suppliers that process personal data on our behalf are located outside the European Economic Area.

These are:

• The Rocket Science Group LLC ‘MailChimp’ who process personal data with the purpose of marketing communications on our behalf in the US, and participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework.

• Tawk.to. Inc who process data with the purpose of supporting customer service communications on our behalf in the US. The company is registered with the Information Commissioner’s Office (ICO) in the United Kingdom and has certified its compliance with the EU-U.S. Privacy Shield Framework.

Security and Safeguards

We take reasonable and appropriate measures to protect Personal Information from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in the processing and the nature of the Personal Information.

The safeguards we have put in place to ensure that our contractors and other third parties keep your personal data secure and confidential and use it only as authorised by SDSD are as follows:

• We require partners to whom we disclose personal data to agree to a confidentiality agreement.
• We use data processors located outside the European Economic Area only after taking such steps as are required to ensure that personal data, they process on our behalf receives protection equivalent to that provided in the EEA.

As the transmission of data via the Internet cannot be assumed completely secure, we cannot guarantee the security of any of your data transmitted to our web-based software products; you are therefore responsible for any risk associated with such transmission. We will however at all times take all reasonable steps to ensure the transmission of your data is executed as securely as possible, and upon receipt of your data we will continue at all times to enforce strict security procedures and features in an attempt to prevent any unauthorised access.

Notice of Breach of Security

If a security breach causes an unauthorized intrusion into our systems that materially affects you or individual’s personal data contained within the licensed software, then SDSD will notify you as soon as possible and later report the action we took in response.

Retention of personal data

We retain personal data as follows:

• Marketing data – If a person opts out/unsubscribes of receiving marketing communications from us we will keep their first name, last name, company name, job title and email address only on an opt out list.
• Personal Data may be archived. These files are stored securely and only accessible via passwords with access restricted.

Your obligations as a data controller and/or processor

In using SDSD software products whereby you act as data controller and/or processor, you will be submitting and providing client data which may contain personal data, and potentially sensitive personal data of users and third parties. In using the SDSD software product you represent and warrant that you have obtained unambiguous consent to transfer such personal data (including sensitive personal data, if applicable) to SDSD for the purpose of receiving the Service.

Your rights

have the following rights in relation to your personal data

You may at any time to withdraw your consent to receive marketing communications from us by using the ‘unsubscribe’ button at the bottom of one of our marketing emails.

You have the right to update and correct the personal information we hold about you. You also have the right to request from us all personal information that we hold that relates to you, to request restriction of the processing of that data and to request that we delete that data or object to continued processing where it is excessive or no longer required for the purpose for which it was collected.

Where allowed by applicable law there may be an administrative charge for supply of copies of data and we may also require you to provide us with appropriate identification before we comply with this request.

Changes to this Privacy Statement

This Privacy Statement will be updated from time to time to reflect changes in our business.

Contacting SDSD

We welcome any questions or comments in relation to this privacy policy, and advise you to send any such communication via:

SD Software Developers Limited

Suite 3446, Unit 3A, 34-35 Hatton Garden,

London EC1N 8DX.

+44 20 3588 6740

Email: gdpr@sdsd.com

Privacy Policy last updated 20th April 2020