Privacy policy

Contact details for Sona Analytics

Info@sonaanalytics.com

Date Privacy notice completed: 02/02/2022

The type of personal information we collect

We currently collect and process the following information:

• Sona Analytics primarily requests Personal Data from you if the site requires registration. Registration requests that you provide Personal Data, such as your First Name, Last Name, and business e-mail address.
• Personal Data provided by you voluntarily through email, order, registration and online forms, promotions, chats, phone call and any other means.
• Sona Analytics may collect Personal Data to comply with the anti-money laundering laws or others if applicable.
• We may use third-party payment services (“Payment Service”) to collect payments made through the Site. If you wish to make a payment via this option, you may be directed to a webpage hosted by a Payment Service (or a Payment Service’s service providers) and not by Sona Analytics. Any Personal Data that you provide through this page will be collected by the Payment Service and not by Sona Analytics, hence will be subject to Payment Service’s privacy policy, rather than this Privacy Policy. Sona Analytics has no control over, and is not responsible for, a Payment Service’s use of information collected through a Payment Service page.
• Sona Analytics collects information through other means such as online searches, events and conferences, introductions, from employers that enrol their employees in our services or provide services to us, and any third party business partners.

How we get the personal information and why we have it

Most of the personal information we process is provided to us directly by you for one of the following reasons:

• Fulfillment of Requests. Sona Analytics may use Personal Data about you to deliver products and services to you and inform you of those you have ordered. We will engage in these activities for the purposes of managing and fulfilling our contractual obligations to you.
• Marketing Communications. Sometimes, in compliance with applicable laws, we may use Personal Data to inform you of various products, services and promotions and other information we believe will be of interest to you. We may also use various media contacts for press release distribution or other newsworthy developments related to our business activities.
• Administrative Communications. Sona Analytics has the right to use Personal Data to send you important information regarding the Site, products and services, account status, User Agreement, this Privacy Policy and any other agreements or policies relevant to your use of this Site.
• Compliance with law and regulation. We may use Personal Data to comply with applicable legal and regulatory requirements from the law.

Use of Other Data

We also receive personal information indirectly, from the following sources in the following scenarios:

• Monitoring Data. Sona Analytics and its service providers may collect and/or track statistical data e.g., Domain Name, Screen Resolution etc. involving the use of the Site (“Monitoring Data”). We use Monitoring Data to help us understand who uses the Site and to improve and market it, as well as our other web sites and services.
• Unless combined with Personal Data, Monitoring Data does not personally identify you or any other user, and we may use it for any purpose.
• Aggregated Data. We may aggregate Personal Data in a manner such that the end-product does not personally identify you or any other user of the Site, for example, by using information to calculate how many of our users are accessing our Site from a particular telephonic code area. Such aggregate information may also be used for any purpose.
• To enhance the Internet experience on the Site, Sona Analytics and our service providers may use ‘cookies’ on the Site. Cookies are data that a web server transfers to an individual’s computer for recordkeeping and other purposes. We use cookies and other technologies to facilitate users’ ongoing access to and use of our Site. If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to automatically decline cookies, or to be given the choice of declining or accepting the transfer of a particular cookie, or cookies from a particular web site, to your computer. If cookies are disabled, however, all features of the Site may not operate as intended. Information about disabling cookies can be found on your Internet browser provider’s web site.
• The Site may have a Cookie Policy that applies to its use of cookies and other similar tracking technologies. If it does, then the Cookie Policy will apply in addition to this Privacy Policy.
• Tools.
  • We and our service providers may also use various common Internet tools such as ‘pixel tags,’ ‘action tags,’ ‘web beacons,’ ‘.gif tags,’ ‘JavaScript’ or similar technologies (together, “Tools”) in connection with Site pages and email messages in certain formats to, among other things, track the actions of Site users and email recipients, to determine the success of marketing campaigns and to compile statistics about Site usage and response rates. Tools allow us to count users who have visited certain pages of the Site, to deliver services, and to help determine the effectiveness of promotional or advertising campaigns. When used in email messages in certain formats, Tools can tell the sender whether and when the email has been opened.
  • Sona Analytics uses cookies and Tools to understand how the Site is used and to customize and enhance the Internet experience of individual users. When you revisit the Site, Sona Analytics may recognize you by a Tool and customize your experience. For example, once you have completed the registration process, a cookie and/or Tool will be used to avoid having you register again. We believe cookies and Tools add value to the user experience.
  • We may use Google Analytics, which uses cookies and other similar technologies, to collect and analyse information about Site use and to report on activities and trends. The service may also collect information regarding the use of other websites, apps and online resources. You can learn about Google’s practices by going to https://policies.google.com/privacy/partners, and opt out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.
  • We do not respond to browser do-not-track signals at this time.
  • We may use third-party services to verify that you are a human user. Any information collected as part of such verification is subject to the privacy policy of the third-party service provider.
  • IP Addresses. When you visit and interact with the Site, we and our third-party service providers may collect Internet Protocol (IP) addresses. Your IP address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). This number is identified and logged automatically in our server log files whenever you visit the Site, along with the time(s) of your visit(s) and the page(s) that you visited. We use IP addresses to understand how the Site is used by our users, to improve the Site and to enhance user experience of the Site. We may also derive your approximate location from your IP address.

If we are required to treat Other Data as Personal Data under applicable law, then we may use and disclose it for the purposes described above, as well as for the purposes for which we use and disclose Personal Data as detailed in this Privacy Policy.

Disclose of Personal Information

We may disclose this information with the following parties and for the following purposes:

• Third-Party Service Providers. We may provide Personal Data to third-party service providers, who provide services to us, including but not limited to, data analysis, order fulfilment, payment processing, marketing automation, and other services. Our services providers have been carefully selected and commissioned by us, are bound by contract, and process Personal Data for purposes compatible with this Privacy Policy.
• Affiliate Communications. In compliance with applicable laws, Sona Analytics may transfer Personal Data among our affiliates to allow our affiliates to contact you regarding products, programs, services and promotions that they believe may be of interest to you, and such affiliates may otherwise use your Personal Data in accordance with the privacy policy applicable to them as specified in the referenced above in this bullet. If you would prefer not to receive marketing communications from Sona Analytics or our affiliates, please see the “Your Choices” section below. Sona Analytics Corporation will be the party responsible for jointly used Personal Data.
• Strategic Partners and Co-Branded Sites. From time to time, we may enter into a special relationship with another company that is not owned by or affiliated with Sona Analytics to provide or promote joint products, services, applications, or features (together, “Jointly Offered Items”). These special relationships may include co-branded web sites (“co-branded pages”). Any information, including Personal Data, that you provide in connection with one of these Jointly Offered Items, and/or on one of these co-branded pages, will be shared with our third-party partners. You should check these third parties’ web sites for information regarding their privacy practices. PLEASE NOTE THAT THIS PRIVACY STATEMENT DOES NOT ADDRESS THE PRIVACY OR INFORMATION PRACTICES OF ANY THIRD PARTIES. If you do not want Personal Data about you shared with such third parties, please do not provide Personal Data in connection with the Jointly Offered Items and/or co-branded pages.
• Third-Party Data Providers. If you subscribe to a Sona Analytics product or service that contains third-party data, we may be required to provide your Personal Data to the third party as part of our reporting obligations. We will only do so if a third-party data provider conditions your receipt of their data on knowing your identity.
• Conferences and Events. When you attend a conference or event organized by Sona Analytics, your name and contact information may be shared with other attendees and co-hosts of the conference or event.
• We may share the Personal Data you provide in connection with Promotions with third-party sponsors of such Promotions (irrespective of whether such Promotions are hosted by us), or otherwise in accordance with the rules applicable to those Promotions.
• We may disclose or transfer any and all Personal Data that we collect to an affiliated entity or a third party (and their respective advisors) in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including without limitation in connection with any bankruptcy or similar proceedings).
• Law Enforcement; Emergencies; Compliance. We may use and disclose Personal Data about you to others as we believe to be appropriate: (a) in compliance with laws, rules, or regulations in any country in which Sona Analytics operates, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from government or public authorities, including government and public authorities outside your country of residence; (d) to enforce our Terms of Use; (e) to protect our operations or those of any affiliated entities; (f) to protect the rights, privacy, safety or property of Sona Analytics, its affiliated entities, you, or others; and (g) to permit us to pursue available remedies or limit the damages that we may sustain. For example, we may, to the fullest extent the law allows, disclose Personal Data about you to law enforcement agencies to assist them in identifying individuals who have been or may be engaged in unlawful activities. Where we receive requests for Personal Data from domestic or foreign government or public authorities, we will resist, narrow or challenge such requests as appropriate and to the extent permitted by applicable law.

Under the General Data Protection Regulation (GDPR), the lawful bases we rely on for processing this information are:

(a) Your consent. You are able to remove your consent at any time. You can do this by contacting us. Our details are at the top of this Policy.

(b) We have a contractual obligation.

(c) We have a legal obligation.

(d) We have a vital interest.

(e) We need it to perform a public task.

(f) We have a legitimate interest.

How we store your personal information

Your Personal Data may be stored and processed in any country where we have facilities or in which we engage service providers. In certain circumstances, courts, law enforcement agencies, regulatory agencies, or security authorities in those other countries may be entitled to access your Personal Data.

If you are located in the European Economic Area (“EEA”) or the UK: Some of the non-EEA countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these countries is available on the EU Commission’s adequacy list online at: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en). For transfers from the UK and the EEA to countries not considered adequate by the European Commission, we have put in place adequate measures, such as standard contractual clauses adopted by the European Commission and the UK, to protect your Personal Data. You may obtain a copy of these measures by contacting us using the information provided in the “Contact Information for Sona Analytics” section below.

If you are located in other countries, we will also ensure that we have appropriate legal grounds to perform cross-border transfers of your Personal Data. Where required in certain jurisdictions, we comply with requirements on initial processing of Personal Data with the use of databases located in the country of collection of your Personal Data.

Data Retention

We will retain Personal Data about you for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law. The criteria used to determine our retention periods include: (i) the length of time we have an ongoing relationship with you; (ii) whether there is a legal obligation to which we are subject; and (iii) whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

Once this Retention Period has ended we will then dispose your information by:

• If the data is stored digitally:
  • On a digital storage device: Manually deleting and ensuring data is overwritten via the use of secure deletion software.
  • Elsewhere, or if unable to perform the former: Seeking specialist IT advice.
• If the data is stored on physical paper:
  • Using a shredder to destroy the paper with its Personal Data on it.

 Your data protection rights

Under data protection law, you have rights including:

Your right of access – You have the right to ask us for copies of your personal information.

Your right to rectification – You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.

Your right to erasure – You have the right to ask us to erase your personal information in certain circumstances.

Your right to restriction of processing – You have the right to ask us to restrict the processing of your personal information in certain circumstances.

Your right to object to processing – You have the the right to object to the processing of your personal information in certain circumstances.

Your right to data portability – You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.

Please contact us at Email: info@sonaanalytics.com

How to complain

If you have any concerns about our use of your personal information, you can make a complaint to us at Email: info@sonaanalytics.com

You can also complain to the ICO if you are unhappy with how we have used your data.

The ICO’s address:           

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Helpline number: 0303 123 1113

ICO website: https://www.ico.org.uk