Sippi

Privacy Policy

1. INTRODUCTION

We are pleased that you have elected to visit this Website (referred to herein as the “Website” or the “Site”), operated by, or on behalf of, Agena Solutions Limited T/A Atria (collectively, “Atria”, “us” and “we”).

This privacy notice provides you with details of how we collect and process your personal data through your use of our website and services. Atria are the data controller, for all data provided to us as a result of direct communication from customers / clients wishing to enquire or utilise our services, and we are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).

We have appointed a Data Protection Officer who oversees privacy related matters for us. If you have any questions about this privacy notice, please contact the Data Protection Officer using the details set out below or email: dpo@weareatria.com.

2. WHO WE ARE

Our full details are: Agena Solutions Limited T/A Atria Company Registration Number 06496884

Email address: info@weareatria.com. Registered office address: 49 Station Road, Polegate, BN26 6EA.

We are registered as a Data Controller with the Information Commissioners Office and our reference number is Z2270603.

It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at: dpo@weareatria.com.

3. THE DATA THAT WE COLLECT ABOUT YOU

Personal data means any information capable of identifying an individual. It does not include anonymised data. We may process the following categories of personal data about you:

Communication Data: that includes any communication that you send to us whether that be through the contact form on our website, through email, text, apple store, google store, Sippi App, social media messaging, social media posting or any other communication that you send us. We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance, or defence of legal claims. Our lawful ground for this processing is our legitimate interests, which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.

Technical Data: that includes data about your use of our website and online services such as your IP address, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is from our analytics tracking system. We process this data to analyse your use of our website and other online services, to administer and protect our business and website, to deliver relevant website content and advertisements to you and to understand the effectiveness of our advertising. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business and to grow our business.

4. COOKIES

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see the Atria Cookie Policy.

5. DISCLOSURE OF PERSONAL DATA

We may have to share your personal data with the parties set out below:

• Professional advisers including lawyers, bankers, and auditors

• Regulatory bodies that require us to report processing activities

• Law Enforcement Agencies

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

We do not transfer your personal data outside the UK.

6. DATA SECURITY

We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorisation. We also allow access to your personal data only to those employees and partners who have a business need to know such data. They will only process your personal data on our instructions, and they must keep it confidential.

We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to.

7. DATA RETENTION

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, contractual, accounting, or reporting requirements.

When deciding what the correct time is to keep the data for, we look at its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.

8. YOUR LEGAL RIGHTS

Under data protection laws you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent.

You can see more about these rights at: https://ico.org.uk/individual-rights

If you wish to exercise any of the rights set out above, please email us at: dpo@weareatria.com

If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you. If you have any queries our email address is:

dpo@weareatria.com

9. UPDATES TO THIS PRIVACY POLICY

Atria recognises that transparency is an ongoing responsibility so we will keep this privacy policy under regular review.