We are committed to safeguarding the privacy of our website visitors, service users, individual customers and customer personnel.
This policy applies where we are acting as a data controller with respect to the personal data of such persons; in other words, where we determine the purposes and means of the processing of that personal data.
We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website and services, we will ask you to consent to our use of cookies when you first visit our website.
In this policy, "we", "us", and "our" refer to TRC SPACE LTD. For more information about us, see Section 18.
In this Section 2, we have set out the general categories of personal data that we process and, in the case of personal data that we did not obtain directly from you, information about the source and specific categories of that data.
We may process data enabling us to get in touch with you ("contact data"). The contact data may include your name, email address, telephone number, postal address and/or social media account identifiers. The source of the contact data is you and/or your employer.
We may process your website user account data ("account data"). The account data may include your account identifier, name, email address, business name, job title, account creation and modification dates, website settings and marketing preferences. The primary source of the account data is you and/or your employer, although some elements of the account data may be generated by our website.
We may process information relating to our customer relationships ("customer relationship data"). The customer relationship data may include your name, the name of your business or employer, your job title or role, your contact details, your classification/categorisation within our customer relationship management system and information contained in or relating to communications between you and us, or between your employer and us. The source of the customer relationship data is you and/or your employer.
We may process your personal data that are provided in the course of the use of our services and generated by our services in the course of such use ("service data"). The service data may include any information you enter directly into the services platforms hosted by us. The source of the service data is you and/or your employer and/or our services.
We may process information relating to transactions, including purchases of services, that you process with us and/or through our website ("transaction data"). The transaction data may include your name, your contact details, your payment card details (or other payment details) and the transaction details. The source of the transaction data is you and/or our payment services provider.
We may process information contained in or relating to any communication that you send to us or that we send to you ("communication data"). The communication data may include the communication content and metadata associated with the communication.
We may process data about your use of our website and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system, including any 3rd party services outlined in Section 5.
Please do not supply any other person's personal data to us unless we prompt you to do so.
In this Section 3, we have set out the purposes for which we may process personal data and the legal bases of the processing.
Applicable EEA and UK data protection law requires having a “legal basis” for each purpose for which the Provider collects the Customer’s or their end user’s personal information. The legal basis for collecting and using the personal information described in this Section 3 will depend on the type of personal information and the specific context in which it is collected. Where relevant, the legal basis is outlined alongside the description of the data collected in this Section 3.
We may process your personal data for the purposes of operating our website, processing and fulfilling orders, providing services, supplying goods, generating invoices, bills and other payment-related documentation, and credit control. The legal basis for this processing is the necessity of operating the services and payment processing to fulfil any contracts, our legitimate interests, namely the proper administration of our website, services and business, and also where relevant due to your consent. The legal basis may also come from the necessity to comply with legal requirements, including applicable laws and regulations.
We may process personal data for the purposes of managing relationships, communicating with you (excluding direct marketing) by email, SMS, post, fax and/or telephone, providing support services and complaint handling. The legal basis for this processing is the necessity of communication with you to fulfil any agreement, our legitimate interests, namely communications with website visitors, service users, individual customers and customer personnel, the maintenance of relationships, and the proper administration of our website, services and business, and also where relevant the due to your consent. The legal basis may also come from the necessity to comply with legal requirements, including applicable laws and regulations.
We may process personal data for the purposes of personalising the content that you see on our website and through our services to ensure that you only see material that is relevant to you. The legal basis for this processing is the necessity of operating services to fulfil any agreements, our legitimate interests, namely improving the experience of our website, services and business generally, and also where relevant due to your consent. The legal basis may also come from the necessity to comply with legal requirements, including applicable laws and regulations.
We may process personal data for the purposes of creating, targeting and sending direct marketing communications by email, SMS, post and/or fax and making contact by telephone for marketing-related purposes. The legal basis for this is our legitimate interests, namely promoting our business and communicating marketing messages and offers to website visitors and service users, and also, where relevant, due to your consent. The legal basis may also come from the necessity to comply with legal requirements, including applicable laws and regulations.
We may process personal data for the purposes of researching and analysing the use of our website and services, as well as researching and analysing other interactions with our business. The legal basis for this processing is the necessity of operating services to fulfil any agreements, our legitimate interests, namely monitoring, supporting, improving and securing our website, services and business generally, and also, where relevant, due to your consent. The legal basis may also come from the necessity to comply with legal requirements, including applicable laws and regulations.
We may process personal data for the purposes of creating and maintaining databases, backup copies of databases and business records generally. The legal basis for this processing is the necessity of operating services to fulfil any agreement, our legitimate interests, namely ensuring access to all the information needed to properly and efficiently run our business in accordance with this policy, and also where relevant due to your consent. The legal basis may also come from the necessity to comply with legal requirements, including applicable laws and regulations.
We may process personal data for the purposes of security and the prevention of fraud and other criminal activity. The legal basis for this processing is the necessity of upholding our obligations in fulfilling any agreement, our legitimate interests, namely the protection of the website, services and business, and the protection of others, and also where relevant due to your consent. The legal basis may also come from the necessity to comply with legal requirements, including applicable laws and regulations.
We may process personal data where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks and/or obtaining professional advice. The legal basis for this processing is the necessity of upholding our obligations in fulfilling any agreement, our legitimate interests, namely the proper protection of the business against risks, and also, where relevant, due to your consent. The legal basis may also come from the necessity to comply with legal requirements, including applicable laws and regulations.
We may process personal data where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or an administrative or out-of-court procedure. The legal basis for this processing is the necessity of upholding our obligations in fulfilling any agreement, and our legitimate interests, namely the protection and assertion of our legal rights, your legal rights, and the legal rights of others, and also, where relevant, due to your consent. The legal basis may also come from the necessity to comply with legal requirements, including applicable laws and regulations.
We may also process personal data where such processing is necessary for compliance with a legal obligation to which we are subject or to protect your vital interests or the vital interests of another natural person. The legal basis for this processing is the necessity of upholding our obligations in fulfilling any agreement, and our legitimate interests, namely the protection and assertion of our legal rights, your legal rights, and the legal rights of others, and also, where relevant, due to your consent. The legal basis may also come from the necessity to comply with legal requirements, including applicable laws and regulations.
We will use your personal data for the purposes of automated decision-making in relation to determining the most likely users to benefit from our services.
This automated decision-making will involve analysing your job title and company alongside non-personal data related to that company. This data will be compared against previous historical data to identify users most likely to benefit from our services.
The significance and possible consequences of this automated decision-making are particular uses being more or less likely to be targeted by marketing or communication from us in relation to the usage of our services.
We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, and obtaining professional advice.
Your personal data held in our website and services database will be stored on the servers of our hosting services providers, Amazon Web Services, Inc., identified at https://aws.amazon.com/privacy/?nc1=f_pr.
We may disclose your personal data to the 3rd party services integrated into our services directly by you insofar as reasonably necessary to fulfil any contractual obligations of service.
Financial transactions relating to our website and services may be handled by our payment services providers. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds.
In addition to the specific disclosures of personal data set out in this Section 5, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject or to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise, or defence of legal claims, whether in court proceedings or an administrative or out-of-court procedure.
We may disclose your personal data to The Rocket Science Group LLC, identified at https://www.intuit.com/privacy/statement/ insofar as reasonably necessary for the purposes of maintaining a mailing list and delivering marketing information to you, as well as to track sign-ups to our services.
We may disclose your personal data to Mixpanel UK Ltd., identified at https://mixpanel.com/legal/privacy-policy/, insofar as reasonably necessary for the purposes of analysing the user behaviour within our website and services.
We may disclose your personal data to Google LLC, identified at https://policies.google.com/privacy, insofar as reasonably necessary for the purposes of analysing the user behaviour within our website and services.
We may disclose your personal data to Twilio Limited, identified at https://www.twilio.com/legal/privacy, insofar as reasonably necessary for the purposes of enabling the collection, sorting, and transfer of data to other 3rd party processors listed here.
Flow Engineering's use and transfer to any other app of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.
In this Section 6, we provide information about the circumstances in which your personal data may be transferred to a third country under UK and/or EU data protection law.
We may transfer your personal data from the European Economic Area (EEA) to the UK and process that personal data in the UK for the purposes set out in this policy and may permit our suppliers and subcontractors to do so during any period with respect to which the UK is not treated as a third country under EU data protection law or benefits from an adequacy decision under EU data protection law. We may transfer your personal data from the UK to the EEA and process that personal data in the EEA for the purposes set out in this policy and may permit our suppliers and subcontractors to do so during any period with respect to which EEA states are not treated as third countries under UK data protection law or benefit from adequacy regulations under UK data protection law.
The hosting facilities for our website and services are situated in the United Kingdom. The competent data protection authorities have made an "adequacy decision" with respect to the data protection laws of the United Kingdom. Transfers outside of the United Kingdom will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the competent data protection authorities, a copy of which can be obtained from https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en.
Some of our data analytics suppliers are situated in the United States of America. The competent data protection authorities have made an adequacy determination with respect to the data protection laws of this country. Transfers to the United States of America will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the competent data protection authorities, a copy of which can be obtained from https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en.
You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
This Section 7 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
We will retain your personal data as follows:
(a) contact data will be retained for a minimum period of 48 months following the date of the most recent contact between you and us and for a maximum period of 10 years following that date;
(b) account data will be retained for a minimum period of 2 months following the date of closure of the relevant account and for a maximum period of 2 years following that date;
(c) customer relationship data will be retained for a minimum period of 48 months following the date of termination of the relevant customer relationship and for a maximum period of 10 years following that date;
(d) service data will be retained for a minimum period of 48 months following the date of termination of the relevant contract and for a maximum period of 10 years following that date;
(e) transaction data will be retained for a minimum period of 48 months following the date of the transaction and for a maximum period of 10 years following that date;
(f) communication data will be retained for a minimum period of 48 months following the date of the communication in question and for a maximum period of 10 years following that date]; and
(g) usage data will be retained for 10 years following the date of collection.
If you grant to us a licence to publish any of your personal data, we may continue to retain and publish that personal data after the end of the relevant retention period specified in this Section 7 in accordance with the applicable licence terms, subject to your data subject rights.
Notwithstanding the other provisions of this Section 7, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject or to protect your vital interests or the vital interests of another natural person.
We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.
We will take appropriate precautions to prevent unauthorised access to data processing facilities, e.g. magnetic or chip cards, keys, electronic door openers, facility security services and/or entrance security staff, alarm systems, and video/CCTV Systems.
We will take appropriate precautions to prevent unauthorised use of the data processing and data storage systems, e.g. (secure) passwords, automatic blocking/locking mechanisms, two-factor authentication, and encryption of data carriers/storage media.
We will take appropriate precautions to maintain internal access control and prevent unauthorised reading, copying, changes or deletions of data within the system, e.g. rights authorisation concept, need-based rights of access, logging of system access events.
We will take appropriate precautions to prevent unauthorised reading, copying, changes or deletions of data with electronic transfer or transport, e.g. encryption, virtual private networks (VPN), and electronic signature.
We will take appropriate precautions to ensure verification, whether and by whom personal data is entered into a data processing system, is changed, or deleted, e.g., logging and document management.
We will take appropriate precautions to prevent accidental or wilful destruction or loss, e.g. backup strategy (online/offline; on-site/off-site), uninterruptible power supply (UPS), virus protection, firewall, reporting procedures and contingency planning.
We will take appropriate precautions to ensure all third-party data processing occurs with corresponding instructions from the Provider, e.g.: unambiguous contractual arrangements, formalised order management, strict controls on the selection of the service provider, and duty of pre-evaluation.
The following personal data will be stored by us in encrypted form: password(s) and cardholder data.
Data relating to your enquiries and financial transactions that are sent from your web browser to our web server or from our web server to your web browser will be protected using encryption technology.
You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
You should ensure that your password is not susceptible to being guessed, whether by a person or a computer program. You are responsible for keeping the password you use for accessing our website confidential, and we will not ask you for your password (except when you log in to our website).
In this Section 9, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
Your principal rights under data protection law are:
(a) the right to access - you can ask for copies of your personal data;
(b) the right to rectification - you can ask us to rectify inaccurate personal data and to complete incomplete personal data;
(c) the right to erasure - you can ask us to erase your personal data;
(d) the right to restrict processing - you can ask us to restrict the processing of your personal data;
(e) the right to object to processing - you can object to the processing of your personal data;
(f) the right to data portability - you can ask that we transfer your personal data to another organisation or to you;
(g) the right to complain to a supervisory authority - you can complain about our processing of your personal data; and
(h) the right to withdraw consent - to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.
You have the right to confirm whether or not we process your personal data and, where we do, access the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply you with a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. You can access your personal data by contacting us via email at contact@flowengineering.com.
You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
In some circumstances, you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
In some circumstances, you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful, but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by a third party or by us. If you make such an objection, we will cease to process the personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you object, we will cease to process your personal data for this purpose.
You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation unless the processing is necessary for the performance of a task carried out for reasons of public interest.
To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into a contract,
and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
If you consider that our processing of your personal data infringes data protection laws, you have a legal right to complain to a supervisory authority responsible for data protection. In relation to complaints under EU data protection law, you may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement; in relation to complaints under UK data protection law, you should do so in the UK.
To the extent that the legal basis for our processing of your personal data is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
You may exercise any of your rights in relation to your personal data by written notice to us or emailing us at contact@flowengineering.com, in addition to the other methods specified in this Section 9.
Our website includes hyperlinks to and details of third-party websites.
In general, we have no control over and are not responsible for the privacy policies and practices of third parties.
Our website and services are targeted at persons over the age of 18.
If we have reason to believe that we hold the personal data of a person under that age in our databases, we will delete that personal data.
Please let us know if the personal information we hold about you needs to be corrected or updated.
A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
Cookies may not contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.
We use cookies for the following purposes:
(a) authentication and status - we use cookies to identify you when you visit our website and as you navigate our website, and to help us determine if you are logged into our website (cookies used for this purpose are: Log In status cookies for Flow services;
(b) personalisation - we use cookies to store information about your preferences and to personalise our website and services for you (cookies used for this purpose are: Preference Settings cookies for Flow services);
(c) analysis - we use cookies to help us to analyse the use and performance of our website and services (cookies used for this purpose are: Analytics Cookies for Flow Services); and
(d) cookie consent - we use cookies to store your preferences in relation to the use of cookies more generally (cookies used for this purpose are: Cookie Preference Cookie for Flow Website).
Our service providers use cookies, which may be stored on your computer when you visit our website.
We use Google Analytics. Google Analytics gathers information about the use of our website by means of cookies. The information gathered is used to create reports about the use of our website. You can find out more about Google's use of information by visiting https://www.google.com/policies/privacy/partners/, and you can review Google's privacy policy at https://policies.google.com/privacy.
We use Segment to analyse website and services users. This service uses cookies to recognise repeat visits to our website and services. You can view the privacy policy of this service provider at https://www.twilio.com/legal/privacy.
Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser and from version to version. You can, however, obtain up-to-date information about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647 (Chrome);
(b) https://support.mozilla.org/en-US/kb/enhanced-tracking-protection-firefox-desktop (Firefox);
(c) https://help.opera.com/en/latest/security-and-privacy/ (Opera);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(e) https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac (Safari); and
(f) https://support.microsoft.com/en-gb/help/4468242/microsoft-edge-browsing-data-and-privacy (Edge).
Blocking all cookies will have a negative impact on the usability of many websites.
If you block cookies, you will not be able to use certain features on our website.
We may update this policy from time to time by publishing a new version on our website.
You should check this page occasionally to ensure you are happy with any changes to this policy.
This website is owned and operated by TRC Space Ltd.
We are registered in England and Wales under registration number 10407202, and our registered office is at Flow Engineering, Northwest House, 119 Marylebone Road, London, United Kingdom, NW1 5PU.
Our principal place of business is at Flow Engineering, Northwest House, 119 Marylebone Road, London, United Kingdom, NW1 5PU.
You can contact us:
(a) by post to the postal address given above; or
(b) by email at contact@flowengineering.com.
© Copyright 2024 TRC Space Ltd.
All rights reserved.
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