Introduction

In this Privacy Policy, "We", "Us" and "Our" mean Shaderware Limited, registered in England, Registered Number : 05897159. VAT Registration Number: GB-825 5772 08.Registered Address : 20 Westbrook, Darlington, DL3 6TD, UK. We are firmly committed to protecting your privacy and aim to be clear when we collect your information and use it only as you would reasonably expect.

How we use personal information

We will not use your personal information unless we have first told you how we will use it or it is obvious how we will use it.

What data we may hold and why:

· Information that you provide by filling in forms, applications, or as part of our customer due diligence procedures. This includes information provided at the time of registering to use trial software, requesting further information, or making a purchase. We may also ask you for information when you report a problem with our products.

· If you contact us, we may keep a record of that correspondence. This is used to inform our future conversations and to inform you about our products and updates

· To provide you with information, products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes.

· We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.

· When you initiate a payment transaction, we also collect financial information such as credit card, debit card, or bank account details.

· We hold employee data for administration purposes

· To establish identity, residence, or place of business. Such proofs of identification may be stored electronically on our servers in order to comply with our legal and regulatory obligations. Your IP address, computer information, and access times may be tracked against your records with us for purposes of preventing fraud, establishing your identity, and creating an audit trail when using the simulators.

· Competitions may be made available on our website from time to time. You do not have to participate in these, however if you choose to you may be asked to disclose some personal information. At the time of entering the competition it will be made clear to you who will have access to your personal information and why. You are not obliged to continue with your competition entry, however if you do so you accept that you may receive a prize.

Our legal basis for processing personal information

Our lawful basis for the purposes that we process personal information is consent, for the performance of a contract, or for our legitimate interests.

The law allows us to collect and use personal data if it is necessary for our legitimate business interest and so long as its use is fair, balanced and does not unduly impact your rights. In many situations, the best approach for our customers is to process personal data because of our legitimate interests, rather than consent.

We will ask for your consent to send you marketing emails and text messages. You can withdraw consent for this at any time.

We may also share your personal information where we are compelled by law to do so.

We process employee personal information to meet our legal obligations as an employer.

How we collect personal information

We collect personal information from you directly through our website, through surveys and sometimes paper forms.

We may collect information about the software on your computer (your browser version etc.) and your IP address (your connection with the internet) for purposes of preventing fraud, establishing your identity, and creating an audit trail when using the simulators. This may happen automatically without your being aware of it.

We may use cookies (small text files which we and other website operators store on your computer when you visit our websites) to deliver a better and more personalised interaction. They enable us to recognise you when you return to the Website, store information about your preferences, and improve the way your searches are processed. They also enable us to generate statistics about the number of visitors we have and how they use the Website and the internet. You can set your browser to reject our cookies if you wish (you should consult your browser help section for details), but this might restrict your use of the website and other websites.

The personal information that we collect

For marketing and administration we may collect:

· Your name

· Information about your specialities

· Your mailing preferences

· Work place name, job title, address and contact information

· Source of referral

· Financial records and information

How we may share personal information

We may share some of your personal information with organisations that carry out processing operations on our behalf, such as web services companies and mailing organisations. We carry out checks on these companies before we work with them and put a contract in place that sets out our expectations and requirements, especially regarding how they manage the personal information that we give to them.

We do not sell or share personal information to third parties for the purposes of marketing.

We will not sell personal information other than as part of a sale of a substantial part of our assets. We may disclose it to a prospective purchaser, but only for use in connection with that sale.

We may need to disclose your details if required to the police, regulatory bodies or legal advisors.

We will only ever share your data in other circumstances if we have your explicit and informed consent.

It may sometimes be necessary to transfer personal information overseas. Any transfers made will be in compliance with data protection regulation.

How we protect personal information

We undertake regular reviews of who has access to information that we hold to ensure that your information is only accessible by appropriately trained staff and contractors.

We provide guidance and regular data protection training to our staff.

We ensure that there are appropriate technical controls in place to protect your personal details. For example, our computer network and servers are protected and routinely monitored.

We store all personal information that you supply us with on secured servers or in secure paper files.

Unfortunately, the transmission of information over the internet is not completely secure. Although we will do our best to ensure that your personal information is protected, we cannot guarantee the security of your data transmitted to the website. Any transmission of your personal information by you is therefore at your own risk. Once we have received your information, we will use strict procedures and security features to try and prevent unauthorised access.

How long we keep personal information

We will only keep personal information for as long as we have a valid reason for keeping it. After that we delete or dispose of the information securely.

We keep personal information about:

· Our customers indefinitely so that we can administer and prove ownership. Non-core information (e.g. personal details not relevant to prove ownership at any point in time) about customer employees is destroyed on request.

· Surveys of prospective customers for three years after the survey so that data can be referenced for statistical analysis.

· Employees for the duration of their employment and six years after employment ceases in accordance with the law.

Your rights

You have a right to know what personal data we hold, who we acquired it from, how we process it, the logic involved in any automatic processing, and who we disclose it to. Any access request may be subject to a reasonable fee to meet our costs in providing you with details of the information we hold about you.

You have a right to ask us not to process your personal data for direct marketing purposes.

You have a right to ask us not to make decisions based solely on the automatic processing of your personal information.

You have a right to ask us not to process your personal information in a way that is likely to cause unwarranted and substantial damage or distress.

You have a right to ask us to erase your personal information.

These statutory rights are qualified by exceptions and exemptions.

To exercise any of these rights, please contact us using the address below.

You can find out more about your rights from the Information Commissioner, who regulates data protection and privacy.

Changes to this policy

We may change this Privacy Policy from time to time. If we make any significant changes in the way we treat your personal information we will make this clear on our website or by contacting you directly.

Contact

Please feel free to contact us with any questions, comments or queries regarding this Privacy Policy. All questions should be directed to the Data Protection Officer at Shaderware Limited at 62 West Crescent, Darlington, DL3 7PR, UK, dpo@shaderware.com.