Privacy Policy

Thank you for choosing to use Proofdesk, a service offered by Native Systems Limited.

Native Systems Limited (referred to as “Proofdesk”, “we”, “our” or “us”) is a company registered in the Isle of Man with registration number 130089C. Our registered office is at First Floor, 8 Victoria Street, Douglas, Isle of Man, IM1 2LH.

We are the controller of personal data obtained via our website and software applications, meaning we are the organisation legally responsible for deciding how and for what purposes it is used.

Please read this Privacy Policy carefully as it contains important information on who we are and how we collect, store, use and share information relating to you (your personal data). It also explains your rights in relation to your personal data and how to contact us or a relevant regulator in the event you have a complaint.

We are subject to the IOM General Data Protection Regulation (IOM GDPR).

1. What this policy applies to

This Privacy Policy relates to your use of our website and software applications only.

Throughout our website and software applications we may link to other websites operated by third parties. Those third party websites may also gather information about you in accordance with their own separate privacy policies.

2. Personal data we collect about you

The personal data we collect about you depends on the particular activities you carry out on our website and software applications.

If you do not provide your personal data where required it may prevent us from providing products and services to you.

Given the nature of our website, we do not expect to collect the personal data of anyone under 13 years old. If you are aware that any personal data of anyone under 13 years old has been shared with our website please let us know so that we can delete that data.

3. How your personal data is collected

We collect personal data from you:

• Directly, when you enter or send us information, such as when you register your interest in our services, create an account with us and send us feedback, and

• Indirectly, such as your browsing activity while using our website and software applications.

4. How and why we use your personal data

Under data protection law, we can only use your personal data if we have an appropriate reason, eg:

• Where you have given consent

• To comply with our legal and regulatory obligations

• For the performance of a contract with you or to take steps at your request before entering into a contract, or

• For our legitimate interests or those of a third party

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own.

5. Marketing

We may use your personal data to send you updates about our products and services.

We have a legitimate interest in using your personal data for marketing purposes however, where consent is needed, we will ask for this separately and clearly.

You have the right to opt out of receiving marketing communications at any time by:

• Contacting us at [e-mail]

• Unsubscribing from our mailing lists at the bottom of inbound marketing emails

We will never sell your personal data to other organisations.

6. Who we share your personal data with

We routinely share personal data with:

• Third parties we use to help deliver our products and services to you

• Other third parties we use to help us run our business

We only allow those organisations to handle your personal data if we are satisfied they take appropriate measures to protect your personal data.

We, or the third parties mentioned above, may occasionally need to share your personal data with:

• External auditors

• Professional advisors

• Law enforcement agencies

• Other parties in connection with a significant corporate transaction or restructuring

7. How long your personal data will be kept

We will not keep your personal data for longer than we need it for the purpose for which it is used. Therefore, different retention periods apply for different types of personal data.

Following the end of the relevant retention period, we will delete or anonymise your personal data.

8. Transferring your personal data out of the IOM

The EEA, IOM and other countries have differing protection laws, some of which may provide lower levels of protection.

It is sometimes necessary for us to share your personal data to countries outside the IOM and EEA. In those cases we will comply with applicable IOM and EEA laws designed to ensure the privacy of your personal data.

We will ensure all protections required by applicable IOM and EEA laws are in place before transferring personal data to any organisation.

9. Cookies and other tracking technologies

A cookie is a text file which is placed onto your device when you use our website or software applications. We use cookies and similar technologies to help us to recognise you and to store some information about your preferences and actions.

10. Your rights

You generally have the following rights, which you can usually access free of charge:

• The right to be provided with a copy of your personal data

• The right to require us to correct any mistakes in your personal data

• The right to require us to delete your personal data in certain circumstances

• The right to require us to restrict use of your personal data in certain circumstances

• The right to receive the personal data you provided to us, ins a structured, commonly used and machine-readable format in certain circumstances

• The right to object at any time to your personal data being used for direct marketing

• The right to object to our continued use of your personal data in certain circumstances

• The right not to be subject to a decision based solely on automated processing that produces legal effects concerning you or similarly affects you

For further information on each of those rights, including the circumstances in which they do and do not apply, please contact us. You may also find it helpful to refer to the guidance from the IOM’s Information Commissioner on your rights under the IOM GDPR.

If you would like to exercise any of those rights, please email [e-mail]

11. Keeping your personal data secure

We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by IOM Government and leading businesses.

12. How to complain

Please contact us if you have any queries or concerns about our use of your information. We hope we will be able to resolve any issues you may have.

You also have the right to lodge a complaint with the Information Commissioner. The IOM’s Information Commissioner may be contacted at https://www.inforights.im/complaint-handling/how-to-make-a-complaint-to-the-information-commissioner/ or by telephone: [phone].

13. Changes to this Privacy Policy

We may change this privacy policy from time to time—when we make significant changes, we will take steps to inform you, for example via our website and where necessary by email.

14. How to contact us

You can contact us and/or our Data Protection Officer by post or email or if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.

Data Protection Officer

Native Systems Limited

First Floor

8 Victoria Street

Douglas

Isle of Man

IM1 2LH

[e-mail]

15. Additional Help

If you would like this policy in another format (for example audio, large print, braille) please contact us.