Privacy Policy

**Privacy Policy**

 

**Last Updated:** [ 28 June 2025]

 

**Introduction**

 

Welcome to Soanes IT. We are committed to protecting the privacy and security of your personal data. This Privacy Policy explains how Soanes IT ("we," "us," or "our") collects, uses, stores, and shares your personal information when you visit our website at www.soanes.it, use our services, or interact with us.

 

Soanes IT is registered with the Information Commissioner's Office (ICO) under registration number: **[ZB495391]

 

We adhere to the principles of the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018 (DPA 2018).

 

**Who We Are**

 

  * **Name:** Soanes IT

  * **Address:** [48 Windsor Road Cosham PO6 2TG]

  * **Website:** www.soanes.it

  * **Contact Email:** [ info@soanes.it]

  * **Data Protection Lead Contact:** [David Soanes, info@soanes.it]

 

**1. What Personal Data We Collect**

 

We may collect and process various types of personal data, including:

 

  * **Identity Data:** Name, title, company name.

  * **Contact Data:** Email address, postal address, telephone numbers.

  * **Technical Data:** Internet Protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.

  * **Usage Data:** Information about how you use our website, products, and services.

  * **Marketing and Communications Data:** Your preferences in receiving marketing from us and your communication preferences.

  * **Service Data:** Information provided when you engage with our IT services, which may include data related to your systems, networks, and IT infrastructure. This could include configuration details, error logs, and performance data, but we always aim to process only necessary data and will inform you if sensitive personal data is required for a specific service.

 

**2. How We Collect Your Personal Data**

 

We collect data through various methods:

 

  * **Direct Interactions:** You may give us your Identity, Contact, and Marketing and Communications Data by filling in forms on our website, corresponding with us by post, phone, email, or otherwise. This includes personal data you provide when you:

      * Enquire about our products or services.

      * Request marketing materials.

      * Provide feedback or contact us.

      * Sign up for a newsletter or event.

  * **Automated Technologies or Interactions:** As you interact with our website, we may automatically collect Technical and Usage Data using cookies, server logs, and other similar technologies. Please see our [Link to your Cookie Policy] for more details.

  * **Third Parties or Publicly Available Sources:** We may receive personal data about you from various third parties and public sources, such as:

      * Technical Data from analytics providers (e.g., Google Analytics).

      * Contact, Financial, and Transaction Data from providers of technical, payment, and delivery services.

      * Identity and Contact Data from publicly available sources (e.g., Companies House, LinkedIn).

 

**3. How and Why We Use Your Personal Data (Lawful Bases)**

 

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances and for the following purposes:

 

| Purpose/Activity | Type of Data | Lawful Basis for Processing (UK GDPR) |

| :---------------- | :----------- | :----------------------------------- |

| **To provide our services and manage our relationship with you:** \<br\> - Processing your service requests \<br\> - Managing our contract with you \<br\> - Informing you about changes to our services | Identity, Contact, Service | Performance of a contract with you |

| **To administer and protect our business and this website:** \<br\> - Troubleshooting, data analysis, testing, system maintenance \<br\> - Supporting our IT infrastructure and cybersecurity | Technical | Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, preventing fraud) \<br\> Necessary to comply with a legal obligation |

| **To deliver relevant website content and advertisements to you:** \<br\> - Measuring and understanding the effectiveness of our advertising | Technical, Usage, Marketing and Communications | Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business, and to inform our marketing strategy) |

| **To make suggestions and recommendations to you about services that may be of interest to you:** \<br\> - Sending marketing communications | Identity, Contact, Usage, Marketing and Communications | Necessary for our legitimate interests (to develop our products/services and grow our business) \<br\> With your consent (for direct marketing where required) |

| **To improve our website, products/services, marketing, customer relationships, and experiences:** \<br\> - Using analytics to understand website traffic \<br\> - Improving user experience | Technical, Usage | Necessary for our legitimate interests (to define types of customers for our products/services, to keep our website updated and relevant, to develop our business) |

| **To comply with legal and regulatory obligations:** \<br\> - Maintaining records for tax or auditing purposes \<br\> - Responding to lawful requests from public authorities | Identity, Contact, Service | Necessary to comply with a legal obligation |

 

**Legitimate Interests:** Where we rely on legitimate interests, we ensure that we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

 

**Marketing:** We will only send you direct marketing communications if we have your consent or a legitimate interest to do so. You can opt out of receiving marketing messages from us at any time by following the opt-out links on any marketing message sent to you or by contacting us directly.

 

**4. Who We Share Your Personal Data With**

 

We may share your personal data with the following categories of recipients:

 

  * **Internal Third Parties:** Other companies within our group who provide IT and system administration services and undertake reporting.

  * **External Third Parties:**

      * **Service providers acting as processors** who provide IT, system administration, backup (e.g., CloudAlly, OpenText, Veeam), and other services (e.g., website hosting, email providers, payment processors, CRM software).

      * **Professional advisors** including lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance, and accounting services.

      * **HM Revenue & Customs, regulators, and other authorities** who require reporting of processing activities in certain circumstances.

      * **Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets.** Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

      * **Specifically for our IT Solutions:** When we provide IT backup and recovery services using CloudAlly, OpenText, and Veeam, your data will be processed by these third-party platforms. They operate under their own robust security and privacy policies, and we configure their services to protect your data in line with our obligations to you. We encourage you to review their respective privacy policies for details on how they handle data.

          * CloudAlly: Site privacy | OpenText

          * OpenText: Site privacy | OpenText

          * Veeam: Privacy Policy | Veeam Backup & Replication Best Practice Guide

 

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

 

**5. International Transfers**

 

We may transfer, store, and process your personal data outside the UK and European Economic Area (EEA).

 

Whenever we transfer your personal data out of the UK/EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

 

  * We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the UK government (e.g., countries with an "adequacy decision").

  * Where we use certain service providers, we may use specific contracts approved by the UK ICO (e.g., International Data Transfer Agreement (IDTA) or International Data Transfer Addendum to the EU Standard Contractual Clauses), which give personal data the same protection it has in the UK/EEA.

  * Where we use providers based in the US, we may transfer data to them if they are part of a framework that provides adequate safeguards (e.g., the EU-US Data Privacy Framework, if applicable and recognised by the UK).

 

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK/EEA.

 

**6. Data Security**

 

We have implemented appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

 

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

 

**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, accounting, or reporting requirements.

 

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

 

For example, by law, we have to keep basic information about our customers (including Contact, Identity, Financial, and Transaction Data) for six years after they cease being customers for tax purposes.

 

In some circumstances, you can ask us to delete your data: see "Your Legal Rights" below for further information.

 

**8. Your Legal Rights**

 

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:

 

  * **Request access** to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

  * **Request correction** of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

  * **Request erasure** of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us to continue to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully, or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

  * **Object to processing** of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

  * **Request restriction of processing** of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

  * **Request the transfer** of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

  * **Withdraw consent at any time** where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

 

If you wish to exercise any of the rights set out above, please contact our Data Protection Lead at [Data Protection Lead Email Address, e.g., privacy@soanes.it].

 

**No Fee Usually Required:** You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

 

**What We May Need From You:** We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

 

**Time Limit to Respond:** We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

 

**9. How to Complain**

 

If you have any concerns about our use of your personal information, you can make a complaint to us at [Data Protection Lead Email Address, e.g., privacy@soanes.it].

 

You also have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues. Their website is www.ico.org.uk.

 

**10. Changes to This Privacy Policy**

 

We keep our privacy policy under regular review. This version was last updated on the date stated at the top of this policy. Historic versions can be obtained by contacting us.

 

We encourage you to review this Privacy Policy periodically to be informed about how we are protecting your information.

 

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