This Privacy Policy clarifies the type, scope and purpose of the processing of personal data (hereinafter referred to as "data" ) we collect, use and process as a part of our online offer and the websites and applications functions and contents connected with it as well as external online presences, such as our Social Media Profile (hereinafter referred to as "services" ). This Privacy Policy applies to our entire services, websites and applications including our SheetGeek App on IOS and Android.

Who we are

We are AM 18 Limited(“we”, “our”, “us”) of C/O Clever Accounts Brookfield Court Selby Road, Garforth, Leeds, England, LS25 1NB. We operate to the highest standards when protecting your personal data and respecting your privacy. If you have any questions about your personal data, or how we use it, you can contact us via our contact forms or email at [email protected] We are the data “controller”, which means we are responsible for deciding how and why your personal data is used. We’re also responsible for making sure it is kept safe, secure and handled legally.

The Regulation

Our Headquarters being in the UK, the UK`s Data Protection Act 2018 applies to our services. If you live in the European Economic Area or are a EU Citizen, Regulation (EU) 2016/679 (General Data Protection Regulation) is the European Regulation.

The Supervisory Authority

The Information Commissioner’s Office (ICO) in the UK is the for us relevant authority in matters of data protection. You have the right to make a complaint at any time to the ICO (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Accuracy

It is important that the data we hold about you is accurate and current, therefore please keep us informed of any changes to your personal data.

What data do we collect and process?

Automated decision-making and profiling

As a responsible company we do not use automation for decision-making and profiling.

What are the categories of data subjects?

Customers, interested parties, visitors and users of the online offer, business partners. Visitors and users of the online offer. In the following, we refer to the data subjects collectively as "users".

What are the purposes for processing?

What are the relevant legal bases for processing your data?

The following informs you about the legal basis of us processing your data and unless the legal basis is not specifically mentioned, the following applies:
Consent – This is where we have asked you to provide explicit permission to process your data for a particular purpose.
Contract – This is where we process your information to fulfil a contractual arrangement we have made with you.
Answering your business enquiries – This is where we process your information to reply to your messages, e-mails, calls, etc.
Legitimate Interests - This is where we rely on our interests as a reason for processing, generally this is to provide you with the best products and service in the most secure and appropriate way. Of course, before relying on any of those legitimate interests we balance them against your interests and make sure they are compelling enough and will not cause any unwarranted harm.
Legal Obligation – This is where we have a statutory or other legal obligation to process the information, such as for the investigation of crime.
Vital interests – This is where we process your information for communications about security, privacy and performance improvements of our services. Or for establishing, exercising or defending our legal rights.

When do we disclose your Personal Data?

We may share your information with organisations that help us provide the services described in this policy and who may process such data on our behalf and in accordance with this policy, to support this website and our services. This will only be done on the basis of a legal authorisation (e.g. if a transfer of the data to third parties, such as payment service providers, in accordance with the above stated regulations).

Also, if you have consented to it, or where there we have a legal obligation to do so or on the basis of our legitimate interests (e.g. when using agents, hosting providers, tax, business and legal advisors, customer care, accounting, billing and similar services that allow us to perform our contractual obligations, administrative tasks and duties efficiently and effectively).

You can choose to send forms and datasets in our application to third party's and other individuals with whom you, directly or indirectly, shared a link to your shared forms and datasets through the Services. Your forms and datasets are at no time a accessible to us.

f we commission third parties to process data on the basis of a so-called "contract processing agreement", this is done on the basis of the above stated regulations.

In relation to information obtained about you from your use of our website, we may share a cookie identifier and IP data with analytic and advertising network services providers to assist us in the improvement and optimisation of our website which is subject to our Cookies Policy.

We may also disclose information in other circumstances such as when you agree to it or if the law, a Court order, a legal obligation or regulatory authority ask us to. If the purpose is the prevention of fraud or crime or if it is necessary to protect and defend our right, property or personal safety of our staff, the website and its users.

International transfers

Our main operations are based in the UK and your personal data is generally processed, stored and used within the UK and other countries in or outside the European Economic Area (EEA). In some instances, your personal data may be processed outside the European Economic Area. If and when this is the case we take steps to ensure there is an appropriate level of security so your personal data is protected in the same way as if it was being used within the EEA.

Where we need to transfer your data outside the UK or the EEA we will use one of the following safeguards as set out in the GDPR:
·The use of European Commission approved standard contractual clauses in contracts for the transfer of personal data to third countries.
·Transfers to a non-EEA country with privacy laws that give the same protection as the EEA

Data retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, the data processed by us will be deleted or restricted in their processing in accordance with the above stated regulations. If the data is not deleted because they are required for other and legally permissible purposes, their processing is restricted. This means that the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons.

How do we protect your Personal Data?

We protect your data using state of the art technical, and physical safeguards and operate a firm system of policies, confidentiality agreements, digital safeguards and procedures to ensure the highest level of administrative protection.

In more detail to access our database the user must be authorised, is challenged through a two-way authentication system and use an encrypted VPN. Also, the removal of Personal Data from our location is forbidden and made by using a complex encryption system very difficult. We use cutting edge antivirus and anti-malware software and up-to-date firewall protection. Moreover, authorised personnel must have a legitimate need to know interest such as being your point of contact or service your user account.

he data we collect from you may be stored, with appropriate technical and organisational security measures applied to it, on our servers in the UK. In all cases, we follow generally high data protection standards and advanced security measures to protect the personal data submitted to us, both during transmission and once we receive it.

Economic Analyses

In order to run our business economically, to identify market trends, customer and user wishes, we analyse the data available to us on business transactions, contracts, enquiries, etc. In doing so, we process inventory data, communication data, contract data, payment data, usage data, metadata on the basis of the above stated regulations, whereby the persons concerned include customers, interested parties, business partners, visitors and users of the online offer. The analyses are carried out for the purposes of business management evaluations, marketing and market research.

In doing so, we may take into account the profiles of registered users with details, for example, of their purchasing transactions. The analyses serve us to increase user-friendliness, to optimise our offer and business efficiency and are not disclosed externally, unless they are anonymous analyses with summarised values.

If these analyses or profiles are personal, they will be deleted or made anonymous upon termination by the user, otherwise after two years from conclusion of the contract. In all other respects, the macroeconomic analyses and general trend determinations are prepared anonymously wherever possible.

Do Not Track

Do Not Track is a privacy preference you can set in most browsers. We support Do Not Track because we believe that you should have genuine control over how your info gets used and our site responds to Do Not Track requests.

Do Not Sell My Personal Information

We do not sell information that directly identifies you, like your name, address, banking information, or phone records. In fact, we do not even share that type of information except with service providers who can use the information solely to provide a service on our behalf, when a consumer directs us to share the information.

Communication by mail, e-mail, or telephone

We use means of distance communication, such as post, telephone or e-mail, for business and marketing purposes. We process inventory data, address and contact data as well as contract data of customers, participants, interested parties and communication partners.

The processing is based on the above mentioned regulations and in connection with legal requirements for advertising communications. Contact shall only be established with the consent of the contact partners or within the scope of the statutory permissions and the processed data shall be deleted as soon as they are not required and otherwise with objection/ revocation or discontinuation of the basis for authorisation or statutory archiving obligations.

Online presences in social media

We maintain online presences on the basis of our legitimate interests. We maintain online presences within social networks and platforms in order to communicate with customers, interested parties and users who are active there. Unless otherwise stated in this policy, we process the data of users if they communicate with us within the social networks and platforms, e.g. write articles on our online presences or send us messages.

Hosting and Content Delivery Networks (CDN)

This website and application is hosted by an external service provider (Cloudflare INC, 101 Townsend Street San Francisco, CA 94107 United States (www.cloudflare.com)). The personal data collected using our service is stored on the Cloudflare's servers. This may include, but is not Limited to, IP addresses, contact requests, meta and communication data, contractual data, contact details, names, website accesses and other data generated via a website.

Cloudflare is used for the purpose of fulfilling contracts with our potential and existing customers and in the interest of a secure, fast and efficient provision of our online offer by a professional provider.

Cloudflare will only process your data insofar as this is necessary for the fulfilment of its service obligations and will follow our instructions with regard to this data.

Contact form

All your personal data and other information that you provide to us via the contact form set up on our website will only be collected and processed for the purpose of processing and responding to your enquiries. Your data will be forwarded to us by e-mail via our provider. If they are not provided, it is unfortunately not possible for us to contact you and process your request. An automated decision-making process will not be carried out.

Customer login and User registration

All your personal data and other information that you provide to us via the customer login area will only be collected and processed for the purpose of processing and answering your enquiries. Your data will be forwarded to us by e-mail via our provider. If they are not provided, it is unfortunately not possible for us to provide you with the customer login area, to contact you and to process your request. An automated decision-making process is not carried out.

Personal Data Statement

Commercial Partners: Individual(s) or companies that have been approved by us as a recipient of organizational Personal Data and from which AM 18 Limited has received confirmation of their data protection practices conformance with the requirements of this policy. Commercial Partners include all external providers of services to AM 18 Limited and include proposed Commercial Partners. No Personal Data can be transmitted to any vendor in any method unless the vendor has been pre-certified for the receipt of such information.

Personal Data Training: All new hires entering AM 18 Limited who may have access to Personal Data are provided with introductory training regarding the provisions of this policy, a copy of this policy and implementing procedures for the department to which they are assigned. Employees in positions with regular ongoing access to Personal Data or those transferred into such positions are provided with training reinforcing this policy and procedures for the maintenance of Personal Data and shall receive annual training regarding the security and protection of Personal Data and company proprietary data

Personal Data Audit(s): AM 18 Limited conducts audits of Personal Data maintained by AM 18 Limited in conjunction with fiscal year closing activities to ensure that this policy remains strictly enforced and to ascertain the necessity for the continued retention of Personal Data. Where the need no longer exists, Personal Data will be destroyed in accordance with protocols for destruction of such records and logs maintained for the dates of destruction.

Data Breaches/Notification: Databases or data sets that include Personal Data may be breached inadvertently or through wrongful intrusion. Upon becoming aware of a data breach, AM 18 Limited will notify all affected individuals whose Personal Data may have been compromised, and the notice will be accompanied by a description of action being taken to reconcile any damage as a result of the data breach. Notices will be provided as expeditiously as possible and in line with the above mentioned regulations.

Confirmation of Confidentiality: All company employees must maintain the confidentiality of Personal Data as well as company proprietary data to which they may have access and understand that that such Personal Data is to be restricted to only those with a business need to know. Employees with ongoing access to such data will sign acknowledgement reminders annually attesting to their understanding of this company requirement.

Violations of Personal Data Policies and Procedures: AM 18 Limited views the protection of Personal Data to be of the utmost importance. Infractions of this policy or its procedures will result in disciplinary actions under AM 18 Limited’s discipline policy and may include suspension or termination in the case of severe or repeat violations. Personal Data violations and disciplinary actions are incorporated in AM 18 Limited’s Personal Data on boarding and refresher training to reinforce AM 18 Limited’s continuing commitment to ensuring that this data is protected by the highest standards.

Direct marketing

From time to time we may use the personal information we collect from you to identify particular products offers which we believe may be of interest to you. We may contact you to let you know about these products and services and how they may benefit you.

You may give us your consent in a number of ways including by selecting a box on a form where we seek your permission to send you marketing information, or sometimes your consent is implied from your interactions or relationship with us. Where your consent is implied, it is on the basis that you would have a reasonable expectation of receiving a marketing communication based on your interactions or relationship with us.

Direct Marketing from generally takes the form of e-mail but may also include other less traditional or emerging channels. These forms of contact will be managed by AM 18 Limited, or by our contracted service providers. Every directly addressed marketing form sent or made by us or on our behalf should include a means by which customers may unsubscribe (or opt out) of receiving similar marketing in the future. You can ask us to remove or amend any previous consent you provided by contacting us.

Your Rights

You have a number of ‘Data Subject Rights’ below is some information on what they are and how you can exercise them. There is more information on the ICO website.
information about the processing of your personal data.
obtain access to the personal data held about you.
ask for incorrect, inaccurate or incomplete personal data to be corrected.
request that personal data be erased when it’s no longer needed or if processing it is unlawful.
object to the processing of your personal data for marketing purposes or on grounds relating to your particular situation.
request the restriction of the processing of your personal data in specific cases.
receive your personal data in a machine-readable format and send it to another controller (‘data portability’).
request that decisions based on automated processing concerning you or significantly affecting you and based on your personal data are made by natural persons, not only by computers.
You also have the right in this case to express your point of view and to contest the decision.
Where the processing of your personal data is based on consent, you have the right to withdraw that consent without detriment at any time through our contact form.

The above rights may be Limited in some circumstances, for example, if fulfilling your request would reveal personal data about another person, if you ask us to delete information which we are required to have by law, or if we have compelling legitimate interests to keep it. We will let you know if that is the case and will then only use your information for these purposes. You may also be unable to continue using our services if you want us to stop processing your personal data.

We encourage you to get in touch if you have any concerns with how we collect or use your personal data. You do however also have the right to lodge a complaint directly with the ICO, their contact details can be found on their website.

Changes

This Privacy Policy and our commitment to protecting the privacy of your personal data can result in changes to this Privacy Policy. Please regularly review this Privacy Policy to keep up to date with any changes.

Deletion of account

Should you wish to delete your contact your account please contact us via email at [email protected]

Queries and Complaints

Any comments or queries on this policy should be directed to us using the following contact details: [email protected] or +44 (0)1296 532618.