Our Privacy & Cookies Policy

Our approach to safeguarding the privacy of our customers and their end users

James Stevens avatar
Written by James Stevens
Updated over a week ago

1. Introduction

We are committed to safeguarding the privacy of our website visitors and service users, as well as the privacy of the personnel of our customers, prospective customers and business partners. 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. In some circumstances we will act as a data processor rather than a data controller with respect to such data.

In this policy, "we", "us" and "our" refer to Tenth Chapter Limited trading as Natter. Our service is not intended for children and we do not knowingly collect data relating to children. We keep our this Privacy and Cookies Policy under regular review to make sure it is up to date and accurate.

2. The personal data that we collect

In this Section 2 we have set out the general categories of personal data that we process along with information about the source and specific categories of that data. You provide some of this data directly, and we collect data indirectly about your interactions, use, and experiences with our platform. For example, data that is collected directly includes certain user account data such as your name, email address and profile picture inputted into our platform. Likewise, data that is collected indirectly includes usage data such as your IP address, operating system or geographical location.

The general categories of personal data that we process are:

  • Customer relationship data

  • User account data

  • Platform communications data

  • General communications data

  • Usage data

We may process information relating to our customer and prospective customer relationships ("customer relationship data"). The customer relationship data may include names, names of businesses, job titles and roles, contact details and information contained in or relating to communications between us and customers. The source of the customer relationship data is you and/or our customer.

We may process account data of users ("user account data"). The user account data may include account identifiers, names, email addresses, business names, social media account details, postal addresses, account creation and modification dates, profile pictures, gender information, dates of birth, educational information, employment information, services settings, statistical or demographic data and marketing preferences. The primary source of the user account data is you and/or our customer, although some elements of the user account data may be generated by our services. If you log into our services using a social media account, we will obtain elements of the user account data from the relevant social media account provider. We will not always act as a controller with respect to user account data, and to the extent that do not act as a controller this policy will not apply to that data.

We may process your personal data that are provided in the course of the use of the communications services on our platform and generated by those services in the course of such use ("platform communications data"). The platform communications data may include text chat and video conference data. The source of the platform communications data is you, the person(s) with whom you communicate via the platform and/or our services providers. We will not always act as a controller with respect to platform communications data, and to the extent that do not act as a controller this policy will not apply to that data.

We may process information contained in or relating to support queries and other communications that you send to us or that we send to you that does not fall within any of the other categories detailed above ("general communications data"). The general communication data may include the communication content and metadata associated with the communication. Our services will generate the metadata associated with communications made using the contact forms.

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 usage data is collected by our analytics tracking systems.

We will only collect data where we deem such data to be:

  1. adequate (sufficient to properly fulfil the stated purpose);

  2. relevant (has a rational link to that purpose) and;

  3. limited (only to what is necessary and needed for that purpose).

3. Purposes of processing and legal bases

In this Section 3, we have set out the purposes for which we may process personal data and the legal bases of the processing.

Operations

We may process your personal data for the purposes of operating our website, the processing and fulfilment of orders, providing our services, generating invoices, bills and other payment-related documentation, and credit control. The provision of our services may include the use of machine learning algorithms to automatically match users to enable user interactions. The legal basis for all this processing is our legitimate interests, namely the proper administration of our website, services and business.

Relationships and communications

We may process user account data, customer relationship data and/or general communications data for the purposes of managing our relationships, communicating with you (excluding communicating for the purposes of direct marketing) by email, SMS, post and/or telephone, providing support services and complaint handling. The legal basis for this processing is our legitimate interests, namely communications with our website visitors, service users, customer personnel, prospect personnel and business partner personnel, the maintenance of our business relationships, enabling the use of our services, and the proper administration of our website, services and business.

Personalisation

We may process user account data, platform communications data and/or usage data for the purposes of personalising the content and advertisements that you see on our platform. The legal basis for this processing is our legitimate interests, namely offering the best possible experience to our service users.

Direct marketing - We may process customer relationship data and user account data for the purposes of creating, targeting and sending direct marketing communications by email, SMS, and/or post and making contact by telephone for marketing-related purposes. The legal basis for this processing is consent.

Research and analysis

We may process user account data, platform communications data and/or usage data for the purposes of researching and analysing the use of our services, as well as researching and analysing other interactions with our business. The legal basis for this processing is our legitimate interests, namely monitoring, supporting, improving and securing our website, services and business.

Record keeping

We may process your personal data for the purposes of creating and maintaining our databases, back-up copies of our databases and our business records generally. The legal basis for this processing is our legitimate interests, namely ensuring that we have access to all the information we need to properly and efficiently run our business in accordance with this policy.

Security

We may process your personal data for the purposes of security and the prevention of fraud and other criminal activity. The legal basis of this processing is our legitimate interests, namely the protection of our website, services and business, and the protection of others.

Insurance and risk management

We may process your 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 our legitimate interests, namely the proper protection of our business against risks.

Legal claims

We may process your personal data where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

Legal compliance and vital interests

We may also process your personal data where such processing is necessary for compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person.

4. Providing your personal data to others

If you are a user of our services, you acknowledge that your use will be within the framework of a contract between us and one of our customers, and that we will share elements of your user account data and/or usage data with the relevant customer. In relation to such shared data, our customer will act as an independent controller and the customer's use of that data will be subject to the customer's own privacy policy.

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, obtaining professional advice.

Your personal data may be stored and processed on the servers of our hosting, data processing, machine learning and other services providers identified on our support pages.

In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order 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 in an administrative or out-of-court procedure.

5. International transfers of your personal data

In this Section 5, 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; and 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.

Details of the locations of our hosting facilities, and the facilities of our other services providers, are set out on our website, along with details of the safeguards used to protect international transfers of personal data to and by these services providers.

6. Retaining and deleting personal data

This Section 6 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.

Unless agreed otherwise, we will retain your personal data as follows:

  • Customer relationship data will be retained for a minimum period of 6 years following the date of the final communication between us and the relevant prospect or customer, and for a maximum period of 7 years following that date;

  • User account data and platform communications data will be retained for a minimum period of 6 years following the date of termination of the customer contract under which the relevant account was created, and for a maximum period of 7 years following that date;

  • General communications data will be retained for a minimum period of 6 years following the date of the communication in question, and for a maximum period of 7 years following that date; and

  • Usage data will be retained for 36 months 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 6 in accordance with the applicable licence terms, subject to your data subject rights. If we cease to publish such personal data after the end of the relevant retention period specified in this Section 6, that personal data will be retained for a minimum period of 6 years and a maximum period of 7 years following the date that publication ceases.

Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

7. How we keep your data secure

We process personal data securely by means of appropriate technical and organisational measures. This includes a range of policies and procedures governing our information security and the security of our platform infrastructure. These measures include:

  • Infrastructure measures such as threat detection and vulnerability scanning systems

  • Authentication logs covering failed login attempts and unauthorised access

  • Encryption of data in transit and at rest in our platform databases

  • The centralisation and automation of backups of user data

  • Provision of single sign on services and account revocation procedures

  • Employee and consultant background checks and security training

We are committed to seeking to continuously improve our security posture. We are accredited to the internally recognised information security standard ISO 27001:2013.

8. Our obligations

We are a data controller in relation to the information that you provide us with. As a result, we are legally responsible for how that information is handled.

We will always endeavour to comply with GDPR in both the EU and UK, which governs the way we use and share your personal data. Among other things, this means that we will only use your personal data:

  • fairly and lawfully;

  • as set out in the legislation and this policy; and

  • to the extent necessary for these purposes.

We will process your personal data ourselves as the data processor. We will take reasonable precautions to safeguard the personal information that you supply.

Where we use data processors or share your data with joint controllers, we will ensure appropriate safeguards and contracts, terms, and data sharing agreements are in place including SCCs. If you have any requests concerning your personal information or any queries about our privacy policy, website, or service, please contact us using the contact details provided in this policy.

9. Your rights

In this Section 9, we have listed the rights that you have under data protection law.

Your principal rights under data protection law are:

  • the right to access - you can ask for copies of your personal data;

  • the right to rectification - you can ask us to rectify inaccurate personal data and to complete incomplete personal data;

  • the right to erasure - you can ask us to erase your personal data;

  • the right to restrict processing - you can ask us to restrict the processing of your personal data;

  • the right to object to processing - you can object to the processing of your personal data;

  • the right to data portability - you can ask that we transfer your personal data to another organisation or to you;

  • the right to complain to a supervisory authority - you can complain about our processing of your personal data; and

  • 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.

These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by visiting https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.

You may exercise any of your rights in relation to your personal data by written notice to us, using the contact details set out below.

10. Third party websites

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.

11. Updating information

Please let us know if the personal information that we hold about you needs to be corrected or updated.

12. Acting as a data processor

All users access our services within the framework of a contract between us and our paying customer. The customer will be either:

  • a user's employer or an organisation of which the user is a member (a "corporate customer"); or

  • a business or other organisation providing products and/or services to the user's employer or to the organisation of which the user is a member (a "community customer").

If you are using our services within the framework of a contract between us and a corporate customer, we will act as a data processor on behalf of that corporate customer with respect to your user account data and platform communications data.

If, on the other hand, you are using our services within the framework of a contract between us a community customer, we will act as a data controller with respect to your user account data and platform communications data.

This policy will only apply where we act as a controller; it does not apply where we act as a processor. Our legal obligations as a processor are instead set out in the contract between us and the relevant corporate customer.

13. About cookies

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 is 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.

14. Purposes of cookies

We and our services providers may use cookies for the following purposes:

  • 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;

  • Security; We use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally; and

  • Ecommerce: We use cookies to facilitate payments functionality relating to our services.
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15. Cookies used by our service providers

We use a range of service providers to power our service, where these service providers use cookies to provide services back to us. Below, we have set out a list of service providers who may use cookies in some form as part of providing their service:

  • Agora Inc: Video live streaming and video recording services (here)

  • Amazon Web Services, Inc: Infrastructure hosting and related services (here)

  • Cloudflare, Inc: Content Delivery Network (CDN) services and cyber threat detection (here)

  • Datadog Inc: Application monitoring and debugging services (here)

  • Detectify AB: Application security vulnerability scanning (here)

  • Intercom, Inc: Customer relationship management (here)

  • Sentry (Functional Software, Inc): Application monitoring and debugging services (here)

  • Twilio Inc: E2EE video communication services (here)

  • Uptime Robot Service Provider Ltd: Website uptime and performance monitoring services (here)
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16. About cookies

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:

Blocking all cookies will have a negative impact upon the usability of many websites. If you block cookies, you will not be able to use all the features on our website.

17. Policy update

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.

18. Our contact details

Our legal name is Tenth Chapter Limited We are registered in England and Wales under registration number 12565130, and our registered office is at Aldwych House, 71-91 Aldwych, London, England, WC2B 4HN.

You can contact us:

  • by post, to the postal address given above;

  • using our website contact form; or

  • by email (team@natter.co).

We are registered as a data controller with the UK Information Commissioner's Office. Our data protection registration number is ZA869456. If you remain dissatisfied, you can make a complaint about the way we process your personal information to the supervisory authority.

19. Our EU representative

Under Article 27 of the GDPR, we have appointed an EU Representative to act as our data protection agent. Our nominated EU Representative is:

  • Instant EU GDPR Representative Ltd.

  • Adam Brogden (contact@gdprlocal.com)

  • +35 31554 9700

  • Office 2, 12A Lower Main Street, Lucan Co. Dublin, K78 X5P8, Ireland

Last updated: 13 May 2024.

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