GDPR

The CeeJay Software GDPR policy for our customers, suppliers and partners is displayed below.

Between: 

CeeJay Software Limited 

23 Melville Street 

Edinburgh 

Scotland 

EH3 7PE 

Registered in Scotland under registration number SC390957 and 

Partner Name: 

Company Address: 

Registered In:    

Company Registration Number:    

Your Email Address: 

1. Introduction 

1.1 We are committed to safeguarding the privacy of all individuals and  partners whose personal data we store and process; in this notice we  explain how we will handle your and your customers personal data. 

1.2 This notice applies where we are acting as a data controller with  respect to your personal data; in other words, where we determine the  purposes and means of the processing of that personal data. 

1.3 In this notice, "we", "us" and "our" refer to CeeJay Software Limited

2. How we use your personal data 

2.1 In this section 2 we have set out: 

(a) the general categories of personal data that we may process;(b) in the  case of personal data that we did not obtain directly from you, the source  and specific categories of that data;(c) the purposes for which we may  process personal data; and(d) the legal bases of the processing.

2.2 We may process your partner account data ("account data"). The  account data may include your name, postal address, telephone number  and email address. The source of the account data is you or your employer.  The account data may be processed for the purposes of providing our  services, ensuring the security of our services, maintaining back-ups of our  databases and communicating with you. The legal basis for this processing  is consent OR our legitimate interests, namely the proper administration of  our business OR the performance of a contract between you and us and/or  taking steps, at your request, to enter into such a contract. 

2.3 We may process your personal data that are provided in the course of  the use of our services ("service data"). The service data may include cloud  server usage, storage usage and login activity. The source of the service  data is you or your employer. The service data may be processed for the  purposes of providing our services, ensuring the security of our services,  maintaining back-ups of our databases and communicating with you. The  legal basis for this processing is consent OR our legitimate interests,  namely the proper administration of our business OR the performance of a  contract between you and us and/or taking steps, at your request, to enter  into such a contract. 

2.4 We may process information relating to transactions, including  purchases of goods and services, that you enter into with us ("transaction  data"). The transaction data may include your contact details, your card  details and the transaction details. The transaction data may be processed  for the purpose of supplying the purchased goods and services and  keeping proper records of those transactions. The legal basis for this  processing is the performance of a contract between you and us and/or  taking steps, at your request, to enter into such a contract and our  legitimate interests, namely our interest in the proper administration of our  business. 

2.5 We may process information that you provide to us for the purpose of  subscribing to our email notifications and/or newsletters ("notification  data"). The notification data may be processed for the purposes of sending  you the relevant notifications and/or newsletters. The legal basis for this  processing is consent OR the performance of a contract between you and  us and/or taking steps, at your request, to enter into such a contract. 

2.6 We may process information contained in or relating to any  communication that you send to us ("correspondence data"). The  correspondence data may include the communication content and  metadata associated with the communication. The correspondence data  may be processed for the purposes of communicating with you and record keeping. The legal basis for this processing is our legitimate interests,  namely the proper administration of our business and communications with  users.

2.7 We may process any of your personal data identified in this notice  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. 

2.8 We may process any of your personal data identified in this notice  where necessary for the purposes of obtaining or maintaining insurance  coverage, managing risks, or obtaining professional advice. The legal basis  for this processing is our legitimate interests, namely the proper protection  of our business against risks. 

2.9 In addition to the specific purposes for which we may process your  personal data set out in this section 2, we may also process any of 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. 

2.10 Please do not supply any other person's personal data to us, unless  we prompt you to do so. 

3. Providing your personal data to others 

3.1 We may disclose your personal data to any member of our group of  companies (this means our subsidiaries) insofar as reasonably necessary  for the purposes, and on the legal bases, set out in this notice. 

3.2 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, or the establishment, exercise or defence of legal claims, whether in  court proceedings or in an administrative or out-of-court procedure. 

3.3 Financial transactions relating to services may be handled by our  payment services providers depending on how you pay these are  GoCardless and/or Stripe. We will share transaction data with our payment  services providers only to the extent necessary for the purposes of  processing your payments, refunding such payments and dealing with  complaints and queries relating to such payments and refunds. You can  find information about the payment services providers' privacy policies and  practices at gocardless.com and stripe.com. 

3.5 In addition to the specific disclosures of personal data set out in this  section 3, 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. 

4. International transfers of your personal data 

4.1 In section 4, we provide information about the circumstances in which  your personal data may be transferred to countries outside the European  Economic Area (EEA). 

4.2 We have offices and facilities in Scotland (Head Office), Data Centres in  London, Frankfurt, Amsterdam, Prague, USA and New Zealand. The  European Commission has made an "adequacy decision" with respect to  the data protection laws of each of these countries. Transfers to each of  these countries will be protected by appropriate safeguards, namely the  use of standard data protection clauses adopted or approved by the  European Commission. 

4.3 Data locations of our services 

All data being transmitted is encrypted, all data stored is encrypted by  several layers for all our services only a few members of CeeJay Software in  our head office in Scotland can access the settings and view log files which  shows the status of any backups. Only the end user (customer) can decrypt  their encrypted file-level data. 

Our Website:  

www.ceejay.com and backupintelligence.com and  

protectedintelligence.com 

Is located in the UK and or Europe with all data encrypted at transmission  and at rest, only the team in Scotland has access to the website data. The  website contains the order form for all our services which are Backup  Intelligence and Protected Intelligence. We request your name, company name, postal address, telephone  number, email address, invoice email address, and plan you wish to  purchase, as well as the IP address and date created, which are all stored.  We also use Google Analytics on the website for analytics of it's  performance, visitors, browsers, page views. 

Backup Intelligence - Protected Intelligence: 

Backup Intelligence is CeeJay Software’s own cloud backup solution to  back up servers, endpoints, cloud to cloud, virtual machines, Protected  Intelligence for Office 365 and Google Suite. 

The master server for all accounts is located in Europe which stores your  username and encrypted login information along with all the settings used  in Backup Intelligence or Protected Intelligence.

The storage servers which the end-users select to store their encrypted  backup data are located in one of three locations of the end-users choosing  which are either UK (London), Europe (Amsterdam) or USA (Ashburn), Canada or Australia

5. Retaining and deleting personal data 

5.1 This section 5 sets out our data retention policies and procedure, which  are designed to help ensure that we comply with our legal obligations in  relation to the retention and deletion of personal data. 

5.2 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. 

5.3 We will retain your personal data as follows: 

(a) Invoicing Details are sent to our partners are retained for a minimum  period of 7 years following creation date to allow for financial inspections in  the UK. 

5.4 In some cases it is not possible for us to specify in advance the periods  for which your personal data will be retained. In such cases, we will  determine the period of retention based on the following criteria: 

(a) the period of retention of backup data will be determined based on the  specific storage period set upon by the user / administrator or partner in the  backup solutions.(b) If you delete or close your backup account or remove  a device from the backup plan all data is automatically purged after 48  hours and is non-recoverable.(c) If you unselect a file, files, folders or drive  or path from your backup selection then the backup for that item will be  purged from the backup archive at our cloud using the retention settings  you have chosen in either Backup Intelligence, Sync Intelligence or in  CrashPlan. 

5.5 Notwithstanding the other provisions of this section 5, 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. 

6. Security of personal data 

6.1 We will take appropriate technical and organisational precautions to  secure your personal data and to prevent the loss, misuse or alteration of  your personal data. 

6.2 All data we hold is stored and transmitted by us using several layers of  encryption. 

6.3 All our passwords used to access our software and IT systems are not 

susceptible to being guessed, administrator passwords are between 40 and  8000 characters long and with Backup Intelligence, Sync Intelligence,  Intercom we also use 2 factor authentication on all administration accounts. 

6.4 Customers and our partners are responsible for keeping the passwords  confidential and we will not ask you for your passwords (except when you  log in to our solutions). Backup Intelligence will have a new web based  console later in May 2018 for end users and partners with that we will  require ultra strong passwords and will use 2 factor authentication. 

6.5 In Backup Intelligence it is impossible for you or us to request a  password reset unless you have chosen that option to allow a password  reset through the account settings in the desktop client. 

6.6 All CrashPlan password resets go back to the user’s email address. 

6.6 All our systems for administration access by us use Apple macOS or  iOS devices running on our secure internal network. We do not use public  wifi networks. For example, if our CEO were away from the office checking  email, a dedicated 4G or secure satellite network is used. All our devices  are encrypted and do not show notifications when locked and are tracked  globally by our email platform run out of our data centre in Europe. All our  devices can be remotely wiped if necessary. 

6.7 We use a few other solutions to help us and through these systems  some information is stored: 

KashFlow is our accounts system which stores the invoicing details of our  partners, which is located in London U.K. (Rackspace Data Centre) and  stores customer order details. This information is retained for 7 years for  our financial checks. 

Details Stored in KashFlow: Your Name, Company Name, Postal Address,  Telephone Number, Solution Ordered, Pricing, Invoice Date, Payment  Method, Payment Date, Account Notes. There is no bank account  information stored i.e. account number, credit or debit card in KashFlow. 

GoCardless is our Direct Debit payment processor. This is stored in the UK  and only used when partners set up to pay in the UK by Direct Debit. 

Details Stored in GoCardless are: Your Name, Address, Email Address and  Financial Details (such as account holder name, account number, sort  code) of the GoCardless end-customer (i.e. the purchaser of services/ goods from a merchant using GoCardless to collect payments). 

Stripe is our credit or debit card payment processor, which is only used  when partners pay by debit or credit card. EU-U.S. and Swiss-U.S. Privacy  Shield Framework: https://stripe.com/privacy-shield-policy

Intercom which is used when partners place a support ticket. Intercom  uses Amazon AWS and is located in USA: https://www.intercom.com/ security 

SoPro is our marketing provider for details visit sopro.io 

Zoom is used when we do webinars. Their data centre is located in USA  with all data encrypted end-to-end and destroyed at the end of the  webinars. For recordings we will download them and make them available  through our website. EU-U.S. and Swiss-U.S. Privacy Shield Framework 

CCTV Our premises are protected inside and outside with Netatmo CCTV  Cameras which record video and audio and process face recognition, car  recognition and animal recognition, all data is encrypted and stored in our  London data centre. 

Bank Details if partners pay directly into our bank account then the  payment details are held by the Royal Bank of Scotland (RBS) 

7. Amendments 

7.1 We we publish changes to this notice on our website at  www.ceejay.com 

8. Your rights 

8.1 In this section 8, we have summarised the rights that you have under  data protection law. Some of the rights are complex, and not all of the  details have been included in our summaries. Accordingly, you should read  the relevant laws and guidance from the regulatory authorities for a full  explanation of these rights. 

8.2 Your principal rights under data protection law are: 

(a) the right to access;(b) the right to rectification;(c) the right to erasure;(d)  the right to restrict processing;(e) the right to object to processing;(f) the  right to data portability;(g) the right to complain to a supervisory authority;  and(h) the right to withdraw consent. 

8.3 You have the right to confirmation as to whether or not we process your  personal data and, where we do, access to the personal data, together with  certain additional information. That additional information includes details of  the purposes of the processing, the categories of personal data concerned  

and the recipients of the personal data. Providing the rights and freedoms  of others are not affected, we will supply to you a copy of your personal  data. The first copy will be provided free of charge, but additional copies  may be subject to a reasonable fee. 

You can request access to your personal data by visiting us at https://help.ceejay.com and putting in a request to view your data. 

8.4 You have the right to have any inaccurate personal data about you  rectified and, taking into account the purposes of the processing, to have  any incomplete personal data about you completed. 

8.5 In some circumstances you have the right to the erasure of your  personal data without undue delay. Those circumstances include: the  personal data are no longer necessary in relation to the purposes for which  they were collected or otherwise processed; you withdraw consent to  consent-based processing; you object to the processing under certain rules  of applicable data protection law; the processing is for direct marketing  purposes; and the personal data have been unlawfully processed. However,  there are exclusions of the right to erasure. The general exclusions include  where processing is necessary: for exercising the right of freedom of  expression and information; for compliance with a legal obligation; or for  the establishment, exercise or defence of legal claims. 

8.6 In some circumstances you have the right to restrict the processing of  your personal data. Those circumstances are: you contest the accuracy of  the personal data; processing is unlawful but you oppose erasure; we no  longer need the personal data for the purposes of our processing, but you  require personal data for the establishment, exercise or defence of legal  claims; and you have objected to processing, pending the verification of  that objection. Where processing has been restricted on this basis, we may  continue to store your personal data. However, we will only otherwise  process it: with your consent; for the establishment, exercise or defence of  legal claims; for the protection of the rights of another natural or legal  person; or for reasons of important public interest. 

8.7 You have the right to object to our processing of your personal data on  grounds relating to your particular situation, but only to the extent that the  legal basis for the processing is that the processing is necessary for: the  performance of a task carried out in the public interest or in the exercise of  any official authority vested in us; or the purposes of the legitimate interests  pursued by us or by a third party. If you make such an objection, we will  cease to process the personal information unless we can demonstrate  compelling legitimate grounds for the processing which override your  interests, rights and freedoms, or the processing is for the establishment,  exercise or defence of legal claims. 

8.8 You have the right to object to our processing of your personal data for  direct marketing purposes (including profiling for direct marketing  purposes). If you make such an objection, we will cease to process your  personal data for this purpose. 

8.9 You have the right to object to our processing of your personal data for  scientific or historical research purposes or statistical purposes on grounds 

relating to your particular situation, unless the processing is necessary for  the performance of a task carried out for reasons of public interest. 

8.10 To the extent that the legal basis for our processing of your personal  data is: 

(a) consent; or(b) that the processing is necessary for the performance of a  contract to which you are party or in order to take steps at your request  prior to entering into a contract, and such processing is carried out by  automated means, you have the right to receive your personal data from us  in a structured, commonly used and machine-readable format. However,  this right does not apply where it would adversely affect the rights and  freedoms of others. 

8.11 If you consider that our processing of your personal information  infringes data protection laws, you have a legal right to lodge a complaint  with a supervisory authority responsible for data protection. You may do so  in the EU member state of your habitual residence, your place of work or  the place of the alleged infringement. 

8.12 To the extent that the legal basis for our processing of your personal  information is consent, you have the right to withdraw that consent at any  time. Withdrawal will not affect the lawfulness of processing before the  withdrawal. 

8.13 You may exercise any of your rights in relation to your personal data  by written notice to us OR by email correspondence OR by telephone  correspondence, in addition to the other methods specified in this section  8. 

9. Our details 

9.1 Our full legal name is CeeJay Software Limited 

9.2 We are registered in Scotland under registration number SC390957,  and our registered office is at 

CeeJay Software Limited 

23 Melville Street 

Edinburgh 

Scotland 

EH3 7PE 

VAT Registration Number GB 116 1130 

9.3 Our principal place of business is at CeeJay Software Limited, at the  above address. 

9.4 You can contact us: 

(a) by post, to the postal address given above;(b) using our website at 

https://ceejay.com;(c)  

10. Representative within the European Union 

10.1 Our representative within the European Union with respect to our  obligations under data protection law is our CEO and you can contact our  representative through the above contact information. 

11. Data protection officer 

11.1 Our data protection officer's is our CEO, Mr Craig Laird Jamieson. 

CeeJay Software Limited 

23 Melville Street 

Edinburgh 

Scotland 

EH3 7PE 

Your legal name 

Signed by Craig Jamieson 

Signed On: 21st January 2020