Data Protection Notice
Alignerly and Alignerly.com are trading names of Alignerly Limited. Alignerly Limited is a data controller which means we have a responsibility to decide how and when your data is used and to ensure it is used correctly in all situations. Alignerly Limited is located in 5 Fitzwilliam Square, Dublin 2, Ireland, company number: 668055.
We may store any information that you provide when you fill in assessment forms on our website or when you contact us, plus we may keep details of any transactions that you carry out through our system, details of your visit to our website and the details of resources that you access using our website. All data (personal information) submitted to Alignerly Limited on our website by you is taken to be accurate and correct.
On submitting your personal information to Alignerly Limited you are consenting to us checking the following:
– Our internal databases and records
– Fraud prevention agencies
We will provide you with access to any information we have about you in accordance with the Privacy Act. If you would like to access this information please contact us by writing to us at 5 Fitzwilliam Square, Dublin 2, Ireland or emailing us at firstname.lastname@example.org.
Some information may be required by the local law, legal enforcement procedures or other bodies with relevant powers or jurisdiction. If you do not provide all of the information requested, we may not be able to provide you with our products or services effectively or at all.
We do our best to protect your personal data that you have shared with us. We protect that information in transit using secure socket layer (SSL) encryption technology. Alignerly Limited uses firewalls and the latest encryption technology to ensure our web site is secure and that all customer data is protected and encrypted.
Through our website we may collect information about your computer, including your IP address, browser type and version and operating system information for system administration and to report aggregate information to our advertisers. All this information is purely statistical and does not identify any individual.
We may contact you by phone, fax, post, email and SMS to tell you about our products, services and promotions. We will only do this if you have agreed to it in terms and conditions.
You have a right to opt out of us contacting you for marketing purposes or sharing information about you with other companies for marketing purposes by contacting us at: email@example.com or by sending us a written letter to: 5 Fitzwilliam Square, Dublin 2, Ireland and letting us know your decision.
Our aim is to process data efficiently, only use it where absolutely needed to give you a better experience and service. This could include but is not limited to fraud prevention, money laundering and other criminal activities. We may also use data to help us improve the customer experience you have, statistical analysis or assess credit risks or suitability for third party products.
You can choose to block cookies in your web browser by changing your browser settings. If you choose not to accept cookies this may affect the quality of our visit to Alignerly.
We use personal information for the purpose of carrying out our business activities -providing the products and services you have requested. We may use your information to help make business decisions that enable us to offer a better service. We may also use your information for marketing purposes but only if you have not made a request for us not to do so. We may, if legally compelled to do so, supply your information to authorities should they require it to conduct investigations.
We may pass your details onto 3rd parties for marketing of products and services that we feel may be of interest to you. The following sectors are the industry types you can expect to receive 3rd party products, information, services or special offers from – Automotive, Broadband, Call Centre, Charity, Competition Sites, Debt, Education, EntertainmentGamingLeisure, Fashion, Finance, FMCG, Freebie Sites, Gambling, Gardening, Government, Health & Beauty, Home & Lifestyle, Mobility, Home Improvement, Household, IT/Technical, Insurance (Life, Home, Automotive, General, Private Medical, Travel), Legal Services, Lottery, Mail Order, Market Research, Music, Pension, Pharmaceutical, PPI, Premium Rate, Publishing/Media, Retail, Sport, Telecoms, Toiletries/Cosmetics, Travel, Utilities. We may also supply your data to these sectors via agencies/brokers.
Our website may contain links to third party websites. Please note that if you follow a link to any such website, we do not accept any liability or responsibility, because these websites have their own Terms & Conditions and Privacy Policies.
You can request your information The UK Data Protection Act provides you with the right to access information held about you. Any such request may be charged a fee of £10 to meet our costs in providing you with details of the information we hold about you. If you require such information please contact us as below.
Data Protection Policy
– Context and overview
– Key details
Alignerly needs to gather and use certain information about individuals. These can include customers, suppliers, business contacts, employees and other people the organisation has a relationship with or may need to contact. This policy describes how this personal data must be collected, handled and stored to meet the company’s data protection standards — and to comply with the law.
Why this policy exists
This data protection policy ensures Alignerly:
- Complies with data protection law and follow good practice
- Protects the rights of staff, customers and partners
- Is open about how it stores and processes individuals’ data
- Protects itself from the risks of a data breach
Data protection law
The Data Protection Act 1998 describes how organisations — including Alignerly — must collect, handle and store personal information.
These rules apply regardless of whether data is stored electronically, on paper or on other materials.
To comply with the law, personal information must be collected and used fairly, stored safely and not disclosed unlawfully.
The Data Protection Act is underpinned by eight important principles. These say that personal data must:
- Be processed fairly and lawfully
- Be obtained only for specific, lawful purposes
- Be adequate, relevant and not excessive
- Be accurate and kept up to date
- Not be held for any longer than necessary
- Processed in accordance with the rights of data subjects
- Be protected in appropriate ways
- Not be transferred outside the European Economic Area (EEA), unless that country or territory also ensures an adequate level of protection
People, risks and responsibilities
This policy applies to:
- The head office of Alignerly
- All branches of Alignerly
- All staff and volunteers of Alignerly
- All contractors, suppliers and other people working on behalf of Alignerly
It applies to all data that the company holds relating to identifiable individuals, even if that information technically falls outside of the Data Protection Act 1998. This can include:
- Names of individuals
- Postal addresses
- Email addresses
- Telephone numbers
- …plus any other information relating to individuals
Data protection risks
This policy helps to protect Alignerly from some very real data security risks, including:
- Breaches of confidentiality. For instance, information being given out inappropriately.
- Failing to offer choice. For instance, all individuals should be free to choose how the company uses data relating to them.
- Reputational damage. For instance, the company could suffer if hackers successfully gained access to sensitive data.
Everyone who works for or with Alignerly has some responsibility for ensuring data is collected, stored and handled appropriately. Each team that handles personal data must ensure that it is handled and processed in line with this policy and data protection principles.
However, these people have key areas of responsibility:
- The board of directors is ultimately responsible for ensuring that Alignerly meets its legal obligations.
- The Senior Leadership Team is responsible for:
- Keeping the board updated about data protection responsibilities, risks and issues.
- Reviewing all data protection procedures and related policies, in line with an agreed schedule.
- Arranging data protection training and advice for the people covered by this policy.
- Handling data protection questions from staff and anyone else covered by this policy.
- Dealing with requests from individuals to see the data Alignerly holds about them (also called ‘subject access requests’).
- Checking and approving any contracts or agreements with third parties that may handle the company’s sensitive data.
- The Senior Leadership Team is responsible for:
- Ensuring all systems, services and equipment used for storing data meet acceptable security standards.
- Performing regular checks and scans to ensure security hardware and software is functioning properly.
- Evaluating any third-party services the company is considering using to store or process data. For instance, cloud computing services.
- The marketing team is responsible for:
- Approving any data protection statements attached to communications such as emails and letters.
- Addressing any data protection queries from journalists or media outlets like newspapers.
- Where necessary, working with other staff to ensure marketing initiatives abide by data protection principles.
General staff guidelines
- The only people able to access data covered by this policy should be those who need it for their work.
- Data should not be shared informally. When access to confidential information is required, employees can request it from their line managers.
- Alignerly will provide training to all employees to help them understand their responsibilities when handling data.
- Employees should keep all data secure, by taking sensible precautions and following the guidelines below.
- In particular, strong passwords must be used and they should never be shared.
- Personal data should not be disclosed to unauthorised people, either within the company or externally.
- Data should be regularly reviewed and updated if it is found to be out of date. If no longer required, it should be deleted and disposed of.
- Employees should request help from their line manager or the data protection officer if they are unsure about any aspect of data protection.
These rules describe how and where data should be safely stored. Questions about storing data safely can be directed to the IT manager or data controller. When data is stored on paper, it should be kept in a secure place where unauthorised people cannot see it.
These guidelines also apply to data that is usually stored electronically but has been printed out for some reason:
- When not required, the paper or files should be kept in a locked drawer or filing cabinet.
- Employees should make sure paper and printouts are not left where unauthorised people could see them, like on a printer.
- Data printouts should be shredded and disposed of securely when no longer required
When data is stored electronically, it must be protected from unauthorised access, accidental deletion and malicious hacking attempts:
- Data should be protected by strong passwords that are changed regularly and never shared between employees.
- If data is stored on removable media (like a CD or DVD), these should be kept locked away securely when not being used.
- Data should only be stored on designated drives and servers, and should only be uploaded to an approved cloud computing services.
- Servers containing personal data should be sited in a secure location, away from general office space.
- Data should be backed up frequently. Those backups should be tested regularly, in line with the company’s standard backup procedures.
- Data should never be saved directly to laptops or other mobile devices like tablets or smart phones.
- All servers and computers containing data should be protected by approved security software and a firewall.
Personal data is of no value to Alignerly unless the business can make use of it. However, it is when personal data is accessed and used that it can be at the greatest risk of loss, corruption or theft:
- When working with personal data, employees should ensure the screens of their computers are always locked when left unattended.
- Personal data should not be shared informally. In particular, it should never be sent by email, as this form of communication is not secure.
- Data must be encrypted before being transferred electronically. The IT manager can explain how to send data to authorised external contacts.
- Personal data should never be transferred outside of the European Economic Area.
- Employees should not save copies of personal data to their own computers. Always access and update the central copy of any data.
The law requires Alignerly to take reasonable steps to ensure data is kept accurate and up to date.
The more important it is that the personal data is accurate, the greater the effort Alignerly should put into ensuring its accuracy. It is the responsibility of all employees who work with data to take reasonable steps to ensure it is kept as accurate and up to date as possible.
- Data will be held in as few places as necessary. Staff should not create any unnecessary additional data sets.
- Staff should take every opportunity to ensure data is updated. For instance, by confirming a customer’s details when they call.
- Alignerly will make it easy for data subjects to update the information Alignerly holds about them. For instance, via the company website.
- Data should be updated as inaccuracies are discovered. For instance, if a customer can no longer be reached on their stored telephone number, it should be removed from the database.
- It is the marketing manager’s responsibility to ensure marketing databases are checked against industry suppression files every six months.
Subject access requests
All individuals who are the subject of personal data held by Alignerly are entitled to:
- Ask what information the company holds about them and why.
- Ask how to gain access to it.
- Be informed how to keep it up to date.
- Be informed how the company is meeting its data protection obligations.
If an individual contacts the company requesting this information, this is called a subject access request.
Subject access requests from individuals should be made by email.
The data controller will always verify the identity of anyone making a subject access request before handing over any information.
Disclosing data for other reasons
In certain circumstances, the Data Protection Act allows personal data to be disclosed to law enforcement agencies without the consent of the data subject. Under these circumstances, Alignerly will disclose requested data. However, the data controller will ensure the request is legitimate, seeking assistance from the board and from the company’s legal advisers where necessary.
Alignerly aims to ensure that individuals are aware that their data is being processed, and that they understand:
- How the data is being used
- How to exercise their rights
To these ends, the company has a privacy statement, setting out how data relating to individuals is used by the company.
Alignerly Limited trading as Alignerly