Privacy notice
Draft for legal review. Not yet in force. Bracketed text marks decisions still to make.
This notice explains how [ROCC legal entity name] ("ROCC", "we") uses personal data when we decide why and how it's used. That covers:
- people with an account in the ROCC Tracker admin;
- billing contacts;
- people who contact us;
- visitors to our website and documentation.
If you're a customer, resident or operative of an organisation that uses Tracker, that organisation decides how your data is used, and we process it for them. See their visit tracking notice or operative notice, or contact them directly.
We're registered with the Information Commissioner's Office (registration [ICO registration number]). Contact us about privacy at [privacy@ROCC domain], or by post at [registered office address].
What we collect and why
| Data | Why | Lawful basis |
|---|---|---|
| Your name, work email, password (stored only as a secure hash), organisation and role | To create and run your account and let you sign in | Contract with your organisation; our legitimate interest in providing the service to it |
| If you sign in with Microsoft: your name, email, and Microsoft's identifiers for you and your organisation (from your organisation's Microsoft account, not your password) | To recognise you when you sign in with Microsoft | Contract with your organisation; our legitimate interest in providing the service to it |
| Sign-in records: when you signed in, your browser, failed attempts | To keep accounts secure and stop misuse | Legitimate interests (security) |
| Billing contact and payment details (card details are held by our payment provider, not us) | To take payment and keep accounts | Contract; legal obligation (tax and accounting records) |
| Emails and support conversations | To answer you | Legitimate interests |
| How organisations use Tracker, such as numbers of visits and messages | To run plans and allowances, plan capacity and improve Tracker | Legitimate interests |
| Website and documentation visits: IP address and browser, processed by our hosting provider | To deliver and protect the site | Legitimate interests |
We send service emails you need, such as confirming your address, resetting a password, invites and billing. We don't send marketing without your consent, and you can opt out at any time.
Who we share it with
- Cloudflare, which hosts Tracker.
- Our email delivery provider.
- Stripe, for payments. Stripe is a controller for some payment data; see its own privacy notice.
- Professional advisers, and authorities where the law requires.
We don't sell personal data.
Some of these providers are outside the UK. Where data leaves the UK, we use a lawful transfer mechanism, such as UK adequacy regulations or the UK International Data Transfer Agreement.
How long we keep it
| Data | Kept |
|---|---|
| Account details | While the account is open, then [12 months] |
| Sign-in sessions | 30 days |
| Billing records | 6 years, for tax |
| Support conversations | [2 years] |
Your rights
You can ask us to:
- give you a copy of your data;
- correct it;
- delete it;
- restrict how we use it;
- move it to another service.
You can also object to us using it for our legitimate interests. Email [privacy@ROCC domain]. We'll respond within one month.
If you're unhappy, you can complain to the Information Commissioner's Office at ico.org.uk or on 0303 123 1113. We'd appreciate the chance to put things right first.
Changes
We'll update this notice when how we use data changes, and show the date at the top.