Privacy

1. About Us

Sort Limited (referred to in this document as "SortRefer", "we" or "us") is a company registered in England and Wales, with registered number 06885158 and registered office at Burdsall House, The Derby Conference Centre, London Road, Alvaston, Derby, DE24 8UX. Our website is at www.sortrefer.co.uk. Our contact e-mail address is: enquires@sortrefer.co.uk.

2. About This Policy

2.1 What it covers

This privacy policy sets out our policy in relation to information which we acquire about:-

2.1.1 our visitors to and users of our website;

2.1.2 our customers (and employees and representatives of our customers), including persons who take up our service enabling them to be a member of our panel of providers wishing to receive instructions and to list their products and services on our website, and persons who register with us as main introducers, staff one introducers, staff introducers or otherwise for services enabling them to make and manage instructions to our panel of providers; and

2.1.3 clients in respect of whom referrals are made.

2.2 Anonymous Access

Note that without providing any personal information, you can access and browse our homepage.

2.3 Third party sites

Our privacy policy does not cover any information you supply to third parties, and if you visit any third party websites through links that may appear on our website, you should read their own privacy policy with respect to any data you supply to them.

Our website currently uses the following services:

YouTube API Services – (http://www.google.com/policies/privacy) to host and display marketing and informational videos and content via our public YouTube channel.

We do not store or process user data from the YouTube API services in the provision of our services; we will not seek to share or make this information available to any other third party.

3. Our Confidentiality And Data Protection Commitment

SortRefer is committed to ensuring that your privacy is protected and when we ask you to provide information, you can be assured that it will only be used in accordance with this privacy policy. We maintain confidential your information, unless your information is supplied for the purpose of being viewed by others, and only use it and share it as detailed in this privacy policy and any agreement between you and us from time to time. We comply with the EU General Data Protection Regulation (2016/679), the Data Protection Act 1998 and the Privacy and Electronic Communications (EC Directive) Regulations 2003 in relation to your information.

4. Changes To This Policy

SortRefer may change this policy from time to time by publishing a new version on our website. You should check our website from time to time for updates to our privacy policy. We may also notify you of significant changes by email or via our website. By continuing to use our website and services after any such change you will be considered to have accepted the change.

5. What Information We Process

We may process the following personal information about you:-

5.1 Business representatives\' general information

If you are a contact, staff one introducer, staff introducer, or other individual or representative associated with any business that is a customer of ours, information about your contact details (such as address, telephone, mobile, fax, and e-mail), your job title and relationship with respect to the business (owner, partner, director, shareholder, employee, agent etc.), your employer (if not the business), your qualifications and skills, your authorities and permissions, demographic information (including preferences and interests), security questions and answers, and the business you are associated with.

5.2 Products and Services Information

If you are advertising products and services through our website or using our services, details of those products and services. In relation to instructions made through our website and services, client information, quotation and instruction information, referral status information (including status of the underlying proposed transaction), and fee information relating to referral fees received and paid.

5.3 Client information

If you are a client who has been the subject of a quotation or instruction through our website and services, such information as we are provided by our introducer who created the quotation or made the instruction, or by our panel of suppliers who receive any instruction, including your name and address, and your personal data relevant to the quotation or instruction. Please note that we receive such information in the capacity of data processor rather than data controller – see section 11 (SortRefer As A Data Processor) for further details.

5.4 Correspondence Information

All other information and correspondence between you and us, including relevant to activities you undertake on or through our website or using our services.

5.5 Surveys and Offers

Your responses to surveys and offers.

5.6 Other

Any information you may volunteer to us from time to time or which you may place on our website from time to time.

5.7 Third Party Information

Information from other sources, such as individuals, public records and regulatory and private organisations, including that which we need in order to verify you and your identity, and your credit status.

5.8 Technical Information

Technical information when you visit our website, including your web browser information including your browser make (e.g. Internet Explorer, Firefox, Safari, Opera, Chrome), your operating system (e.g. Microsoft Windows, OSX, Android), your IP address (a unique identifier allocated to your computer for your connection to the internet), and information in relation to your use of our website.

6. How We Collect/Generate That Information

On registration you will be asked to provide some or all of the above information. In addition, we may collect your information through a variety of means, including from forms you fill in or information you provide through our website, information your web browser and computer provide when accessing our website, information you provide directly to us, information supplied by other customers or users of our website and services and information we generate ourselves in operating our website and providing our services.

7. What We Do With Your Information

Data protection laws require that, where we process your personal data, we must have at least one of certain stipulated reasons for processing, which include the following:

• it is necessary to fulfil a contract we have with you or in order to take steps at your request prior to entering into a contract (“Contract”);
• it is necessary to comply with a legal duty (“Legal Duty”);
• it is in our legitimate interests (“Legitimate Interests”); or
• you have given consent to it (“Consent”).

These are set out in data protection law and we rely on a number of different conditions for the activities we carry out.

We use your information for the purposes, and in reliance on the reasons, set out in the table below. Where we rely on our legitimate interests as a reason for processing, we provide details of such interests:

Purpose of processing	Reason
To operate and administer our website and services, including providing you with any account on our website	Contract
To process quotations created and instructions made through our website	Contract
To make and receive payments due, including fees	Contract
To analyse and improve our website, products and services	Legitimate Interests – developing products and services and their pricing; identifying which customers may be interested in products and services; improving user experience
To keep you informed about our website and services	Legitimate Interests – to improve customer experience by keeping our customers informed of information which may affect their usage of the our website and services
To provide, perform, administer and manage all contracts with you and your accounts and services, and any business you are associated with	Contract
Internal record keeping for accounts and auditing	Legal Duty
Database backups for disaster recovery purposes	Legal Duty; Contract; Legitimate Interests – ensuring business continuity
To keep you informed of your activities as a result of using the services and of changes in our services	Contract; Legitimate Interests – keeping our customers informed about business-critical information and helping our customers to achieve their business objectives
To communicate with you for administrative and support services	Contract; Legitimate Interests – keeping our customers informed about business-critical information and helping our customers to achieve their business objectives
To make occasional contact to help manage your account with us, namely to discuss website functionality and service delivery	Legitimate Interests – helping our customers achieve their business objectives
If you have previously used our products and/or services, to send you marketing materials relating to similar products and services	Legitimate Interests – to tell our customers about products and services which may interest them and to develop our business
To send you other marketing materials relating to our website, products, and services and those of our panel of providers, including to inform you of new products, special offers or other information (but, only where you consented to this, and only for so long as you have not withdrawn your consent)	Consent

8. Who We Disclose Your Information To

We will not sell your information. However, we may disclose your information to others in the following circumstances:

8.1 Public Information

Where, as part of the functionality of our website, it is envisaged that certain of your information will be made available to the public in general, or to other persons registered with our website or services, then we may make that data available on such basis. If our website settings allow you to control what elements of your information are made public, then we will honour the settings that you select.

8.2 Business Representative Information

If you are a contact, staff one introducer, staff introducer, or other individual or representative associated with any business that is a user of ours, then we may provide all of your information to them.

8.3 Panel Information

Where you are a supplier of products and services on our panel, then we may provide your information and details of your products and services to businesses and individuals registering with our website and services who are looking to create quotations and instructions.

8.4 Instruction Information

In relation to specific instructions made, we may pass information concerning that instruction between the businesses making and receiving that instruction (including client information, introducer information, quotations, progress, and fee information), and their associated representatives.

8.5 Our contractors and suppliers

Where we use third parties to provide or supply any part of our website or services, or to enforce or administer any contracts with you, or to manage any fee or other payments to be made or received, then we may provide your information to them as reasonably required for those purposes, including to the suppliers who host or manage our website and systems, our payment processors, and insurers.

8.6 Legal requirements

We may supply your information to a government authority or regulator where required to comply with a legal requirement, for the administration of justice, or where reasonably required to protect your vital interests.

8.7 How third parties will handle your information

In any case where we are providing your data to a third party, your information may be held by them as data processor on our behalf, in which case we will remain (if applicable) the data controller, and your information will only be held and used by them on our behalf and in accordance with our instructions and this policy. In some cases, your information may need to be provided to them to be used by them for their own purposes, and as data controller, where this is reasonably necessary, such as, where required for the purposes of any instruction, or for the purposes of processing any payments; and in such case, they should inform you separately that they are holding your information as data controller and the details of their privacy policy.

9. Where We Process Your Information

We and our contractors and suppliers normally store and process your information in the European Economic Area. However, we and our contractors and suppliers may from time to time store and process your information elsewhere outside the European Economic Area (such as because our contractor or supplier who carries out any order fulfilment or payment processing, for instance, may be based elsewhere). If your information is to be stored or otherwise processed outside the European Economic Area, we apply strict safeguards such as:

• Sending your personal information to countries approved by the European Commission as having an adequate level of data protection, whether by virtue of its domestic legislation or of the international commitments it has entered into (e.g. Canada, the Isle of Man and Switzerland).
• Entering into a contract that has been approved by the European Commission with the recipient of your personal information that provides a suitable level of protection for your data.
• Where personal information is to be transferred to the United States, sending such information to a company which is a member of the EU-US Privacy Shield Scheme, a framework which requires members to adhere to certain privacy principles.

10. Choosing Whether To Provide Information

You can choose not to give us information. In this section we explain the effects this may have.

We may need to collect information by law or to enter into or fulfil a contract with you. If you choose not to give us this information, it may: (i) delay or prevent us from fulfilling our contract with you or doing what we are required to do by law, (ii) affect our ability to administer our accounts or implement our policies; and/or (iii) mean that we cancel a product or service we provide to you.

We sometimes ask for other information that is useful, but not required by law or a contract. We will make this distinction clear when we ask for it: for example, on web forms we will generally highlight required information with an asterisk symbol. You do not have to give us these extra details which are not required and it will not affect the products or services we provide to you.

11. SortRefer As A Data Processor

We collect, use and disclose certain personal data in the capacity of a data processor (as defined in the EU General Data Protection Regulation (2016/679)) rather than a data controller. Such data includes personal data about clients in respect of whom referrals are made, as well as personal data about any other individuals which you may place on our website from time to time. Our introducers and panel members are responsible for making sure that the relevant data subject’s privacy rights are respected, including ensuring appropriate disclosures about third party data collection and use. To the extent that we are acting as a user’s data processor, we will process personal data in accordance with the terms of our agreement with the user and the user’s lawful instructions.

12. How Long We keep Your Personal Data

Where we hold your personal data as a data controller, we will keep your data for the period that you are a customer or counterparty of SortRefer. If you cease to be a customer or counterparty of SortRefer, we will keep your data for the minimum length of time we deem necessary to fulfil the purposes set out in this privacy policy unless a longer retention period is required or permitted by relevant legal or regulatory provisions.

13. Security

We are committed to doing what we reasonably can to keep your information secure from unauthorised access, and we have put in place reasonable physical, electronic and managerial measures with a view to safeguarding and securing your information. However, no technology or measure is absolutely secure, so we cannot guarantee that your information will not be subject to unauthorised access. You are responsible for keeping your username and password log-in details confidential.

14. Data Protection And Your Rights

Where we are holding any personal data about you as a data controller, you have the following rights, and if you would like to exercise any of these, please contact us through our contact details appearing above in this privacy policy:-

14.1 Access to your information

You have the right to access the personal data that we hold about you. If you would like to exercise this right, please contact us using the details in section 1 (About Us) above, however note that if you have an account with us, then you can see most of your information through your account web pages on our website.

14.2 Right to rectification

You have the right to make us correct any inaccurate personal data we hold about you. If you have an account with us, we would ask you to keep your information up to date. If you believe that your personal data is incorrect or incomplete, please write to or email us as soon as possible using the details in section 1 (About Us) above.

14.3 Right to erasure

You have the right to make us erase personal data we hold about you. This right will only apply in certain circumstances, for example:

• We no longer need to use the personal data to achieve the purpose we collected it for
• You withdraw your consent if we are using your personal data based on that consent
• Where you object to the way we use your data, and there is no overriding legitimate interest

14.4 Right to restrict processing

You have the right to restrict our processing of the personal data we hold about you. This right will only apply in certain circumstances, for example:

• You contest the accuracy of the personal data we hold
• Your personal data has been used unlawfully but you do not want us to delete it
• Where we no longer need to use the personal data to achieve the purpose we collected it for, but you need the data for legal claims
• You have asked us to stop processing your data but you are waiting for us to tell you if we are allowed to keep on using it

14.5 Right to data portability

You have the right to receive personal data, which you have provided to us, in a structured, commonly used and machine-readable format. You also have the right to make us transfer this personal data to another organisation.

14.6 Right to object

You have the right to object to our processing of personal data we hold about you in certain circumstances (including for the purposes of sending marketing materials to you).

14.7 Right to withdraw consent

You have the right to withdraw your previously granted consent to processing; however, this will not affect the validity of any processing previously consented to.

15. Complaints

To make enquiries, exercise any of your rights set out in this privacy policy or make a complaint please contact us using the details given in section 1 (About Us) above.

You also have the right to lodge a complaint about the use of your personal data with the relevant data protection regulator, which in the UK is the Information Commissioner’s Office.

16. Legal Status Of This Policy

This privacy policy is not intended to and does not create any contract or contractual rights. Your rights in relation to this privacy policy are limited to any non-contractual obligation of confidentiality we may have at law, any confidentiality obligation assumed by us in any contract with you under our applicable terms and conditions if you register for an account with our website, and any statutory rights you may have under the Data Protection Act 1998, the EU General Data Protection Regulation (2016/679) and the Privacy and Electronic Communications (EC Directive) Regulations 2003.