SOURSE AI LTD: PRIVACY POLICY
Updated 15th May 2023
Introduction
Welcome to Sourse’s privacy policy.
This privacy policy applies only to the processing, by Sourse, of the personal data of customers based in the United Kingdom (“UK”) and/or European Economic Area (“EEA”).
The personal data of customers based outside of the UK and or EEA, will be governed by, and processed in accordance with the local laws of that jurisdiction. For customers based in Australia, please see our privacy policy relevant to you, as found here: https://www.sourse.ai/privacy-policy-au-2/
Sourse respects your privacy and is committed to protecting your personal data. This privacy policy will inform you how we look after your personal data and tell you about your privacy rights and how the law protects you.
Please use the Glossary (at section 10 below) for explanation of some of the terms we use.
1. Important Information and Who We Are
Purpose of this privacy policy
This privacy policy will give you information about how we collect and process your personal data through your use of our website, including any data you may provide through when you contact us, purchase (or enquire about) our services, or sign up to our newsletters.
This website is not intended for children, and we do not knowingly collect data relating to children.
It is important that you read this privacy policy (together with any other privacy or processing policy we may provide on specific occasions) so that you are fully aware of how and why we are using your information. This privacy policy supplements other notices and policies and does not override them.
Controller
Sourse is made up of different legal entities, you can find out more about us here: https://www.sourse.co/.
This privacy policy is issued on behalf of the Sourse Group (in respect of UK and European customer’s data) so when we say “Sourse”, “we”, “us” or “our” in this privacy policy, we are referring to the relevant entity in the Sourse Group responsible for processing your data.
Sourse Pty Ltd is the parent company in the Sourse Group and is responsible for this website, as a controller.
Contact details
If you have any questions about this privacy policy or our privacy practices, please contact us in the following ways:
Full name of legal entity: Sourse AI Ltd (Company Number: 14699706)
Email address: privacyofficer@sourse.co
Postal address: 10 John Street, London, United Kingdom, WC1N 2EB
You have the right to make a complaint at any time to a relevant Data Protection Authority based within the UK or the relevant EEA Member State; for example, the UK regulator for data protection issues is the Information Commissioner’s Office (ICO) (www.ico.org.uk).
We would, however, appreciate the chance to deal with your concerns before you approach the relevant data protection authority, so please contact us in the first instance.
Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review; this version was last updated on the date stated at the beginning of it.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third-party links
Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
2. The Data We Collect About You
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
The nature of our services and platform mean that generally we only process anonymised data. This will therefore not contain any personal data about you, and we will be unable to identify you from the anonymised or aggregated data we process. This privacy policy does not apply to any anonymised data that we hold or process.
However, when we do collect personal data, we will always do so in accordance with this privacy policy, and the applicable local laws.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, gender and photographs/images.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Technical and Usage Data includes information about how you use our website, internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We may also collect, use and share Aggregated Data such as statistical or demographic data. Aggregated Data could be obtained from your personal data but is not considered personal data in law as it will not directly or indirectly reveal your identity. For example, we may aggregate some of your Technical and Usage Data to calculate the percentage of users accessing a specific website feature.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have, or are trying to enter into, with you (for example, to provide you with our services). In this case, we may have to cancel a service you have with us, but we will notify you if this is the case at the time.
3. How Is Your Personal Data Collected?
We may use different methods to collect data from and about you including through:
• Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you (i) enquire about or purchase our services, (ii) subscribe to our marketing, (iii) contact us, or (iv) give us feedback.
• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical and Usage Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please also see our cookie policy https://www.sourse.ai/cookies/ for further details.
• Third parties or publicly available sources. We will receive personal data about you from various third parties as set out below:
Technical and Usage Data from analytics providers, such as Google, based outside the UK and EEA, and advertising networks, such as [NAME], based [inside/outside] the UK and EEA; and
Contact, Financial and Transaction Data from providers of technical, payment and delivery services, such as Stripe, based outside the UK and EEA; and
Identity and Contact Data from publicly available sources, such as Companies House and the Electoral Register, based inside the UK and EEA.
4. How We Use Your Personal Data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Where we need to perform the contract that we are about to enter, or have entered, into with you/
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal obligation.
Please see section 10 (Glossary) below to find out more about the types of lawful basis that we will rely on to process your personal data.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
We have included a table below which describes the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also, where appropriate, identified what our legitimate interests are.
Please note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if, where more than one ground has been set out in the table below, you need details about the specific legal ground which we are relying on to process your personal data.
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
| To register you as a new customer and deliver our services to you including dealing with payment and invoice recovery. | (a) Identity
(b) Contact (c) Financial (d) Transaction |
(a) Performance of a contract with you.
(b) Necessary for our legitimate interests (to recover debts due to us). |
| To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy; (b) Asking you to leave a review or take a survey; (c) Contacting you with regards to updates or informative communications related to our services; and (d) Attending to and managing your requests. |
(a) Identity
(b) Contact (c) Profile (d) Marketing and Communications |
(a) Performance of a contract with you.
(b) Necessary to comply with a legal obligation. (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our services, particular in order to develop our services and grow our business). |
| To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data). | (a) Identity
(b) Contact (c) Technical |
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise).
(b) Necessary to comply with a legal obligation. |
| To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you. | (a) Identity
(b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical and Usage |
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy). |
| To use data analytics to improve our website, products/services, marketing, customer relationships and experiences. | (a) Technical and Usage | Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy). |
| To make suggestions and recommendations to you about services that may be of interest to you. | (a) Identity
(b) Contact (c) Technical (d) Usage (e) Profile |
Necessary for our legitimate interests (to develop our products/services and grow our business). |
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us, or purchased goods or services from us, and you have not opted out of receiving that marketing.
Third-party marketing
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time by clicking the unsubscribe button in any emails you receive from us, checking or unchecking the relevant boxes on our website to opt in or opt out, or by contacting us at any time.
Where you opt-out of receiving these marketing messages, this will not apply to the personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
Cookies
https://www.sourse.ai/cookies/
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see https://www.sourse.ai/cookies/
Change of purpose
We will only use your personal data for the reasons we collected it, unless we reasonably need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. Disclosures of Your Personal Data
We may share your personal data with the parties set out below for the purposes set out in the table in section 4 (How we use your personal data) above.
Internal Third Parties as set out in the Glossary.
External Third Parties as set out in the Glossary.
Specific third parties as set out in the Glossary.
Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. International Transfers
We share the personal data of our customers within the Sourse Group. This will involve transferring your data outside the UK and EEA to Australia.
We do not transfer the personal data of the end-users of our platform out of the UK or EEA, and their personal data will be stored in the country from which it originates.
Some of our external third parties are based outside the UK and EEA so their processing of your personal data will involve a transfer of data outside the UK.
Whenever we transfer your personal data out of the UK and EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
Where the country is not deemed to have an adequate level of protection, we (i) will use specific contracts approved for use in the UK and EEA (called Standard Contractual Terms and/or International Data Transfer Agreements) which give personal data the same protection it has in the UK and EEA, and (ii) undertake a data transfer risk assessment to ensure the protection of your data.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK and EEA.
7. Data Security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. Data Retention
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect of our relationship with you.
To decide the appropriate retention period, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see section 9 (your legal rights) below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
9. Your Legal Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data, including the right to:
• request access to your personal data (commonly known as a “data subject access request“). This enables you to receive a copy of the personal data that we hold about you and to check that we are lawfully processing it.
• request correction of your personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local laws. Please note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground, as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• request restriction of processing your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (i) if you want us to establish the data’s accuracy; (ii) where our use of the data is unlawful but you do not want us to erase it; (iii) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; (iv) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• request transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• withdraw consent where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us using the details in section 1 above.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
10. Glossary
LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
THIRD PARTIES
Internal Third Parties
Other companies in the Sourse Group, acting as joint controllers or processors may provide our services to you and may also provide IT, system, financial and other administrative services. Australia is currently the only other country where a Sourse Group company is based.
External Third Parties
Professional advisers acting as processors including lawyers, bankers, auditors and insurers based in Australia and the UK who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue & Customs, regulators and other authorities acting as processors based in the United Kingdom who require reporting of processing activities in certain circumstances.