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Privacy Policy

INTRODUCTION

At Field Connection Ltd we take the matter of privacy very seriously. This privacy policy ("Privacy Policy") explains how
Field Connection Ltd, our subsidiaries and affiliates collect, share, and use your personal information. You'll also find information
about how you can exercise your privacy rights. By visiting our website, you agree to Field Connection Ltd using your
personal information as described in this Privacy Policy.
 
Please use the Glossary at the end of this Privacy Policy to understand the meaning of some of the terms used in it.

PUPOSE OF THIS PRIVACY POLICY

This Privacy Policy aims to give you information on how Field Connection Ltd collects and processes your personal data through
your use of this website and our Smartsnap website, including any data you may provide through our associated mobile data
collecting devices and the SnapWebHost website when you sign up to complete our market research surveys.

It is important that you read this Privacy Policy together with any other privacy notice on our website from time to time so that you
are fully aware of how and why we are using your data.

CONTROLLER

Field Connection Ltd is the controller and responsible for your personal data (collectively referred to as, "we", "us" or "our" in this
Privacy Policy).

We have appointed a data protection lead (DPL) who is responsible for overseeing questions in relation to this Privacy Policy. If you
have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact us via our
customer  contact page  and state that your query is for the attention of the DPL.

CONTACT DETAILS

Our full details are:
 
Field Connection Ltd 2 Warner House Harrovian Business Village Harrow HA1 3EX United Kingdom.
Telephone : +44 208 423 3925 You can also contact us through our customer  contact page
 
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority
for data protection issues ( https://ico.org.uk ). In the UK, please read: 
https://ico.org.uk/make-a-complaint/
 for details of
how to do this. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so
please  contact us in the first instance.

CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

We may update this Privacy Policy from time to time in response to changing legal, technical or business developments. When we
update our Privacy Policy, we will take appropriate measures to inform you, consistent with the significance of the changes we make.
We will obtain your consent to any material Privacy Policy changes if and where this is required by applicable data protection laws.
 We encourage you to periodically review this page for the latest information on our privacy practices. 
 It is important that the personal data we hold about you is accurate and up to date. Please keep us informed if your personal
data changes during your relationship with us.

THIRD-PARTY LINKS

This 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.

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). We may collect, use, store and transfer different
kinds of personal data about you which we have grouped together: Identity Data includes first name and last name.
 Contact Data means the data we use to contact you including your personal details, address, email address, social
media id and telephone number.
 
Technical Data means details about the device(s) you use to access our website including your internet protocol (IP) address,
browser type and version, location, browser plug-in types and versions, operating system and platform and other technology on
the devices you use to access this website. Profile Data includes your username (email address) and password, your login
data, feedback and survey responses. Usage Data includes information about how you use our website. This includes your
browsing patterns and information such as how long you might spend on one of our webpages and what you look at and for
on our website, the click stream to and from our website, page response times and page interaction information such as scrolling,
clicks and mouseovers. Marketing and Communications Data includes your preferences in receiving ongoing market research
from us and your communication preferences. We also collect, use and share aggregated and/or anonymised data
("Aggregated Data") such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal
data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we
may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. This is used within
Field Connection Ltd to improve the design and layout of our sites. We gather information on the relative popularity of each page,
the average number of pages accessed by visitors, the number of emails sent, or files downloaded, and the average time spent
on the Website. None of this information is linked back to you as an individual. However,if we combine or connect Aggregated Data
with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be
used in accordance with this Privacy Policy.

HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:Direct interactions. You may give us your Identity
Data, Contact Data, Transaction Data, Profile Data and Marketing and Communications Data by using our website, filling in forms
or by corresponding with us by post, phone, email or otherwise; Automated technologies or interactions. As you interact with our
website/mobile data collectiong devices, we may automatically collect Usage Data and Technical Data about you and your
reactions and buying patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see
our  Cookies Policy  for further details.

THIRD PARTY SOURCES OF DATA/DATA SHARING:

We also collect from and share data with the following providers: Business Partners & Agents: We will not sell, rent, lease or
transfer personal information to third parties other than business partners or agents. We will not disclose such information to
business partners without first letting you know and offering you an opportunity to opt-out or otherwise prohibit disclosure to that
transfer personal information to our agent in order that such agent processes personal data pursuant to our instructions and only
after assuring that the agent has privacy policies in effect for such data which are at least as stringent as those contained in this
privacy policy.

Professional Advisers and Investors: We may also share your data with professional advisers such as our lawyers and
insurers to manage risks and legal claims, and/or as part of our relationship and obligations to our investor organisations or to our
pension administrators. This is in our legitimate interests.

Group: Given the global nature of Field Connection Ltd 's business, we may need to transmit your information to other members
of Field Connection Ltd group, which may involve the cross-border transfer of your information. Please note that by sending your
personal information to us you are explicitly consenting to the cross-border transfer of your information. Please refer to 
International Transfers  below for more information.

Law Enforcement/Legal Compliance: We will cooperate with all third parties to enforce their intellectual property or other rights.
We will also cooperate with law enforcement requests from within or outside your country of residence. This may include disclosing
your personal information to government or law enforcement agencies, or private parties, when we have a good faith belief that
disclosure is required by law or when we, in our discretion, believe that disclosure is necessary to protect our legal rights, or those
of third parties and/or to comply with a judicial proceeding, court order, fraud reduction or legal process served on us. In such cases,
we may raise or waive any legal objection or right available to us. These uses of your data are in our legitimate interests of protecting
our business security. We may also use your data and share it with the recipients listed in this Privacy Policy for the purpose of
complying with our legal obligations.

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 provide you with details about our products and services.

•  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 or regulatory obligation.

You have the right to withdraw consent to market research data gathering at any time by visiting our Preferences Page.

MARKETING

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 and services may be relevant for you. We only use the data
you provide to us directly for this purpose along with the Aggregated Data provided to us by our analytics partners and we do not
track what other websites you may visit after visiting our site, though in common with most websites, we may register the site
which referred you to our site (e.g. a search engine).

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
We generally only send electronic messages - such as email invites - to people who have previously expressed an interest in
products and services from us and this is in our legitimate interests. We will always offer a way out of receiving this market research
invite when you enquire about our services and in every market research communication afterwards. We may on occasion send
out postal requests
for the purpose of growing our sales which is in our legitimate interests and in this scenario, we will rely on you to let us know if you do
not want to receive this by opting out of marketing (see  Opting Out  below). OPTING OUT

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to
you or by  contacting us  at any time.
 
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result
of a product/service enquiries or related correspondence, and we will continue to process such data in accordance with this
Privacy Policy and only ever as permitted by law.

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 our  Cookies Policy

CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we 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.

DISCLOSURES OF YOUR PERSONAL DATA

We require all third parties to respect the security of your personal data and to treat it in accordance with the law and they may only
use your data for the purposes we specify in our contract with them. We will always work with them to protect your privacy.

INTERNATIONAL TRANSFERS

Some of our External Third Parties and members of the Field Connection Ltd group are based outside the European Economic Area
(EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
 
Whenever we transfer your personal data out of the 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 by the European Commission. For further details, see 
European Commission: Adequacy of the protection of personal data in non-EU countries
 
Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal
data the same protection it has in Europe. For further details, see  European Commission: Model contracts for the transfer of
personal data to third countries
 

Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires
them to provide similar protection to personal data shared between the Europe and the US. For further details, see 
European Commission: EU-US Privacy Shield
 

Please  contact us  if you want further information on the specific mechanism used by us when transferring your personal data out
of the EEA.

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. You acknowledge that the Internet is not a completely secure medium
for communication and, accordingly, we cannot guarantee the security of any information you send to us (or we send to you) via
the Internet. We are not responsible for any damages which you, or others, may suffer as a result of the loss of confidentiality of
such information.

DATA RETENTION: HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the
purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, 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 requirements. 
 

In some circumstances you can ask us to delete your data: see ' Your Legal Rights ' below for further information.

In some circumstances we may 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. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under GDPR in relation to your personal data.
 
You have 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 we hold about you and to check that we are lawfully processing it.

Request correction of the 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 for example where you consider that we do not need it any longer for the purposes for which
we originally collected it as explained to you in this Privacy Policy, where you have withdrawn your consent to our using it and we
had relied on that consent according to this Policy, where you consider that we cannot show a 'legitimate interest' in continuing to
process it and we have relied on that legitimate interest to process it as explained to you in this Policy . 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 law. 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 of your personal data. This enables you to ask us to suspend the processing of your personal
data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you
do not want us to erase it; (c) 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; or (d) you have objected to our use of your data but we need to verify whether we have
overriding legitimate grounds to use it.

Request the 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. 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 at any time 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 wish to exercise any of these rights, please  Contact Us , marking your query for the attention of the DPL.

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 may 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 may 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.

GLOSSARY

DATA PROTECTION

For the purposes of this Privacy Policy data protection law means: (i) until 25 May 2018 the Data Protection Act 1998 and then (ii)
from 25 May 2018 and unless and until it is no longer directly applicable in the UK, the General Data Protection Regulation ((EU)
2016/679) (GDPR) and any national implementing laws, regulations and secondary legislation, as amended or updated from time
to time, in the UK and then (iii) any successor legislation to the GDPR or the Data Protection Act 1998.

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 (both positive and negative) and your rights 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.
 

Complying with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a
legal or regulatory obligation that we are subject to.

EXTERNAL THIRD PARTIES

Cloud storage providers - we use cloud computing platforms that securely store all of our data, including respondent details.
Email service providers - in order to send you market research requests and transactional emails, we share your details with our
email service providers. clients and insights providers - other market research companies and insights tools allow us to
understand our respondents better so that we may provide you with the best possible website, experience and respondent
experience. We may share certain information about our respondentsor website visitors to facilitate this process.

 Feedback forms - we engage a third party to send out feedback surveys on our behalf.  Web Beacons - We may also use
"Web beacons" that monitor your interaction with our HTML email campaigns. Web beacons (or Web bugs) are small strings of
code that provide a method for delivering a graphic image for the purpose of transferring data including the IP (Internet Protocol)
address of the computer that downloaded the Web beacon and the time the Web beacon was viewed, to let us know whether
you received and opened our e-mail. Please refer to our  Web Beacon Policy  for further details.

Last updated: 24th May, 2018
 © Field Connection Limited, 2018. All Rights Reserved.