Gecko Connect (“we” or “us”) is committed to protecting and respecting your privacy. This policy (together with our Cookie Policy and any other documents referred to in it) sets out the basis on which any personal data (as defined in the UK`s Data Protection Act 2018 (“DPA”), the General Data Protection Regulation (“GDPR”),) (the “Personal Data”) we collect from account holders or individual users or visitors to our Platform, or that is uploaded to our Platform, will be processed by us. 

Account holders, users and visitors of our Platform or owners of Personal Data collected by us (each, “you”) should read the following carefully to understand our views and practices regarding your personal data and how we will treat it. 

By providing any Personal Data to us, you consent to the collection, use, disclosure and transfer of such Personal Data in the manner and for the purposes set out below.

The Data Controller

Responsible for data processing in accordance with the provisions of the DPA and GDPR is:

Gecko Connect 

Unit 7, Millhouse Barns, Puxton Park, 

Nr Cowslip Lane, Hewish,

BS24 6AH, United Kingdom

Web: www.geckoconnect.com

E-mail: info@geckoconnect.com

Should you have any questions about this Privacy Policy or the feeling that your interests are not or inadequately represented, you can contact us using info@geckoconnect.com or our Contact Form.

The Supervisory Authority

According to the DPA and GDPR, you are entitled to file a complaint with your local Supervisory Authority or the Supervisory Authority responsible for us. The UK`s Information Commissioner`s Office (ICO) is the for us relevant data protection supervisory authority. The ICO is located at Wycliffe House, Water Ln, Wilmslow SK9 5AF, UK (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO.

The relevant legal bases

In accordance with the DPA and GDPR, we inform you of the legal basis for our data processing. If the legal basis is not stated, the following applies: 

• the legal basis for obtaining consent is of course consent, 

• the legal basis for processing in order to fulfil our services and carry out contractual measures and respond to enquiries is contract fulfilment, 

• the legal basis for processing in order to fulfil our legal obligations is our legal obligation, and 

• the legal basis for processing in order to protect our legitimate interests is our legitimate interests. 

Your rights

These rights are standardised in both the DPA and GDPR. This includes:

• the right to information,

• the right to erasure,

• the right to rectification,

• the right to data portability,

• the right to restriction of data processing,

• the right to object to data processing.

Please contact us at any time with questions and suggestions regarding data protection and to enforce your rights as a data subject. 

Automated Decision Making

Automated decision making is not used at Gecko Connect.

Processing of special categories of data

No special categories of data are actively collected or processed at Gecko Connect.

General information on data processing

In the course of our business and website operations, we process data. This also includes disclosure by transmission to third parties and, where applicable, to so-called third countries outside the UK. Where we transfer data outside the UK, we have highlighted this accordingly below.

If, in the course of our processing, we disclose data to other persons and companies, transmit it to them or otherwise grant them access to the data, this will only be done on the basis of a legal permission i.e., the above-mentioned legal bases. If we commission third parties to process data, this is done on the basis of a so-called "processing agreement". 

Information we may collect 

We may collect and process the following data which may contain Personal Data:

• information that you provide by filling in forms on our website and/or mobile application (“our Platform”), including information provided at the time of registering to use our Platform, subscribing to any services provided by us, posting material, reporting a problem with our Platform, or requesting further services;

• information, data, documents or images that you upload onto our Platform;

• details of transactions you carry out through our Platform; 

• details of your visits to our Platform, resources that you access and actions you are working on through the Platform;

• if you contact us, a record of that correspondence; and

• responses to surveys that we send to you, although you do not have to respond to them.

IP Addresses

We may also collect and process information about your device, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our business partners. This is statistical data about our users’ browsing actions and patterns and does not identify any individual.

Cookies

We use so-called cookies on our website. Cookies are small text files that are stored on your respective device (PC, smartphone, tablet, etc.) and saved by your browser. For further information please refer to our Cookie Policy. 

Log files during your visit

We log your visit. In doing so, we process:

• Name(s) of our accessed website(s),

• date and time of the access,

• the amount of data transferred,

• the browser type and version,

• the operating system you use,

• the referrer URL (the previously visited website),

• your IP address,

• the requesting provider.

The log file is deleted after seven days, unless it is needed to prove or clarify specific legal violations that have become known within the retention period.

Contacting us

If you contact us, we process the following data from you for the purpose of processing and handling your enquiry: Name, contact details -if provided by you- and your message. 

Business relationships

In the course of our business activities, we mainly processing personal data and contact data. The purpose of processing the personal data is to execute the relevant contract, to secure and enforce obligations, to conduct business communications and correspondence or to comply with legal obligations.

Administration, financial accounting, office organisation, contact management

We process data in the context of administrative tasks as well as organisation of our operations, financial accounting, and compliance with legal obligations, such as archiving. In this regard, we process the same data that we process in the course of providing our contractual services. 

The purpose and our interest in the processing lies in the administration, financial accounting, office organisation, archiving of data, i.e., tasks that serve the maintenance of our business activities, performance of our tasks and provision of our services. The deletion of data with regard to contractual services and contractual communication corresponds to the data mentioned in these processing activities.

In this context, we disclose or transfer data to consultants, such as legal advisors or auditors, as well as other fee offices and payment service providers. Where applicable, we provide our service providers with further data, which they use together with the data necessary for the processing of the payment as our processors for the purpose of fraud prevention and optimisation of our payment processes (e.g., invoicing, processing of contested payments, accounting support). 

Duration of data storage

We only store personal data for as long as it is necessary for the purposes for which it is processed or for as long as any consent you have given us has been revoked by you. Insofar as statutory retention obligations must be observed, the storage period for certain data may be up to 6 years, irrespective of the processing purposes.

Transfer of personal data 

Gecko Connect will not disclose or otherwise distribute your personal data to third parties unless this is necessary for the performance of our services, you have consented to the disclosure, or the disclosure of data is permitted by relevant legal provisions. 

Gecko Connect is entitled to outsource the processing of your personal data in whole or in part to external service providers acting as processors for Engagement Gecko within the framework of the DPA and GDPR. External service providers support us, for example, in the technical operation and support of the website, data management, the provision and performance of services, marketing, as well as the implementation and fulfilment of reporting obligations. 

The service providers commissioned by Gecko Connect process your personal data exclusively in accordance with our instructions. Gecko Connect remains responsible for the protection of your personal data, which is ensured by strict contractual regulations, technical and organisational measures and additional controls by us.

Personal information may also be disclosed to third parties if we are legally obliged to do so e.g., by court order or if this is necessary to support criminal or legal investigations or other legal investigations or proceedings at home or abroad or to fulfil Gecko Connects  legitimate interests.

Security

State-of-the-art internet technologies are used to ensure the security of your personal data. During the online enquiry process, your details are secured with SSL encryption. For secure storage of your personal data, the systems are protected by firewalls that prevent unauthorised access from outside. In addition, technical and organisational security measures are used to protect the personal data you have provided against accidental or intentional manipulation, loss, destruction, or access by unauthorised persons.

All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Platform, you are responsible for keeping this password confidential. We ask you not to share the password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your personal data transmitted to our Platform; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Uses made of the information

We use information held, including Personal Data, in the following manner: 

• to ensure that content from our Platform is presented in the most effective manner for you and for your device;

• to provide you with information, products or services that you request from us, and to otherwise carry out our obligations arising from any contracts entered into between you and us;

• to provide you with information, products or services which we feel may interest you, where you have consented to be contacted for such purposes;

• to allow you to participate in interactive features of our service, when you choose to do so;

• to notify you about changes to our services; 

• to investigate any complaints relating to the use of our Platform or any suspected unlawful activities; 

• complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;

• any other purposes for which you have provided the information; and

• carrying out whatever else is reasonable or related to or in connection with the above and our provision of goods and/or services to you.

Disclosure of your information

We may disclose your personal data to third parties:

• for the purposes of providing products or services that you request from us, fulfilling our obligations arising from any contracts entered into between you and us, processing payments in connection therewith or otherwise in connection with your use of our Platform;

• where a third party claims that any content posted or uploaded by you to our Platform constitutes a violation of their rights under applicable law, in which case we may disclose your identity to that third party;

• in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets; or

• if we or substantially all of our shares or assets are acquired by a third party, in which case Personal Data held by us about our customers will be one of the transferred assets.

• We may also disclose your personal data to a governmental or regulatory body, law enforcement, or other authorities, in order to enforce our terms of use for the Platform, to cooperate with any direction, request or order from such parties or to report any suspected unlawful activity. 

Consent

By providing your personal data to us, you consent to the collection, use and disclosure of your personal data by us for the purposes set out in this Privacy Policy.

Where any Personal Data relates to a third party, you represent and warrant that the Personal Data is up-to-date, complete, and accurate and that you have obtained the third party’s prior consent for our collection, use and disclosure of their Personal Data for the Purposes. You agree that you shall promptly provide us with written evidence of such consent upon demand by us. 

Each use of our services by you shall constitute a fresh agreement for us to collect, use and disclose the Personal Data in accordance with this privacy policy.

You may withdraw your consent and request us to stop using and/or disclosing your personal data for any or all of the Purposes by submitting your request to us in writing to info@engagementgecko.com.

Should you withdraw your consent to the collection, use or disclosure of your personal data, it may impact our ability to proceed with your transactions, agreements, or interactions with us. Prior to you exercising your choice to withdraw your consent, we will inform you of the consequences of the withdrawal of your consent. Please note that your withdrawal of consent will not prevent us from exercising our legal rights (including any remedies) or undertaking any steps as we may be entitled to at law.

Access and correction 

The DPA and the GDPR give you the right to access your personal data. Your right of access can be exercised at any time without detriment. Any access request may be subject to a fee of an administrative fee at our rates then in force to meet our costs in providing you with details of the information we hold about you. 

In the event that you wish to correct and/or update your personal data in our records, you may inform us in writing of the same by sending us an email at info@engagementgecko.com. In certain cases, Personal Data may also be corrected or updated via the Platform.

We will respond to requests regarding access and correction as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any Personal Data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the DPA and the GDPR). 

Accuracy

We endeavour to ensure that all decisions involving your personal data are based upon accurate and timely information. However, we rely on you to disclose all relevant information to us and to inform us of any changes in your personal data. As such, please disclose all relevant information necessary for us to provide services to you and ensure all information submitted to us is up-to-date, complete, and accurate. Kindly inform us promptly if there are any changes in your personal data. 

Third Party Policies

Our Platform may, from time to time, contain links to and from the websites of our partner networks, business partners and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any Data to these websites.

Data Intermediary

Where we process your personal data as a data intermediary on behalf of a third party, we will process your personal data in accordance with the instructions of the third party and shall use it only for the purposes agreed between you and the third party. All such Personal Data will be protected and retained in accordance with this privacy policy and the terms of the DPA and the GDPR. We will take steps to inform the third party of any requests, complaints, or questions that you may have regarding such Personal Data.

Online presences in social media 

We maintain online presences within social networks and websites in order to communicate with users, interested parties and users who are active there. Unless otherwise stated in this policy, we process the data of users if they communicate with us within the social networks and websites, e.g., write articles on our online presences or send us messages.

Personal information and children 

We will not knowingly collect, use or disclose personal data from minors under the age of 18 without first obtaining consent from a legal guardian through direct contact. 

Changes and updates to the privacy policy

We kindly ask you to regularly inform yourself about the content of our privacy policy. We will amend the privacy policy as soon as changes to the information processing activities we carry out make this necessary. We will inform you as soon as the changes require an act of cooperation on your part (e.g., consent) or other individual notification.

Contact

Questions, comments and requests regarding this privacy policy are welcome and should be addressed to us at info@geckoconnect.com or per mail to Gecko Connect, Unit 7, Millhouse Barns, Puxton Park, Nr Cowslip Lane, Hewish, BS24 6AH, United Kingdom. 

Last Reviewed: 20th August 2023