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Privacy Policy

Introduction

This document refers to personal data, this is defined as information concerning any living person (a natural person who hereafter will be called the Data Subject) that is not already in the public domain.

The Data Protection Act (DPA), Privacy and Electronic Communications Regulations (PECR) and The General Data Protection Regulations (GDPR) which is EU wide and far more extensive, seek to protect and enhance the rights of data subjects. These rights cover the safeguarding of personal data, protection against the unlawful processing of personal data and the unrestricted movement of personal data within the EU. It should be noted that GDPR does not apply to information already in the public domain such as Companies House data.

Citrus IT Limited is pleased to provide the following GDPR information:

Who we are

Citrus IT is an Internet services company specialising in managed Internet services such as our CitrusMail platform.

Personal Data

Citrus IT uses the information collected from you to provide quotations, make telephone contact and support any services which you have purchased.

Some personal data may be collected about you from the forms and surveys you complete, from records of our correspondence and phone calls and details of your visits to our website, including but not limited to personally-identifying information like Internet Protocol (IP) addresses. Citrus IT may from time to time use such information to identify its visitors. Citrus IT may also collect statistics about the behaviour of visitors to its website.

A cookie is a small file which asks permission to be placed on your computer's hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

We use traffic log cookies to identify which pages are being used. This helps us analyse data about webpage traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

Overall, cookies help us provide you with a better website by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.

Any information Citrus IT holds about you and your business encompasses all the details we hold about you and any sales transactions including any third-party information we have obtained about you from public sources and our own suppliers such as credit referencing agencies.

Citrus IT will only collect the information needed so that it can provide you with our services.

Links to other websites

Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.

Legal basis for processing any personal data

To meet Citrus IT's contractual obligations to clients and to also respond to marketing enquiries.

Consent

Through agreeing to this privacy notice you are consenting to Citrus IT processing your personal data for the purposes outlined. You can withdraw consent at any time by emailing the dpo@citrus-it.co.uk or by telephoning +44 (0) 333 0124 007 or writing to us, see last section for full contact details.

Disclosure

Citrus IT may on occasion pass your Personal Information to third parties exclusively to process work on its behalf. Citrus IT requires these parties to agree to process this information based on our instructions and requirements consistent with this Privacy Notice and GDPR. Citrus IT do not broker or pass on information without your consent. However, Citrus IT may disclose your Personal Information to meet legal obligations, regulations or valid governmental requests. The company may also enforce its Terms and Conditions, including investigating potential violations of its Terms and Conditions to detect, prevent or mitigate fraud or security or technical issues; or to protect against imminent harm to the rights, property or safety of Citrus IT, its clients and/or the wider community.

Retention Policy

Citrus IT will process personal data during the duration of any contract and will continue to store only the personal data needed for six years after the contract has expired to meet any legal obligations. After six years any personal data not needed will be deleted.

We retain backups of deleted email messages for at least a month. This is for the purpose of restoring messages in case of accidental deletion. After this point, deleted messages will be purged from all our backups, although the time this takes to happen may vary due to automated load balancing.

We normally keep logs of email and server activity for up to 6 months. This is for the purposes of diagnosing and fixing problems, which are often reported to us weeks or months after they occur. Message subjects may be contained in these logs, but not message bodies. Aggregate or anonymous data, which cannot be linked to individual user accounts, may be kept for longer periods, for the purpose of improving the CitrusMail service.

Backups and logs may be kept longer than these limits in special circumstances. For example, if a problem is taking a long time to resolve, logs relevant to that investigation may be retained. Or if a server that contains backups or logs is temporarily offline because of a fault, then those backups or logs may not be deleted until the server is brought back up.

These situations are unusual, however, and when they do occur, they are temporary.

Data storage

Data is held in the United Kingdom using different (multiple) servers. Citrus IT does not store personal data outside the EEA.

Your rights as a data subject

At any point whilst Citrus IT is in possession of or processing your personal data, all data subjects, have the following rights:
  • Right of access - you have the right to request a copy of the information that we hold about you.
  • Right of rectification - you have a right to correct data that we hold about you that is inaccurate or incomplete.
  • Right to be forgotten - in certain circumstances you can ask for the data we hold about you to be erased from our records.
  • Right to restriction of processing - where certain conditions apply to have a right to restrict the processing.
  • Right of portability - you have the right to have the data we hold about you transferred to another organisation.
  • Right to object - you have the right to object to certain types of processing such as direct marketing.
  • Right to object to automated processing, including profiling - you also have the right to be subject to the legal effects of automated processing or profiling.

In the event that Citrus IT refuses your request under rights of access, we will provide you with a reason as to why, which you have the right to legally challenge.

Citrus IT at your request can confirm what information it hold about you and how it is processed.

You can request the following information:

  • Identity and the contact details of the person or organisation (Citrus IT) that has determined how and why to process your data.
  • Contact details of the data protection officer, where applicable.
  • The purpose of the processing as well as the legal basis for processing.
  • If the processing is based on the legitimate interests of Citrus IT or a third party such as one of its clients, information about those interests.
  • The categories of personal data collected, stored and processed.
  • Recipient(s) or categories of recipients that the data is/will be disclosed to.
  • How long the data will be stored.
  • Details of your rights to correct, erase, restrict or object to such processing.
  • Information about your right to withdraw consent at any time.
  • How to lodge a complaint with the supervisory authority (ICO).
  • Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
  • The source of personal data if it wasn't collected directly from you.
  • Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.

To access what Personal data is held, identification will be required

Citrus IT will accept the following forms of ID when information on your personal data is requested:

A copy of your driving licence, passport, birth certificate and a utility bill not older than three months. A minimum of one piece of photographic ID listed above and a supporting document is required. If Citrus IT is dissatisfied with the quality, further information may be sought before personal data can be released.

All requests should be made to the dpo@citrus-it.co.uk or by telephoning +44 (0) 333 0124 007 or writing to us at the address further below.

Complaints

In the event that you wish to make a compliant about how your personal data is being processed by Citrus IT or its partners, you have the right to complain to Citrus IT's Financial Director. If you do not get a response within 30 days you can complain to the ICO.

The details for each of these contacts are:

Citrus IT Limited, attention of the Financial Director
Rock House Farm
Green Moor
Sheffield
S35 7DQ

ICO

Wycliffe House, Water Lane, Wilmslow, SK9 5AF
Telephone 0303 123 1113 or email: https://ico.org.uk/global/contact-us/email/

Data mining and profiling

We do not sell or give information about our users to any third parties. Some payments are securely handled via Stripe or PayPal; your credit card details are never transmitted to our servers. The payment provider will store your credit card details and address for the purpose of future payments with Citrus IT, unless you have requested your payment details not to be stored. Stripe's privacy policy is available at https://stripe.com/gb/privacy. PayPal's privacy policy varies depending on your country of residence; you can select your country to find the relevant privacy policy at https://www.paypal.com/webapps/mpp/ua/legalhub-full

Message Processing

As part of our CitrusMail service, incoming messages are scanned for the purpose of spam detection unless you disable spam protection for the email address or your account as a whole. We may also scan some outgoing messages with the same software to prevent people using our service to send spam. Emails you report as spam are automatically analysed to help train our spam filter.

To make message searching fast, we build an index of your messages (this is a table, just like you would find at the back of a reference book, in which you can look up a word to quickly find the emails in which it appears).

No information from any of these activities is used for any other purpose, or to compile any kind of profile on our users.

We also take technical measures where feasible to prevent surveillance of our users occurring without our co-operation, such as:

  • Using encrypted SMTP for sending your mail when the receiving server supports it.
  • Mandating encrypted access for webmail, IMAP and POP if configured in your account settings.
  • Using Perfect Forward Secrecy where possible for all encrypted connections.
  • Encrypting communications between our data centres.
Like any company, we can never guarantee our measures are 100% effective, as we don't know the full capabilities of any attackers. However, these measures do act to increase the difficulty and expense of any surveillance.

Employee access to data

Due to the nature of their jobs as system administrators, some of our employees have the capability to access data in customer accounts. We hold all of our employees to the highest ethical standards, and this includes not accessing anyone's account without their permission. If you ask us to look at a specific message, for example because it was incorrectly classified, we will normally request that you move it to a special folder so we can be sure we won't access anything else.

Account deletion

Should you close your account, all data will be permanently deleted 7 days after closing. It may take a further 2 weeks to purge from all our backups.