Privacy Policy

 

BACKGROUND:

Speechly® is managed and owned by FITTS Limited.

FITTS Limited understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits this website (“Our Site”) and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.

 

Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of this Privacy Policy is requested prior to using our products and services.

 

  1. Definitions and Interpretation

In this Policy the following terms shall have the following meanings: 

 

“Account”

means an account required to access and/or use certain areas and features of Our Site;

“Cookie”

means a small text file placed on your computer or device by Our Site when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in Part 14, below; and

“Cookie Law”

means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;

 

  1. Information About Us

Our Site and App is owned and operated by FITTS Limited; a Limited Company registered in England under company number 10882160.

Registered address: 20 – 22 Wenlock Road, London, N1 7GU.

Data Protection Officer: James Haworth.

Email address: Data.Protection@fitts.io.

Telephone number: +44 (0) 203 855 0750.

Postal address: Data Protection Officer, FITTS Limited, 20 – 22 Wenlock Road, London, N1 7GU.

 

  1. What Does This Policy Cover?

This Privacy Policy applies only to your use of Our Site and our App. Our Site may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other services and we advise you to check the privacy policies of any such websites before providing any data to them.

 

  1. What Is Personal Data?

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

 

  1. What Are My Rights?

Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:

  1. The right to be informed about Our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 15.
  2. The right to access the personal data we hold about you. Part 13 will tell you how to do this.
  3. The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 15 to find out more.
  4. The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 15 to find out more.
  5. The right to restrict (i.e. prevent) the processing of your personal data.
  6. The right to object to us using your personal data for a particular purpose or purposes.
  7. The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
  8. The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
  9. Rights relating to automated decision-making and profiling. We do not use your personal data in this way.

For more information about Our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 15.

It is important that your personal data is kept accurate and up to date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about Our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 15.

 

  1. What Data Do You Collect and How?

Depending upon your use of Our Site, we may collect and hold some or all of the personal and non-personal data set out in the table below, using the methods also set out in the table. Please also see Part 14 for more information about Our use of Cookies and similar technologies. We do not collect any ‘special category’ or ‘sensitive’ personal data, personal data relating to children or data relating to criminal convictions and/or offences.

Data Collected How We Collect the Data
Identity Information including name, title, organisation. We will collect this data through registration for marketing such as an event, mailing list or webinar or during the provisioning of a user account for use of a particular service or product.
Contact information including email address, telephone number, address, contact preferences. We will collect this data through registration for marketing such as an event, mailing list or webinar or during the provisioning of a user account for use of a particular service or product.
Business information including business name, job title, industry, organisation size. We will collect this data through registration for marketing such as an event, mailing list or webinar or during the provisioning of a user account for user account for use of a particular service or product. We may from time to time supplement business information you provide us with publicly available data.
Payment information including bank account number, bank name, bank country, payment history. Payment information will be collected through a contract and onboarding form..
Technical information including IP address, browser type and version, operating system. This will be collected through audit and monitoring capabilities built into our products and services.
Usage data of our applications and services including log in date and log in time, actions and activities within the service. This will be collected through audit and monitoring capabilities built into our products and services.
App Transcription Recordings. Transcription audio and text is synced to each user’s account and stored in Azure. This data is used solely for the purposes of storing and surfacing it in the App for the end user. 

 

  1. How Do You Use My Personal Data?

Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes how we may use your personal data, and our lawful bases for doing so:

What We Do What Data We Use Our Lawful Basis
Registering you on our Site or App. Identity information, contact information, business information. We must register you in order to carry our contractual obligations to provision access to FITTS products and services in line with the applicable terms.
Providing necessary functionality Identity information, contact information, business information, usage data. We process your Personal Data to perform our contract with you for the use of our websites and services; where we have not entered into a contract with you, we base the processing of your Personal Data on our legitimate interest to provide you with the necessary functionality required during your use of our websites and services;
Promoting the security of Our websites and services

 

Identity information, contact information, technical information, usage data.

We process your Personal Data by tracking use of our websites and services, creating aggregated, non-personal data, verifying accounts and activity, investigating suspicious activity and enforcing our terms and policies, to the extent this is necessary for our legitimate interest in promoting the safety and security of the services, systems and applications and in protecting our rights and the rights of others;
Handling contact and user support requests Identity information, contact information, business information, technical information, usage data.. If you fill out a “Contact Us” web form or request user support, or if you contact us by other means including via a phone call, Teams message or self-service request we process your Personal Data to perform our contract with you and to the extent it is necessary for our legitimate interest in fulfilling your requests and communicating with you
Managing payments for our products and services. Identity information, contact information, business information, usage data, payment information. If you have provided financial information to us, we process your data to verify that information and to collect payments to the extent that doing so is necessary to complete the transaction and perform our contract with you.
Sending marketing communications (you may opt-out at any time by following the opt-out procedure provided in our communications). Identity information, business information contact information. We will process your Personal Data to send you marketing information, product recommendations and other non-transactional communications (e.g., marketing newsletters, telemarketing calls, SMS, or push notifications) about us and our affiliates and partners, including information about our products, promotions or events as necessary for our legitimate interest in conducting direct marketing or to the extent you have provided your prior consent (please see the “Your rights relating to your Personal Data” section, below, to learn how you can control the processing of your Personal Data by FITTS for marketing purposes)
Assessing and improving user experience Identity information, technical information, usage data. We process device and usage data, which in some cases may be associated with your Personal Data, in order to analyse trends in order to assess and improve the overall user experience to the extent it is necessary for our legitimate interest in developing and improving the service offering, or where we seek your valid consent;
Developing and improving our websites and services: Identity information, technical information, usage data. We process your Personal Data to analyse trends and to track your usage of and interactions with our websites and services to the extent it is necessary for our legitimate interest in developing and improving our websites and services and providing our users with more relevant content and service offerings, or where we seek your valid consent;
Handling and Storing Transcription Data Identity information, technical information, Identity information, business information contact information, usage data and conversation history. In order for our App users to access transcription history and recordings, we [FITTS] must store this data. Transcription audio and text is synced to each user’s account and the data is stored in Azure. This data is used solely for the purposes of storing and surfacing it in the App for the end-user. If the Account is terminated, the data will be terminated with it.

 

With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email, telephone, text message and/or post with information, news, and offers on our products and services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out. We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time.

Third Parties (including our partners and suppliers) whose content appears within Our Site may use third-party Cookies, as detailed below in Part 14. Please refer to Part 14 for more information on controlling cookies. Please note that we do not control the activities of such third parties, nor the data that they collect and use themselves, and We advise you to check the privacy policies of any such third parties.

We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 15.

If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.

In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.

 

  1. How Long Will You Keep My Personal Data?

We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):

Type of Data How Long We Keep It
Identity Information including name, title, organisation. 5 years from the last engagement with FITTS or until the customer requests to be removed from our records; whichever is sooner.
Contact information including email address, telephone number, address, contact preferences. 5 years from the last engagement with FITTS or until the customer requests to be removed from our records; whichever is sooner.
Business information including business name, job title, industry, organisation size. 5 years from the last engagement with FITTS or until the customer requests to be removed from our records; whichever is sooner.
Payment information including bank account number, bank name, bank country

7 years from the last date of entry.

Technical information including IP address, browser type and version, operating system. 1 year.
Usage data of our applications and services including log in date and log in time, actions and activities within the service. 3 years from the last use of a FITTS product or service.
Transcription history 30 days.

 

  1. How and Where Do You Store or Transfer My Personal Data?

We may store or transfer some or all of your personal data in countries that are not part of the European Economic Area (the “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein). These are known as “third countries” and may not have data protection laws that are as strong as those in the UK and/or the EEA. This means that we will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation as follows.

We share your data within the group of companies of which we are a part. Where this involves the transfer of personal data outside the EEA, our group ensures that personal data is protected by requiring all companies within the group to follow the same rules with respect to personal data usage. These are known as “binding corporate rules”. More information on binding corporate rules is available from the European Commission.

The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:

  • limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;
  • procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so;

 

  1. Do You Share My Personal Data?

We will not share any of your personal data with any third parties for any purposes, subject to the following exceptions.

If we sell, transfer, or merge parts of Our business or assets, your personal data may be transferred to a third party. Any new owner of Our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Policy.

In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

 

  1. How Can I Control My Personal Data?

    • In addition to your rights under the Data Protection Legislation, set out in Part 5, when you submit personal data via Our Site, you may be given options to restrict Our use of your personal data. In particular, we aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details and by managing your Account).
    • You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.

 

  1. Can I Withhold Information?

To enable us to deliver Our Site to you, we require personal data from you. If you withhold this data or your consent, then we will not be able to deliver Our Site to you.

You may restrict Our use of Cookies. For more information, see Part 14.

 

  1. How Can I Access My Personal Data?

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 15.

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover Our administrative costs in responding.

We will respond to your subject access request within one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of Our progress.

 

  1. How Do You Use Cookies?

Our Site may place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by us and are used only by us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve Our products and services. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.

By using Our Site, you may also receive certain third-party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, and/or parties other than us. Third-party Cookies are used on Our Site for the purpose of user analytics and performance monitoring to ensure we provide the best service to you. For more details, please refer to the table below. These Cookies are not integral to the functioning of Our Site and your use and experience of Our Site will not be impaired by refusing consent to them.

All Cookies used by and on Our Site are used in accordance with current Cookie Law.

Before Cookies are placed on your computer or device, you will be shown a prompt requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended.

The following first-party Cookies may be placed on your computer or device:

 

Name of Cookie

Purpose

Strictly Necessary

Identity

Identifier of you as a user to provide session state information between your visits

No

Analytical

Data related to your previous activities to provide additional insight on Our Site and to provide easy navigation functionality.

No

 

and the following third-party Cookies may be placed on your computer or device:

 

Analytics

Google

How our customers use our products and/or services to allow us to innovate and develop them.

To Grow our business through understanding of user requirements and interests.

Analytics

Hubspot

How our customers use our products and/or services to allow us to innovate and develop them.

To Grow our business through understanding of user requirements and interests.

Analytics

LinkedIn

How our customers use our products and/or services to allow us to innovate and develop them.

To Grow our business through understanding of user requirements and interests.

In addition to the controls that we provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.

You can choose to delete Cookies on your computer or device at any time, however, you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.

It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.

 

  1. How Do I Contact You?

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details (for the attention of the Data Protection Officer):

Email address: Data.Protection@fitts.io.

Telephone number: +44 (0) 203 855 0750.

Postal Address: Data Protection Officer, FITTS Limited, 20 – 22 Wenlock Road, London, N1 7GU.

 

  1. Changes to this Privacy Policy

We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up to date.

This Privacy Policy was first updated on 1st July 2020.

This Privacy Policy was updated again on 2nd December 2020.