Definitions

In this policy the definitions below shall have the following meanings:

We, Us, Our, Company refers to Comm21 Ltd.

Comm21, Comm21 Ltd refers to Comm21 Ltd whoes principal place of business is at The Belfry, Solent Business Park, Fareham, Hampshire. PO15 7FJ. Comm21 are a registered company in England, UK at the principle place of business address. The Company registration number is 06534439, and the VAT number is 941648704.
Comm21 are responsible for this Service and not necessarily the products and services that are mentioned and configured on the Service as defined by the Portal.

Keep21 is the online Service available to You as permitted by Comm21 or a Portal. Keep21 has been developed and is maintained by Comm21.

Portal, Portals are companies, organisations and other business entities that have been granted permission and a license by Comm21 to use Keep21 for their own Customers in accordance with the standard terms and conditions of this Service.

You, Your, User, Customer, Customers referes to the user of this Service granted by Comm21 or a Portal.

Data means any personal or company information, and information about the products and services We supply to You. This Data is either submitted by Us or You and is stored in (but not limited to) our computer systems, or paper retrieval systems.

Service, Site means collectively the online web site, tools, services or information Keep21 makes available to You now or in the future.

Account means a personal means of accessing the Service by using personal login details such as an E-mail address and secure password.

Background

Keep21 operates a Data Protection Policy as We believe that Data Protection is important to everyone. You can be secure in the knowledge that We will ensure the highest security in holding Your personal data.

Data Collected

Without limitation, any of the following Data may be collected:

• Company name;
• Your name;
• Your telephone;
• Your E-mail address;
• Demographic information such as address and post code;
• IP address (and if available your geographical location based on this) (automatically collected);
• Information about your web browser and operating system (automatically collected);
• URL of the site you entered Keep21 (automatically collected);

Use of Data

• We only collect Data from You where We deem it be useful, necessary and required to provide you with a suitable Service. We don't collect data for the sake of collecting data that will never be used.
• Data is predominently collected and required to provide You with the Service. It is also collected for statistical purposes and to judge where we can improve the Service.
• Unless We are obliged to (by any applicable law), and subject to the Third Party Web Sites and Services clause, your data will not be disclosed to third parties.
• Your data may be shared between other companies within Our group or close affliliates whereby they require oversight of Your information to provide You with a suitable service.
• All Data is stored in accordance with the principles of the Data Protection Act 1998. For more details on security see our clause on Security below.
• Internal record keeping.
• Improvement of our products and services.
• Transmission by E-mail promotional materials that may be of interest to you.

Third Party Web Sites and Services

We may from time to time employ the services of other parties for dealing with matters that may include, but not limited to, delivery of purchased goods, maintenance and support of products and services, advertising and marketing. These third parties do not have all encompasing access to all Your Data, instead they are provided with the necessary data required by them to perform the services that We may request for You. Furthermore, any Data that is processed by the third parties must be processed in accordance with these terms and in accordance with UK law.

Examples of third party companies who may require access to Your Data include (but not limited to) phone system maintainers such as Comm21 Ltd and network providers such as BT and Opal.

Examples of Data disclosed to these third parties and affilicates includes (but not limited to) your name, company name, on-site contact details and postal address and E-mail address.

Google Analytics

We like many other organisations employ the services of Google Analytics to provide us with detailed statistical information about our web site visitors browsing patterns and Web browser capabilities. Google Analytics is used on all web pages where we display information to You. Google Analytics will only operate if Javascript and Cookies are enabled in Your Internet Browser. Google are developing an Opt-Out plug in that will enable you to prevent Google Analytics from analysing your visit to this Service. Google Analytics can also be disabled by disabling Cookies in Your Internet Browser. Your Details about your Internet Web Browser, ISP, IP address, time of visit are collected automatically. Information that is collected for Google Analytics does not include personalised identifiable information such as names, E-mail address or telephone numbers.

Cookies

A cookie is a small text file that stores itself on your computer's hard drive.

Keep21 uses cookies where You ask us to keep you logged into the Service from the main login screen. In this instance We simply store a unique secure ID on your computer that allows you to remain logged into the Service. This secure ID is created at the time You first login to the Service with the "keep me logged in" checkbox checked.

Your Internet browser settings determine whether cookies are allowed, and for how long. We don't employ use of any tracking cookies apart from Google Analytics which analyses traffic whilst on Our site only, or any other type of cookie that contains personally identifiable information.

Cookies can be deleted using your Internet Browser's settings to remove them at any time. Disabling or removing Cookies will not severly impact the Service or Your experience of using the Service.

Change of Ownership

Comm21, who presently own and operate Keep21, may expand and or reduce its business and this may involve the sale of all or some of Comm21's divisions to other parties. Data may be transferred to the other party if Comm21 or Keep21 is transferred onto them, where this data is required to continue providing your with a suitable Service.

In the event that Data is transferred in such a manner, You will be notified in advance and informed of the changes. You reserve the right to request that Your data be removed so that the new owner or controller do not have visibility of this. However, your Service may cease to function if you withold your Data to the new owner or controller as they cannot provide you with the Service.

Your Right to Withold Information

• We will not store any information that you inform us not to. However, We may not be able to provide you the Service where We don't have a minimum amount of required Data for the Service and associated actions to be performed. You may or may not be notified of any disadvantages of witholding certain Data.
• However, certain Data is retrieved automatically and We have no method of preventing this. E.g. Data such as log files created on the web server when You visit the web site or Cookies in relation to Google Analytics.
• Forms on the Web site specify which are the required fields, and which fields You must fill in. Those fields that are not marked as required, are those that you don't need to fill in.

Accessing Your Own Data

• Most of your Data is freely shown to you by the Service. However if you require knowledge of any further information We may hold on You, then you are requested to make a Subject Access Request (SAR) in Writing to Us.
• If a SAR is sought, We must verify that You are authorised to view the Data in question by verifying Your identity.
• A response to a SAR will be given within 40 days after receiving the request in writing.

Security

Access to the web site is secured by a valid E-mail address and password that enables You to access Your company's account.

There is a strict password policy applied on all accounts, that requires you have at least: 7 characters, at least one UPPER case character and at least one numeric character.

Your company's account is only visible to Us and Your accounts that We or You have created. It is not accessible to other users.

Your passwords are not stored in plain text in Our computer systems. They are one-way encrypted.