Privacy Notice

Foundation SP Limited (“FSP”, “we”, “us”, and “our”) are committed to respecting and protecting your personal information. This Privacy Notice describes your privacy rights regarding our collection, use, storage, sharing, and protection of your Personal Information and it applies to the Foundation SP websites: www.foundation-sp.com, www.pulse360.io and all related websites, applications, services, and solutions, regardless of how you access or use them (collectively, the “Site”).

FSP Engage (FSP’s client portal), the Pulse 360 Platform and the Pulse 360 mobile application, collectively known as the “Services”. By using our Services, you are accepting and consenting to the practices described in this Privacy Policy.

Information obtained by FSP

We may collect and process the following information about you:

Personal information you provide

You provide us with personal information about yourself by:

  • filling in the contact form on our website;
  • registering to use our products or services;
  • raising an incident or liaising with our support team via our support helpdesk;
  • participating in discussion forums or other social media functions;
  • corresponding with us by telephone, email or otherwise.

The information you give us may include your first name, last name, sign-in name, password, job title, company name, contact phone number, email address, postal address, country and photograph.

Information we collect about you

Each time you use our services we may automatically collect the following information:

  • technical information including the Internet Protocol (IP) address used to connect your computer to the Internet, your log information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform.
  • information about your online activity, which may include your URL, visits to, through and from our services (including date and time), length of visits to certain pages, page interaction information (such as scrolling, clicks and mouse-overs) and methods to browse away from the page, page response times, download errors and any phone number used to call our support helpdesk.
  • when you download and use our Services, we may automatically collect information on the type of device you are using and your operating system version.
  • on devices where location-based services are enabled, we may receive location information (GPS or other signals). You can restrict our access to your device’s location by adjusting the location-based service preferences on your device.
  • we may use mobile analytics software to allow us to better understand the functionality of our services on your mobile device. This analytics software may record information about how often you use the application, from where the application was downloaded, the events that occur within the application, aggregated usage, and performance data. The information stored within the analytics software is not linked to any identifiable personal information you submit within the mobile application.

Information we receive from other sources

Work we complete on behalf of our customers

In some cases FSP has visibility of, handles or migrates personal information, under the direction of its Clients, but we have no direct relationship with the individuals whose personal information we process. FSP works with its Clients to help them notify the relevant parties of the purpose for which their personal information is collected.

An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct their query to FSP’s Client (the data controller). If the Client requests FSP to remove the data, we will respond to their request within 30 days. If you are a customer or employee of one of our Clients and would no longer like to be contacted by that company, please contact them directly.

FSP may transfer personal information to companies that help us provide our service. Transfers to subsequent third parties are covered by the provisions in this Policy regarding notice and choice and the service agreements with our Clients. FSP will retain personal data we process on behalf of our Clients for as long as needed to provide services to our Client. FSP will retain and use this personal information as necessary to comply with our legal obligations, resolution disputes, and to enforce our agreements.

Other services

We may receive information about you if you use any of our other services. In this case we will have informed you when we collected that data that it may be shared internally and combined with the data we have previously collected. We also work with third parties (including, for example, partners, analytics providers, search information providers) and may receive information about you from them.

Cookies

We use cookies on our website to distinguish you from other users of our websites. This helps us to provide you with a good experience when you browse our website and also allows us to improve the website.

Uses made of the personal information

We use the information held about you to:

  • identify you when you sign-in to your account;
  • administer and provide you with the products and services that you request from us;
  • carry out our obligations under any contracts we have entered into with you;
  • keep our services safe and secure;
  • improve our services and ensure content is presented in the most effective manner for you, your computer, browser and mobile device;
  • allow you to participate in the interactive features of our services, when you choose to do so;
  • notify you about changes to our services;
  • conduct internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
  • measure or understand the effectiveness of advertising or promotions we send; and
  • make suggestions and recommendations directly, or via one of our partners, about other goods or services we offer that may be of interest.

If you wish to stop receiving correspondence from FSP please contact GDPR@foundation-sp.com.

Disclosure of your information

Information we share with third parties

We do not sell your information to third parties. We may share your personal information with the third parties listed below, only in the ways that are described in this Privacy Policy:

  • other companies from within our corporate group, for example our ultimate holding company;
  • partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you. For example, we may use service providers, including a customer relationship management software provider, marketing automation provider, website analytics provider, payment services provider, service desk and IT service management service provider, and credit reference agencies. These service providers may need to have access to your information in order to provide their services.
  • analytics and search engine providers that assist us in the improvement and optimisation of our website (information will be disclosed in a non-personally-identifiable form);
  • from time to time we reference personal testimonials of satisfied customers. With your consent we may display your testimonial of our services along with your name.

We will only share your information that is essential for such third parties to provide services on our behalf.

Information we disclose to third parties

We may disclose aggregate statistics about the visitors that use our services in order to describe our services to prospective clients, partners, sponsors and other reputable third parties and for other lawful purposes, however these statistics will include no personal information.

We may disclose your personal data to third parties:

  • if we are required to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms and Conditions or other agreement with you; or
  • in the event that we are involved in a merger, acquisition, or sale of all or a portion of our business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets, subject to the seller or buyer signing a suitable confidentiality undertaking;
  • when we believe in good faith that disclosure is necessary to protect the rights, property, safety, of yourself, our business, our customers, or others. This includes fraud protection, credit risk reduction, or responding to a government request;
  • to any other third party with your prior consent to do so.

Where we store your personal data

The personal data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers or partners. Such staff maybe engaged in, among other things, the fulfilment of the services, the processing of your payment details and the provision of support services. By submitting your data, you agree to this transfer, storing or processing outside of the EEA.

We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy. In particular, this means that your personal data will only be transferred to a country that provides an adequate level of protection (for example, where the European Commission has determined that a country provides an adequate level of protection) or where the recipient is bound by standard contractual clause according to conditions provided by the European Commission (“EU Model Clauses”).

Our website is accessible via the internet and may potentially be accessed by anyone around the world. Other users may access the website from outside the EEA. This means that where you chose to post your data on our website, it could be accessed from anywhere around the world and therefore a transfer of your data outside of the EEA may be deemed to have occurred. You consent to such transfer of your data for and by way of this purpose.

Protection of Information

All information you provide to us is stored on our secure servers. All personal data will be encrypted at rest and in transit between our servers and your browser. We will take all steps reasonably necessary to ensure that your information is treated securely and in accordance with this Privacy Policy. Where we have given you (or where you have chosen) a password which enables you to access certain services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of any information across the Internet cannot be guaranteed to be completely secure. Although we will endeavour to protect your information, we cannot guarantee the security of your information transmitted to our website. 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.

Links to other websites

From time to time, our services may contain links to and from the websites of our partner networks, affiliates and social media platforms. If you follow a link or submit personal information to any other websites, please note that those websites are governed by their own privacy policies and FSP does not accept any responsibility or liability for their privacy policies. We encourage you to read the privacy policy of each individual website you access before providing any information about yourself, and assess whether the policy is satisfactory to you before you use that website.

Your rights

You have the right, free of charge, to request:

  • access to your personal data;
  • rectification or deletion of your personal data;
  • a restriction on the processing of your personal data;
  • object to the processing of your personal data;
  • a transfer of your personal data (data portability);
  • to stop receiving any marketing materials by using the unsubscribe instructions provided, or you can contact us at GDPR@foundation-sp.com

You can make a request in relation to any of the above rights by emailing GDPR@foundation-sp.com or by writing to us at address given at the end of this Privacy Policy. We will respond to such queries and deal with requests we receive from you within 30 days, in accordance with the provisions of the EU General Data Protection Regulation (GDPR) and the Data Protection Act 2018.

Consent

You have the right to withdraw your consent to us processing your personal data, at any time, by writing to us at the contact address given at the end of this Privacy Policy.

Where we process your personal data for marketing purposes, we will inform you and obtain your ‘opt in’ consent (before collecting your personal data) if we intend to use your personal data for such purposes or if we intend to disclose your information to any third party for such purposes. If you change your mind about being contacted in the future, please click on the ‘opt out’ option and we will remove you from our mailing lists.

Data Retention

We retain personal data for as long as necessary for the relevant activity for which it was provided or collected - this will be for as long as you require access to our services. Your account with us will remain open for the period set out in any relevant contract you have with us. However, we may keep some data after your account is closed or you cease using the services for the purposes set out below.

After your account has been closed, we usually delete personal data, however we may retain de-personalised information after your account has been closed. We may also retain personal data where reasonably necessary to: comply with our legal obligations; meet regulatory requirements; resolve disputes; and to enforce our agreements and Terms and Conditions.

If you wish to request we no longer use your information to provide you with our services, please contact GDPR@foundation-sp.com

Privacy Policy changes

We may update this Privacy Policy to reflect changes to our information practices. If we make any material changes we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice via the services we provide you with, prior to the change becoming effective. We encourage you to periodically review this policy for the latest information on our privacy practices.

Complaints or queries

The security of your information is important to us. Our intention is to meet the highest standards when collecting and using personal information. We follow accepted standards to protect the personal information submitted to us, both during transmission and once it is received.

Should you have any concerns regarding this Privacy Policy, you wish to assess or amend your information, or you have any questions about the security of your personal information please contact us via email at GDPR@foundation-sp.com or you can write to us at:

Foundation SP Limited
Reading Enterprise Centre
Whiteknights Road
Reading
Berkshire
RG6 6BU