Privacy Policy 2021-06-02

Hi 👋

We’re Attest Technologies Limited. We own and operate the technology, tools and services made available to you via out websites and the Attest Platform (the ‘Attest Services’).

When operating the Attest Services, we exercise overall control over how your information is collected and used, including personal information. As a data controller, we understand it’s really important for you to know how we’re using your information and we’re committed to protecting and respecting your privacy.

If you have any questions about this policy or would like to exercise any of the rights set out within, you can email us at dataprotection@askattest.com.

Who are you?

The information we collect and use depends on who you are. Select the relevant category below to find out how we may collect, use and share your information.

The categories of information that we collect, store and/or process are set out below with some examples of what’s included:

Contact → your name, email address, phone number, job title, etc.

Financial → your bank details or billing information. All payments made on our website are processed via a third party payment provider and your details will be processed in accordance with their own privacy policy, Attest does not store or process any of this information. See Braintree and Chargebee.

Account → username, password, feedback etc.

Usage → information about how you use our website, products and services

Survey → your survey questions and responses received

Technical → IP address, login data, browser type and other technology on the devices you use to access the platform. We use cookies and other tracking technologies in order to collect this information, you can find out more about this here.

The above information will be collected regarding the individual who signed up for an Attest account, as well as any other users attributed to the account (for example, on business accounts where other company users have access).

Direct interactions → We’ll collect your contact and financial information when you sign up for the Attest Services or submit your information to us via an online form or request to contact you. We’ll collect your survey information as you use the Attest Services.

Automated technology or analytics → As you use our website or the Attest Services, we’ll automatically collect technical and usage information by using cookies and similar technologies.

Third parties or publicly available sources → We use third parties who provide us with information from Companies House or other publicly available sources to enable us to contact you. We may also collect information from third parties who provide a service to us. Find out more about our service providers below.

Why do we need your data?	Type of information	Legal basis
To create and manage your account with us.	Contact Financial Account Usage	We need to process your personal information in this way to perform the contract to register you and provide ongoing account services and benefits to you such as access to our Client Expertise team. We’ll also use this information to provide you with important service or legal updates.
To enable additional account users on company accounts.	Contact Account	Same as above ^ 🎉
To send you communications, including information about products or services we think may be of interest to you.	Contact Usage Technical Account	We’ll send you certain transactional emails, for example, confirmation of registration or survey purchase. These emails enable us to perform the contract to provide you with the Attest Services. We’ll also send you communications to promote our services and provide useful product updates. We’ll always give you the right to opt-out of these communications if you’d prefer not to receive them.
To gather information about how you and other users are interacting with the Attest Services.	Usage Technical	We process your data for this reason because we have a legitimate interest to continuously assess and improve the Attest Services for all customers. We also use this information to provide you with relevant and interactive guidance when you use the Attest Services.
To help us manage and promote our business, e.g. in relation to our financial performance, customer base, product range or other efficiency measures.	Technical	For our legitimate interests or those of a third party, i.e. to promote our business and be as efficient as we can so we can deliver the best service to our customers. Where such data is collected by cookies, you will be able to opt in or out of non-essential cookies.

We collect very limited information about you, which is set out below. Survey Creators are prevented from collecting any personal information about you under the terms they agree to in order to use the Attest Services (for example, you should never be asked to input your name or age into a survey). If you are ever asked for this type of information, please contact us immediately at dataprotection@askattest.com.

You might be wondering how you receive surveys via the Attest Services because you don’t remember signing up to Attest or providing us with any information previously. That’s a great question! In order to provide the Attest Services, we partner with a number of trusted panels who connect you to the surveys created by our Survey Creators. Those partners will hold your personal details and you should contact them if you’d like to understand more about the information they hold.

The categories of information that we do collect, store and/or process are:

Usage → information about how you use our website, products and services

Survey → your survey responses

Technical → IP address, browser type and other technology on the devices you use to access the platform. We use cookies and other tracking technologies in order to collect this information, you can find out more about this here.

Automated technology or analytics → As you respond to surveys (hosted on the Attest Services), we’ll automatically collect technical and usage information by using cookies and similar technologies. This includes your IP address, which may be personal information if it can be used to identify you. We’ve set out some more information about this below.

We collect the above information (Usage, Survey and Technical) in order to provide the Attest Services. We collect your survey responses so these can be shared with Survey Creators to allow them to complete their surveys. We’ll also store certain information regarding how you use the Attest Services for our legitimate interests; so we can continuously improve our services and deliver the best service to our customers.

We’ll use your technical information in order to provide the Attest Services, for example, we might use information relating to your device so Survey Creators can send surveys out to users of certain devices. We also use this information to make sure we can tell which answers match each Respondent. We do not link usage or technical data in any way that would identify individual Survey Respondents.

We may collect the following information about you:

Contact → your name, email address, phone number, job title, etc.

Usage → information about how you use our website, products and services

We’ll collect your information in a number of ways, directly or indirectly. For example:

Direct interactions → for example, when you sign up for an Attest event, ask for a follow up on web chat, book an intro or request content from us.

Automated technology or analytics → as you use our website or the Attest Services, we’ll automatically collect technical and usage information by using cookies and similar technologies.

Third party sources → we work closely with third party advertising networks, analytics providers, hosting providers and search information providers from whom we may receive general aggregated anonymous information about you. We also use demand generation tools to find email addresses, for example, of people we believe to be decision makers and who we can contact in companies that may benefit from the Attest Services.

Why do we need your data?	Type of information	Legal basis?
To understand how the Attest Services are used and what we could do to improve them, for example, using A/B testing to analyse the most effective improvements we can make to the website.	Usage Technical	We have a legitimate interest to continuously assess and improve the Attest Services for all customers. Where such data is collected by cookies, you will be able to opt in or out of non-essential cookies.
To make our site more secure, to administer our site and for internal operations, including troubleshooting.	Usage Technical	We have a legitimate interest to ensure that our site is kept secure.
To provide you with support tools, including online chat functions.	Contact Usage Technical	We process your data in order to determine whether you are an existing customer and therefore to ensure we are providing the contracted services to you, or whether you are a prospective customer so we can follow up with you about specific questions you have asked or rely on our legitimate interest to follow up with you if we think you may be interested in the Attest Services.
To share content with you, such as reports, guides, information about events.	Contact Usage Technical	We’ll use the information we collect in order to provide the relevant services to you. For example, if you’ve signed up to receive a newsletter, we’ll use your information to send you that newsletter and other materials we think may be of interest to you. You will always have the option to opt out of these communications and you can do so by clicking the unsubscribe link at the bottom of an email or by contacting us at [dataprotection@askattest.com]. We send you communications like this because of our legitimate interest to promote the success of Attest.
To identify and contact potential future Survey Creators who we believe may benefit from the Attest Services.	Contact	We have a legitimate interest to promote the success of Attest by engaging in methods to increase our customer base.
To analyse the effectiveness of marketing campaigns.	Contact Usage Technical	We may use your information to understand whether marketing campaigns, for example, have been successful. For example, we may use Technical information to determine how many leads came to our website from a particular marketing asset, which helps us to determine what has been successful and what we can do to improve.

If you’re attending an event, we’ll use your information to build up our guest lists so we can tailor the event to the specific audience. We may share your company name, name and/or role with organisations hosting the event and/or other individuals who attend our events. We’ll process your personal information in this way either because we have a legal obligation to provide the delegate list for health and safety reasons or because we have a legitimate interest in promoting the success of the event and the Attest Services. We’ll never share your email address in either of these cases without your consent or informing you in advance.

During events, we may take photographs or film the events. Where this is the case, we will display notices or advise event attendees in advance that photography or filming may take place, with information as to how you can let us know if you’d rather not be photographed or filmed.

Like most tech businesses, we do share your information with third parties where it is required in order to provide the Attest Services (for example, to host our platform, communicate with you and provide in platform advice) but only where we have appropriate safeguards in place.

We do not allow the collection of any personal information within our surveys. We will, of course, share survey information between Survey Creators and Survey Respondents so that surveys can be completed.

For Survey Respondents, we’ll only ever share the responses you give to surveys with Survey Creators. The responses are anonymous, so we’ll never share any personal information about you as mentioned earlier. Survey Creators determine how to use the content from the responses you provide so anything you put as a response will be shared. Please don’t ever provide personal information and remember, you can skip a question if you don’t feel comfortable answering it.

For Survey Creators, we’ll only ever share the surveys you put together with Survey Respondents to allow them to provide survey responses. We’ll never share your Survey Questions or the responses received to them with anyone else (unless you explicitly request us to do so or consent to us doing so).

We use a number of third party service providers to help us provide the Attest Services. In order to do this, we may have to provide some of your information to them and we will only ever do this to the extent necessary to provide services to you and only when we have contractual provisions in place to ensure your information is securely held and not used for any other purpose. We’ve set out a list of the main service providers we may share data with in order to provide the Attest Services here.

Where you are using the Attest Services as part of a company account, we may share any information regarding your usage of the account with other authorised members.

We might share aggregated information with third parties to improve or promote the Attest Services. This information will always be anonymous, ensuring that no individual could be reasonably identifiable or linked to any part of the information we share.

We may share your information with Attest companies in order to provide the Attest Services. For example, we share information with local entities generating sales and building Attest Services within other countries, such as Attest Technologies, Inc in the USA. All Attest companies are subject to this privacy notice.

If we were to sell all or part of any of our business or assets, we will provide or transfer your personal information to the buyer (provided this is done in accordance with relevant data protection laws). We’ll do this because we have a legitimate interest to ensure our business can be continued by the buyer. If you object to our use of your personal information in this way, the buyer of our business may not be able to provide services to you.

There are some circumstances where we have to share your information because we either have a legal obligation to do so or it’s necessary in order to protect ourselves and other users of the Attest Services. We will only do so where we reasonably believe it is necessary to comply with laws and regulations, requests from a governmental or law enforcement agency, to protect the security of the Attest Services or, where necessary, to enforce our legal agreements.

Cookies

You can find out all about the use of cookies within the Attest Services in our Cookies Policy.

Other websites

Our site may connect you to different websites with their own privacy policies. We do not accept any responsibility or liability for these policies or websites and you should check their policies before submitting any personal information.

Where do we store and transfer your data?

All information you provide to us is stored on our secure servers or those of our third party data storage providers. We currently use Amazon Web Services and data is stored on servers located in Dublin.

The information we gather from you may be transferred to, and stored at, a destination outside the European Economic Area (EEA). For example, we may transfer data to one of our offices located outside the EEA or to service providers located in the United States. Where this is the case, we always ensure your information is treated appropriately by putting in place at least one of the following safeguards:

using specific contracts approved by the European Commission which give your personal information the same protection it has in the EEA; and
where we use providers based in the US, relying on Standard Contractual Clauses or other lawful measures in order to protect personal information shared between Europe and the US.

How long do we keep your data for?

We’ll keep your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any accounting or legal requirements.

To determine the appropriate retention period for the personal information we hold, we consider the amount, nature and sensitivity of the personal information, the risk of harm from unauthorised use or disclosure of your personal information, the reasons why we handle your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

We may anonymise your personal information so that it can no longer be associated with you for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Security

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Your privacy rights

When using the Attest Services, you have the right to:

access personal information (also known as a “subject access request”);
correct incomplete or inaccurate personal information we hold about you;
ask Attest to erase the personal information we hold about you;
ask Attest to restrict its handling of your personal information;
ask Attest to transfer your personal information to a third party;
object to how Attest is using your personal information; and
withdraw your consent to Attest handling your personal information.

You have an absolute right to ask us to stop processing your personal information for the purposes of direct marketing.

If you are resident in California, you have certain rights afforded to you under the CCPA. The categories of personal information we collect, where we collect it from, the business purpose for collecting it and any third parties we may share this information with is already set out in this policy.

We do not sell your personal information and we will not sell it without providing you the right to opt out.

You will not be discriminated against for exercising any of the above rights. Where you do so, we are required to verify your request using information associated with your Attest account (for example, your email address).

What to do if you’re not happy with this information?

If you’re not happy with the information we’ve set out here, please let us know so we can try to resolve your query or concern. You may also have the right to complain to a data protection authority. In the UK, you can contact the Information Commissioner’s Office here.

Updates to this policy

Any changes we make to our privacy policy in the future will be posted on this page and, where significant, notified to you by email. Please check back frequently to see any updates or changes to our privacy policy.

This policy was updated on 03/06/2021

Update

Updates to this policy

As of June 2021, our Privacy Policy has been completely refreshed and re-written to ensure it is clear and transparent for our customers. Going forward, any changes made to the Privacy Policy will be identified here.

Service providers

This table sets out the key service providers used by Attest, and may be updated from time-to-time.

Service Provider	Purpose	Location	Relevant to
Amazon Web Services	AWS hosts all Attest sites and databases	Location Ireland	Relevant to
Braintree (PayPal)	Payments tool used on Attest website	Location USA	Relevant to
Calendly	This tool is used for prospects to register interest on the Attest website	Location USA	Relevant to
Chameleon	This tool enables us to provide you with guides in the Attest Platform	Location USA	Relevant to
Chargebee	This is a recurring payments tool, connected to Braintree for subscription payments	Location USA	Relevant to
DocuSign	This tool is used to send out contracts for customers to sign electronically	Location Ireland	Relevant to
Gainsight	This tool is used for customer management and success	Location USA	Relevant to
Gotowebinar	This tool is used to host webinars for prospects and existing customers	Location E.U.	Relevant to
GSuite	Business platform used by Attest	Location USA	Relevant to
Intercom	This tool enables website users and customers to message Attest	Location USA	Relevant to
Jiminny	This is a call recording and training tool used by our customer teams	Location USA	Relevant to
Looker	This tool is used for business intelligence	Location USA	Relevant to
Mailchimp – Mandrill	This tool is used for sending transactional and customer emails	Location USA	Relevant to
Pardot	This is our marketing & communications platform	Location USA	Relevant to
Snowplow	This tool is used to improve user experience on the Attest platform	Location USA	Relevant to
Salesforce	This is our client relationship management tool.	Location USA	Relevant to
Salesloft	This is a sales engagement platform	Location USA	Relevant to
Smartlook	This tool is used to analyse user data on the Attest website	Location E.U.	Relevant to
Xero	This is a business accounting platform, use to send invoices	Location USA	Relevant to
Zoom	This tool is used to for remote meetings/conferencing	Location USA	Relevant to

Privacy Policy 2021-06-02

Who are you?

Who does Attest share my information with?

Cookies

Other websites

Where do we store and transfer your data?

How long do we keep your data for?

Security

Your privacy rights

What to do if you’re not happy with this information?

Updates to this policy

Updates to this policy

Service providers