Privacy Policy

PRIVACY
POLICY

Effective Date: 21 October 2020

Sister takes your privacy seriously where we deal with your personal information. This privacy policy describes how Sister will collect, store and use your information in connection with your use of the website at www.sister.net (“our Website”).

References to “Sister”, “us”, “we”, “our” in this privacy policy means Sister Holdings Limited, a company registered in England and Wales under number 12111207 whose registered office is at 34 Park Street, London, England, W1K 2JD, together with its subsidiaries. Sister Holdings Limited is the data controller of information processed under this privacy policy.

You have the right to object to us using, sharing or carrying out processing of your information in certain circumstances, including using your information for direct marketing. Please contact us at any time using the contact details provided below for more details and to exercise this right where applicable.

WHAT PERSONAL INFORMATION DO WE COLLECT ABOUT YOU?

We collect and process your information in the following ways:

Information you give us

You give us information about you when you contact us or otherwise interact with us, including via our Website, e-mail, letter, phone call or social media.

Information we receive from third parties

We collect information from our other group companies for internal reasons, primarily for business and operational purposes, and we ensure your information is used in line with this privacy policy.

Information we collect automatically

We collect certain information by automated means, such as cookies and web beacons, whenever you visit our Website. This could include IP address, browser type, operating system, referring URLs, information on actions taken on our website, and dates and times of website visits. You can find more information about our use of cookies in our Cookie Policy.

HOW DO WE USE YOUR PERSONAL INFORMATION?

To provide a requested service or carry out a contract with you

To perform any contract entered into between you and us.

Where we have a legitimate interest

To investigate and address enquiries, questions and complaints and respond to any feedback.
To compile statistics about the behavior of our website visitors and other users of our services.
To assist in the effective resolution of disputes.
To develop and improve our engagement with you.
To ensure effective operational management and internal administration of our business, document retention, compliance with regulatory guidance and exercise or defence of legal claims.
To enforce any agreement we have in place with you, or to protect the rights, property, safety, or security of Sister Holdings Ltd, third parties, users of our services or the public.

Where we have a legal obligation

Where we are under a duty to process your information, in order to comply with (and/or where we reasonably believe we are under a duty to comply with) any legal obligation.

Where we have your consent

For any purpose where we specifically ask for your consent.

Where we rely on legitimate interest for processing your information, we carry out a ‘balancing test’ to ensure that our processing is necessary and that your fundamental rights of privacy are not outweighed by our legitimate interests, before we go ahead with such processing. You can find out more about the information in these balancing tests by contacting us using the details below.

HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION FOR?

We only retain your information for as long as is necessary for us to use your information as described above, where it is in our legitimate interest, or to comply with our legal obligations. However, please be advised that we may retain some of your information after you cease to use our services, for instance if this is necessary to meet our legal obligations, such as retaining the information for tax and accounting purposes.

When determining the relevant retention periods, we will take into account factors including:

(a) our contractual obligations and rights in relation to the information involved;

(b) legal obligation(s) under applicable law to retain data for a certain period of time;

(d) statute of limitations under applicable law(s);

(e) (potential) disputes;

(f) if you have made a request to have your information deleted; and

(g) guidelines issued by relevant data protection authorities.

Otherwise, we securely erase or anonymise your information where we no longer have a legitimate reason for keeping it.

WHO DO WE SHARE YOUR PERSONAL INFORMATION WITH?

We share your personal information with trusted third parties where we have retained them to perform services on our behalf, such as professional advisors (including our lawyers and accountants), service providers (including our communications agency and website design agency), IT consultants carrying out testing and development work on our Website, and analytics and search engine providers that assist us in the improvement and optimisation of our services.
We share your personal information with our other group companies for internal reasons, primarily for business and operational purposes.
Where required we share your personal information with third parties to comply with a legal obligation; when we believe in good faith that an applicable law requires it; at the request of governmental authorities conducting an investigation; to verify or enforce our Website Terms and Conditions or other applicable policies; to detect and protect against fraud, or any technical or security vulnerabilities; to respond to an emergency; or otherwise to protect the rights, property, safety, or security of third parties, visitors to the our website, our business or the public.
We share your information where you give us express permission to share your information in the course of your relationship with us from time to time.
As we continue to develop our business, we may sell or purchase assets. If another entity acquires us or merges with us your personal information will be disclosed to such entity. If any bankruptcy or reorganisation proceeding is brought by or against us, all such information will be considered an asset of ours and as such it is possible they will be sold or transferred to third parties.

WHAT HAPPENS IF YOU DO NOT PROVIDE US WITH THE INFORMATION WE REQUEST OR ASK THAT WE STOP PROCESSING YOUR INFORMATION?

If you do not provide the personal information necessary, or withdraw your consent for the processing of your personal information, where this information is necessary for us to provide services to you, we will not be able to provide these services to you.

DO WE MAKE AUTOMATED DECISIONS CONCERNING YOU?

No, we do not carry out automated decision making.

DO WE USE COOKIES TO COLLECT PERSONAL DATA ABOUT YOU?

To provide better service to you on our websites, we use cookies to collect your personal data when you browse. See our Cookie Policy for more details.

DO WE TRANSFER YOUR PERSONAL INFORMATION OUTSIDE THE UK AND EEA?

In certain circumstances we may transfer your information outside of the UK and EEA. For example, when we use cloud-based solutions your data may be hosted on servers located outside of the UK and EEA, including in the USA, Singapore, Brazil, Russia and Australia. Where we transfer your information outside of the UK and EEA, we rely on appropriate safeguards permitted by UK data protection law for such transfers, such as the standard contractual clauses issued by the European Commission.

If we intend to transfer your information to any additional countries, we will update this privacy policy to reflect such overseas transfers.

WHAT ARE YOUR RIGHTS?

By law, you have a number of rights when it comes to your personal information. Please contact us using the contact details below to exercise any of your rights. Further information and advice about your rights can be obtained from the data protection regulator in your country.

Rights	What does this mean?
The right to object to processing	You have the right to object to certain types of processing, including processing for direct marketing (i.e. if you no longer want to be contacted with potential opportunities).
The right to be informed	You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we’re providing you with the information in this Policy.
The right of access	You have the right to obtain access to your information (if we’re processing it), and certain other information (similar to that provided in this Privacy Policy). This is so you’re aware and can check that we’re using your information in accordance with data protection law.
The right to rectification	You are entitled to have your information corrected if it’s inaccurate or incomplete.
The right to erasure	This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your information where there’s no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions.
The right to restrict processing	You have rights to ‘block’ or suppress further use of your information. When processing is restricted, we can still store your information, but may not use it further. We keep lists of people who have asked for further use of their information to be ‘blocked’ to make sure the restriction is respected in future.
The right to data portability	You have rights to obtain and reuse your personal information for your own purposes across different services. For example, if you decide to switch to a new provider, this enables you to move, copy or transfer your information easily between our IT systems and theirs safely and securely, without affecting its usability.
The right to lodge a complaint	You have the right to lodge a complaint about the way we handle or process your personal information with your national data protection regulator. See details of the UK data protection regulator in the contact section below.
The right to withdraw consent	If you have given your consent to anything we do with your personal information, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your personal information with your consent up to that point is unlawful). This includes your right to withdraw consent to us using your personal information for marketing purposes.

We usually act on requests and provide information free of charge, but may charge a reasonable fee to cover our administrative costs of providing the information for:
• baseless or excessive/repeated requests, or
• further copies of the same information.

Alternatively, we may be entitled to refuse to act on the request.

Please consider your request responsibly before submitting it. We’ll respond as soon as we can. Generally, this will be within one month from when we receive your request but, if the request is going to take longer to deal with, we’ll come back to you and let you know.

WILL WE UPDATE THIS PRIVACY POLICY?

We may periodically make changes to this privacy policy. We will notify you of any significant changes where we have a relationship with you and otherwise post updated versions on our website at www.sister.net/privacy

HOW CAN YOU CONTACT US?

If you have any queries or requests concerning this privacy policy or how we handle your information more generally, please get in touch with us using the following details:

· Email: dpolondon@sister.net
· Post: FAO Web Team, Sister Holdings Limited, 34 Park Street, London, England, W1K 2JD

If you are not satisfied with our response to a complaint you have made, or think we are not complying with data protection law, you can make a complaint to the UK data protection regulator who can be contacted as set out below:

Address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF
Phone number: 0303 123 1113
Website: https://ico.org.uk/make-a-complaint