Privacy & Cookies Policy
v1.0 – Last Updated 14/09/2019
Overview
In order for us to operate our business and provide our services to You, it is sometimes necessary for us to collect or process information about You. In general terms, this information will take one or more of the following forms:
- Information that you provide to us directly, such as in the situation where you complete an online form or send us a message via our website;
- Information that is automatically sent to us by Your computer’s internet browser when you visit our website, such as your computer’s technical address (or ‘IP address’) or information about which particular internet browser you are using and so on;
- Information about how you use our website or our services, such as which pages you visit, how frequently you visit the site and so forth.
Our commitment to data privacy
We are fully committed to maintaining the privacy of any information (‘personal data’) that you provide to us. Furthermore, we commit to ensuring that such data is held securely, used appropriately and only retained for as long as is necessary.
Our systems and services are designed with privacy in mind, and we operate a ‘data minimisation’ principle wherever possible – that is to say that we will only ever ask you for the minimum amount of information required to provide our services efficiently; we have no desire to retain (and therefore maintain) any more information than is necessary. We aspire to comply to the fullest extent possible with applicable data protection regulations, in particular the European Union’s General Data Protection Regulation (‘GDPR’) and ePrivacy Directive, where applicable.
Who we are
In terms of your use of this website, We, SenBa Solution, act in the capacity of Data Controller, and should you have any questions or concerns about the data we hold about you, we can be contacted using the information below:
Data Controller: SenBa Solutions
Correspondence address: P. O. Box CE 12201, Tema, Ghana
Email correspondence: info@senbasolutions.com
Definition of ‘personal data’
When we refer to ‘personal data’ we mean any information that allows us to identify you personally. Obvious examples include your name, email address, postal address etc. We will always seek to gain your explicit consent to providing this information before we collect it from you, although this may not be the only legal basis on which we collect the data. Other types of information, such as your computer’s ‘IP’ address or broad geographical location do not, generally, allow us to identify you directly. However, because in their current form, European data privacy regulations are somewhat vague in this regard, we will cover the use of such data here also.
Who we share data with
We operate on a strict ‘need to know’ basis for all data that we work with, and that is particularly true for any personal data. The only people/organisations that are granted access to personal data are:
- Employees of Senba Solutions who provide design and/or support services;
- Defiant Inc, the providers of the Wordfence™ security software that protects our website. Only limited, technical data (such as device IP address, browser type/version, language etc) are transmitted.
We have signed Data Privacy Agreements with all of the 3rd party technology suppliers above which detail our respective responsibilities for data security. In all cases where our 3rd party service providers have an establishment outside of the European Economic Area (EEA), we ensure adequate protection of personal data via the accepted EU Model Contract Clauses or EU-US Privacy Shield framework.
How your data is protected
We take the security of all personal data very seriously, and that data is protected in a number of ways:
- Access control: access to personal data is strictly limited in line with our policy detailed in the ‘who we share data with section’ on this page. Access is controlled by individual user accounts, where a strong password policy is enforced
- Dedicated security software: We operate dedicated security scanning and access control software on all of our websites. This software is responsible for limiting login attempts to our site, blocking potentially malicious attempts to access our services, and regularly performing full file system scans.
- Data encryption: where data is stored in a cloud facility (such as the storage of website backup files), that data is encrypted both ‘in transit’ and ‘at rest’ – meaning that all data is securely obscured both during the process of transfer to the cloud provider, and then additionally when it is in storage at its final location.
This website is also secured with SSL encryption, which means that all traffic to and from our servers is encrypted. This applies to our own administrative access to the website as well as that of users of our services.
Additionally, we ensure that our own dedicated secure Virtual Private Network (VPN) is used when we access the site from anywhere on a public wifi network.
- Selection of third party service providers: we use a very limited number of third party service providers, but some are essential for the provision of physical hosting environments and cloud services. One of the core factors in the selection of such providers is their ability to provide secure systems and processes. We have written Data Processing Agreements with each of our core service providers that sets out the requirements for data security.
Access to your personal data
In the situation where you have directly provided personal information to us (such as by completing an online form or contacting us for further information), you have a number of rights regarding the personal data that we hold:
- You have the right to obtain from us confirmation about whether any such data is being held;
- You have the right to require that we provide you with whatever data we are holding/processing about you, including the right for that data to be transferred to another data controller;
- Even if you have consented to Us processing your personal data, you have the right to withdraw that permission at any time;
- You have the right to require us to rectify any incomplete or incorrect information held about you;
- You have the right to require us to erase the data held about you (the ‘right to be forgotten’);
In the situation where we collect personal data automatically (such as from your internet browser or via internet Cookies or other similar technologies):
- You have the right to object to the legal basis upon which we are collecting this data, and We have an obligation to consider and respond to that objection;
- You have the right to request the prevention of further processing of your data while your objection is considered;
- You have the right to make a complaint to the relevant data protection authority
- In most circumstances, you can exercise these rights without paying a fee to us.
Types of data collected
Website contact forms
When you complete one of the contact forms on our website, we will ask you for a number of pieces of personal information, such as your name, email address and other contact details. This is obviously required for us to respond to your request. If you do not use or submit an online form on the website, no data will be collected in that regard.
Account logins
For some website functionality, we will need to create for you a user account that allows you to login to the site to ensure that only authorised individuals can access your data and that functionality. Examples include when you make an online purchase via the site, or when you have a role in administering or contributing towards the website content (such as a blog author). The purpose of these user accounts is to protect your personal data behind login security, and to protect the integrity of our site and the servers that run it.Data collected will generally involve your name and email address (which doubles as username) as a minimum, but may include your postal address if it is required for online purchases.If you do not register for an online account then no such data will be collected in this regard.
Technical data (such as ‘IP address’)
When you visit our website, our systems will log a record of your visit in our server logs, and typically this record will include the technical ‘IP’ address that is associated with your device and the browser type and version that you are using.
Such server logs are extremely common practice, and are used to monitor technical resources, monitor high-level server activity, and importantly to detect and prevent malicious or fraudulent activity on our systems. This data can also be used, if required, to diagnose reports of technical issues. The storage of IP addresses, allow us to identify patterns of behaviour (such as repeated malicious attempts to access a system).
IP addresses, in and of themselves, do not allow us in any way to identify you as an individual, especially given that it is very common for IP addresses to be dynamically allocated by your service provider, and will therefore often routinely change.
Furthermore, we do not and will not use the content of server access logs to attempt to determine an identifiable individual. We therefore do not consider that data held within server logs falls within the scope of ‘personal data’, and accordingly we do not seek your consent to collect it.
Cookies & ‘similar technologies’
We have included cookies, web beacons and similar technologies into one section because they all perform similar functions even if, from a technical perspective, they work slightly differently. All of these technologies allow us to better understand how users are using our website and other related services. They can also be an essential part of providing certain online functionality. They are all essentially small data files placed on your computer (or other device) that allow us to tell when you have visited a particular page, or performed a particular action (such as clicking a particular button) on our website. These technologies are used by most websites as they provide useful insight into how the services are being used, as well as improving speed, performance and security, and enabling us to improve our personalisation of your experience.
Cookies
These are small text files placed in the memory of your browser or device when you visit a website. Cookies allow a website to recognize a particular device or browser. There are several types of cookies:- Session cookies expire at the end of your browser session and allow us to link your actions during that particular browser session.
- Persistent cookies are stored on your device in between browser sessions, allowing us to remember your preferences or actions across multiple sites.
- First-party cookies are set by the site you are visiting.
- Third-party cookies are set by a third party site separate from the site you are visiting.
Web beacons
– Small graphic images (also known as “pixel tags” or “clear GIFs”) that may be included on our sites and services that typically work in conjunction with cookies to identify our users and user behaviour.Website Analytics
We use Google Analytics to better understand what people look at on our website.When people visit our site, information about their visit (such as which pages they look at, how long they spend on the site and so on) is sent in an anonymous form to Google Analytics (which is controlled by Google).The data contains information about anyone who uses our website from your computer, and there is no way to identify individuals from the data.We ensure that no personally identifiable information is ever contained within the data sent to our analytics providers, and we also perform a process which partially obscures your IP address information.As analytics information is not personal data, we do not specifically ask for your prior consent.
Other Google Services
In addition to Google Analytics, we use a number of industry-standard Google services to provide particular pieces of website content. These include:
- Google Fonts: We may use one or more of Google’s web fonts to ensure that our website content is displayed in a clear and consistent fashion across all of the different types of devices and browsers.
- Google Maps: We may use the Google’s mapping services to provide dynamic geographic maps on our website
- Google Recaptcha: We may use Google’s Recaptcha service (which provides the ‘I Am Not A Robot’ functionality) on our web contact forms. This is a security measure to prevent the abuse of our contact forms by automated programs.