Semafone Limited Understands and Respects the Rights of Individuals’ Privacy and is Committed to Providing On-Line Data Security
This privacy statement explains how data is handled whilst you browse and submit information through the website and your options regarding the ways in which your data is used.
Semafone Ltd is the controller and responsible for your personal data (referred to as “we”, “us” or “our” in this privacy statement).
You will be asked to provide contact details such as your name, address, telephone number and e-mail address when you complete forms in certain areas.
The information gathered will only be used for completing your request. Information provided by you will be handled in accordance with the . We maintain strict security standards and procedures with a view to preventing your data being accidentally lost, used or accessed in an unauthorised way, and altered or destroyed, including by our staff. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable of a breach where we are legally required to do so.
Data for Direct Marketing
Individuals are given the opportunity to opt-out of receiving direct marketing activity from us. Where individuals do not want to opt out of such communication, we may provide information on:
- our services and products that may be of interest
- changes and improvements to the website.
Should you decide to change your mind on not receiving such communications at any time, please e-mail: or write to the Data Privacy Manager at the address below.
Transfer of Data/Sharing
We will not disclose your personal information unless we are obliged to do so by law, or where we need to do so in order to run our organisation: this could be to the other companies in our group, being Semafone Inc in the USA and Semafone Pty Limited in Australia, or certain of our business partners which sell our software on our behalf for purposes of following up your sales enquiry. Should this be the case, we require all such parties to respect the security of your personal data, to treat it in accordance with the law and we will ensure confidentiality agreements are in place. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
If we transfer the information to Semafone Inc or Semafone Pty Limited, this will involve transferring your data outside the European Economic Area (EEA). We will ensure a similar degree of protection is afforded to such information by ensuring the following safeguards are in place:
- to Semafone Pty Limited in Australia, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries
- to Semafone Inc in the USA, Semafone Inc is part of the which requires it to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
Please contact us (details below) if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
If you believe that any information held by us about you is incorrect or incomplete, you should contact the Data Privacy Manager at the address given below. Any information which is found to be incorrect will be corrected as soon as possible.
Applying for an Open Role and Submitting a CV Online
When you apply for a role with Semafone Ltd you are requested to provide us with personal information such as your name, address, telephone number, email address and other information that is relevant to your personal circumstances or career history. We use this information for the purpose of assessing your work history for a role within Semafone.
We have legal obligations towards you in the way we deal with that data. Any information you give us will be stored securely in accordance with data protection laws. The legal bases we rely upon to store your information are:
- Legal obligation
- Contractual obligation
Semafone will never share your personal data such as a CV with a third party without your prior consent. Your personal data is required in the event of a contractual requirement (e.g. we may require this personal data for the processing of employment contracts).
If you wish to complain about any of the procedures set out for applying for roles or submitting CVs online, please contact Semafone’s HR Team at [email protected]
How Long Do We Keep Your Data?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Links To and From Third Party Websites
Notification of Changes to the Privacy Statement
This version was last updated on 25th May 2018. Any subsequent changes will be notified by a pop up on the website.
Your Legal Rights
You have the right to:
- Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us (see below). Also:
- You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
- We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
- We try to respond to all legitimate requests within one month.
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy statement. If you have any queries or comments regarding this privacy statement, including any requests to exercise your legal rights please write to: The Data Privacy Manager, Semafone Limited, Pannell House, Park Street, Guildford, Surrey GU1 4HN or telephone +44 (0)845 543 0822 or email [email protected].
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.