Privacy policy
This privacy policy outlines how Programmatic collects, uses, and protects personal data when you use our website. By accessing this website, we assume you agree to the practices described in this policy.
1. General Information
At Programmatic Solutions Ltd (”we”, “us”, “our”, and/or “Programmatic”), we are deeply committed to safeguarding your privacy and the security of your personal data. This Privacy Policy (”Policy”) outlines how we collect, use, store, and share your personal information, and the rights you have regarding your personal data.
This privacy policy ("Policy") gives you information about:
• who we are;
• our website and our smart contracts platform ("Platform");
• what personal data we collect about you;
• how, when and why we collect, use, store and share your personal data;
• your privacy and other related rights in relation to your personal data;
• how to contact us or the relevant supervisory authorities.
1. Who we are
1.1 We are Programmatic, registered with Companies House under reg. No. 15215317, with seat and registered office at 86-90 Paul Street, London, United Kingdom, EC2A 4NE. You may contact us at the following contact details: privacy@programmatic-app.com
1.2 We operate the website and the platform to which this Policy relates. Our business activity is focused on the development and implementation of cutting-edge technologies, such as smart legal contracts and automation regarding contracting processes.
1.3 When we collect, use and process personal data we are subject to the provisions of the UK General Data Protection Regulation ("UK GDPR") and the Data Protection Act 2018. We are also subject to the EU General Data Protection Regulation ("EU GDPR") in relation to personal data we collect, use and process in the European Economic Area ("EEA").
1.4 This Policy relates to your use of our website and our Platform. Please note that our website may link to other third-party websites that may also gather information about you. Third-party websites will operate in accordance with their own separate privacy policies, and we have no control over any personal data that they may acquire, store and use. For privacy information relating to such other third-party websites, you should consult their privacy policies as appropriate.
1.5. In this Policy, please note the use of the following terms:
• personal data: means any information relating to an identified or identifiable individual (known as a "data subject")
• data processing: means any operation or actions performed on personal data; for example, collection, recording, organisation, structuring, storing, altering, deleting or otherwise using personal data.
• Platform: means our web-based platform for automatically executed legal contracts (i.e. smart legal contracts)
• we, us and our: refers to Programmatic and its representatives;
• you and your: refers to the person who is accessing our website or our platform and whose data is processed.
Any terms not specifically defined in this Policy shall have the meaning ascribed under the EU GDPR.
2. Your personal data
2.1. Personal data is collected about you whenever you:
• access our website or Platform;
• register with us;
• contact us;
• use our products/services;
2.2. Personal data is collected either directly (for example when you register with us, contact us, etc) or indirectly (for example through the use of ‘cookies’ on our website).
2.3. The personal data we receive, and process is dependent upon how you access our website and Platform and what you do whilst you are accessing them.
2.4. The categories of data that we collect and process may differ depending whether you only access our website or use the products/services we provide on our Platform:
2.4.1. Processing when you use our website:
• Access to our website and browsing
When you browse our website, we collect technical data such as your IP address, browser type and version, and operating system. We also collect usage data, including the pages you viewed and the URL that referred you to our site. This information helps us understand how our website is used and improve the user experience. We process this data under the legal basis of legitimate interest.
• Contacting us
If you contact us directly, we may collect your first and last name and email address to respond to your inquiries. This data is collected with your consent.
• Marketing
We currently do not collect identity or contact data for marketing purposes. Any future marketing communications will require your explicit consent.
• Analysing Website Use
To analyse how visitors use our website, we may collect technical data (such as your IP address, browser type and version) and usage data (such as the URLs of the pages you visited). This data is processed under legitimate interest to improve the functionality and user experience of our website.
2.4.2. Processing when you use our Platform:
• Access to platform
We collect Technical Data such as your internet protocol (IP) address, login data, browser type, version, and operating system to ensure you can access and navigate our Platform effectively. We also process Identity Data, including your name and username. This data is processed under the legal grounds of performance of a contract and our legitimate interest in ensuring the proper functioning of the Platform.
• Verifying your identity
To verify your identity on our Platform, we may collect Identity Data, including your first and last name, and ID or passport details. This is essential for verifying user identity for security purposes and is processed under the legal basis of performance of a contract and legitimate interest.
• Providing our products/services
To deliver our products and services, we collect Identity Data such as your first and last name, as well as ID or passport details. This data is processed to fulfill our contractual obligations under the legal ground of performance of a contract.
• Fraud prevention and detection
For the purpose of preventing or detecting fraud, we collect Technical Data, including your IP address, browser type and version, login data, and operating system details. This processing is carried out under the legal basis of our legitimate interest in ensuring the security and integrity of our services.
2.5. Please note that it is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal details change during your relationship with us.
2.6. Please note that our website and Platform are not intended for use by children, and we do not knowingly collect or use personal information relating to children.
2.7. The purposes set out above will not apply to special categories of personal data. This includes personal information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs, or trade union membership, genetic and biometric data, and data concerning health, sex life or sexual orientation. We will only ever process information of that nature with your explicit consent or where required for the purposes of compliance with legal obligations to which we are subject.
2.8. We may need to send you updates concerning our products/services, and about relevant developments in relation to you, our products/services, or other related matters which might concern you, or be of interest to you. This may be by post or email and may include information about the products/services we offer and information relating to changes in them.
2.9. We treat your personal data with the utmost respect and will never share it with others for marketing or promotional purposes. You have, at all times, the right to request that we do not contact you for any purpose other than providing our services. We may, however, require that you confirm your marketing preferences from time to time so that we can be sure that your views remain the same, especially in relation to issues such as legal and regulatory updates.
3. Cookies
Our website uses cookies. These are small text files that may be placed on a device while browsing our website which store certain information. Cookies cannot access, read, or modify other data stored on your device. By referring to “cookies” we include other technologies with similar purposes, such as pixel tags. We use two types of cookies on Company's website:
• Necessary cookies: Without necessary cookies the proper functioning of our website would not be possible or only to a limited extent. The use of necessary cookies on our website is possible without your consent. You can deactivate necessary cookies at any time by modifying your browser settings, however in such case we cannot guarantee the proper functioning of our website.
• Optional cookies: These types of cookies may be used to improve our website, optimise your experience, analyse your behaviour or customise marketing activities. Optional cookies may also be placed by external advertising companies ("third party cookies"). Optional cookies will only be used upon your consent which you may provide via the website's cookie banner. This consent can be withdrawn at any time with effect for the future.
Optional cookies can be analytical, functional or for advertisement.
3.1. Analytics Cookies
• _ga (Google Analytics)
Purpose: This cookie, installed by Google Analytics, calculates visitor, session and campaign data and also keeps track of site usage for the site's analytics report. The cookie stores information anonymously and assigns a randomly generated number to recognise unique visitors.
Storage period: 2 years
• _ga_* (Google Analytics)
Purpose: Google Analytics sets this cookie to store and count page views.
Storage period: 1 year, 1 month, 4 days
• hjSessionUser (HotJar)
Purpose: Set by Hotjar to ensure data from subsequent visits to the site is attributed to the same user ID, which persists as a unique Hotjar User ID.
Storage period: 1 year
• hjSession(HotJar)
Purpose: Hotjar sets this cookie to attribute data from future visits to the same user session.
Storage period: 1 hour
3.2. Functional Cookies
• trx_addons_is_retina (ThemeREX)
Purpose: Set by ThemeREX to detect whether the user is using a retina display, which adjusts visual content accordingly.
Storage period: session
• wpEmojiSettingsSupports (WordPress)
Purpose: Set by WordPress to determine if the user’s browser can display emojis properly.
Storage period: session
3.3. Advertisement and Marketing Cookies
• bcookie (LinkedIn)
Purpose: LinkedIn sets this cookie to track the usage of embedded LinkedIn services.
Storage period: 1 year
• li_gc (LinkedIn)
Purpose: LinkedIn uses this cookie to store visitors’ consent regarding the use of non-essential cookies.
Storage period: 6 months
• lidc (LinkedIn)
Purpose: LinkedIn uses this cookie to facilitate data center selection.
Storage period: 1 day
3.4. Security Cookies
• rc::a (Google)
Purpose: This cookie is set by Google reCAPTCHA to identify and prevent bot traffic, protecting the website against spam and malicious attacks.
Storage period: Never
• rc::c (Google)
Purpose: Set by Google reCAPTCHA to ensure security by identifying bots during browsing sessions.
Storage period: Session
3.5. Other Cookies
• hjActiveViewportIds (Hotjar)
Purpose: Used by Hotjar to track the user’s active viewport dimensions for optimized display and tracking.
Storage period: never
• hjViewportId (Hotjar)
Purpose: Used to store the user’s viewport dimensions for optimized display and user tracking.
Storage period: session
4. Disclosure of personal data
4.1. In some cases, it may be necessary for us to share your personal data with others in order to perform our services for you, to comply with our contractual obligations to you, to comply with our legal or regulatory obligations to you, or to comply with any contractual, legal or regulatory obligations that we are subject to. Such third-party recipients may include, amongst others:
• other entities within the Programmatic corporate group;
• external service providers which perform services on our behalf;
• financial or judicial authorities, state agencies or public bodies, upon request and to the extent permitted by law;
• certain regulated professionals such as lawyers, notaries or auditors;
• IT service providers who provide hosting, maintenance and security services for our company IT systems;
4.2. When sharing your personal data, we will always ensure that those with whom it is shared process it in an appropriate manner and take all necessary measures in order to protect it. We will only ever allow others to handle your personal data if we are satisfied that the measures which they take to protect that personal data are satisfactory.
4.3. Please be aware that, from time to time, we may be required to disclose your personal data to, and exchange information about you or relating to you with government, law enforcement and regulatory bodies and agencies to comply with our own legal and regulatory obligations.
4.4. We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
5. How your personal data is kept
5.1. Your personal data will be kept secure at all times. We operate various security measures in order to prevent loss of, or unauthorised access to, your personal data. In order to ensure this, we restrict access to your personal data to those with a genuine business need to access it, and we have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
5.2. Personal data that is processed by us will not be retained for any longer than is necessary for that processing, or for purposes relating to or arising from that processing. Where your personal data is retained after we have finished providing our products/services to you, or where the contract with you has ended in any other way, this will generally be for one of the following reasons:
• so that we can respond to any questions, complaints or claims made by you or on your behalf;
• so that we are able to demonstrate that your matter was dealt with adequately and that you were treated fairly; or
• in order to comply with legal and regulatory requirements.
5.3. In general, we will retain your data for only so long as is necessary for the various objectives and purposes contained in this Policy. Please note, however, that different periods for keeping your personal data will apply depending upon the type of data being retained and the purpose of its retention.
5.4. We will delete and/or anonymise any personal data which it is no longer necessary for us to retain.
6. Your rights in relation to your data
6.1. The EU GDPR and applicable national legislation give you, the data subject, various rights in relation to your personal data that we hold and process, namely:
6.1.1. Right of access—the right to obtain from us confirmation as to whether personal data concerning you is being processed, and, where that is the case, access to that personal data and various other information, including the purpose for the processing, with whom the data is shared, how long the data will be retained, and the existence of various other rights.
6.1.2. Right to rectification—the right to obtain from us, without undue delay, the rectification of inaccurate personal data concerning you or the completion of incomplete personal data.
6.1.3. Right to erasure—sometimes referred to as the ‘right to be forgotten’, this is the right for you to request that, in certain circumstances, we delete data relating to you. You can require the deletion of your personal data, to the extent the exceptions under Art. 17, para 3 of the GDPR do not apply, namely where the processing of your personal data is necessary:
• for exercising the right of freedom of expression and information;
• for the performance of a task carried out in the public interest or in the exercise of official authority;
• for reasons of public interest in the area of public health;
• for archiving purposes in the public interest, scientific or historical research purposes or statistical where erasure is likely to render impossible or seriously impair the achievement of the objectives of that processing;
• for the establishment, exercise or defence of legal claims.
6.1.4. Right to restrict processing—the right to request that, in certain circumstances, we restrict the processing of your data.
6.1.5. Right to data portability—the right, in certain circumstances, to receive that personal data which you have provided to us in a structured, commonly used and machine-readable format, and the right to have that personal data transmitted to another controller.
6.1.6. Right to object—the right, in certain circumstances, to object to personal data being processed by us where it is in relation to direct marketing, or in relation to processing supported by the argument of legitimate interest.
6.1.7. Right not to be subject to automated decision making—the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. This right will be applicable when you are using our website. However, you shall be aware that by using our Platform, your personal data may be used for automated decision making for the purposes of execution of a smart contract. In such case, we shall ensure that suitable measures to safeguard your rights and freedoms and legitimate interests are implemented, including the right to obtain human intervention, to express your point of view and contest the decision.
7. Keeping your data secure
7.1. We recognise our responsibility to protect the information you provide to us and have taken appropriate technical, organisational, and legal steps to protect job application information, including secure servers, firewalls, and encryption of application data. Access to your personal data is restricted to those with a need to access it, and regard will be had to the need for confidentiality when that personal data is processed.
7.2. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
8. Making a complaint
8.1. If you have any queries as to the collecting, use, storage, or disposal of any personal data relating to you please contact privacy@programmatic-app.com.
8.2. You also have the right to lodge a formal complaint to the competent supervisory authority. In the UK, the competent supervisory authority for data protection matters is the Information Commissioner’s Office, who may be contacted in writing at Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF; by telephone on 0303 123 1113; by fax on 01625 524510; or online at www.ico.org.uk.
9. This policy
9.1. This policy was published on 14.10.2024 and last updated on 14.10.2024.
9.2. We may update this privacy policy to reflect legal or technical changes or any changes to our business. We will take reasonable efforts to inform you of such updates.