We are a Stirk Lamont and Associates, Ltd. of Innovation Center, Queen’s Road, Belfast BT3 9DT, Northern Ireland.
Stirk Lamont and Associates, Ltd. (together, “SLA Digital”, “we”, or “our”) is a leading digital services provider delivering solutions such as direct carrier billing to global mobile operators and content partners in order to drive new revenue streams.
Under the General Data Protection Regulation (GDPR), SLA Digital has a number of lawful reasons where we can use (or ‘process’) your personal information. One of the lawful reasons is called ‘legitimate interests’. This means SLA Digital has a genuine and legitimate reason to use your personal information and we are not harming any of your rights and interests.
How we collect your personal information
We collect your personal information in a number of ways and combine the information from these sources with the information you provide to us directly, e.g.
- When you provide it to us voluntarily (for example, when you request more information from us, fill in a form, download our content etc.)
- When you provide permission to other organisations to share it with us (including LinkedIn, or Twitter)
- When we collect it as you use our websites
- When you have given it to a third party (e.g. when purchasing or subscribing to content or services provided by a partner or mobile operator who uses our platforms for their service). This data may include:
- Mobile number
- Device data
- IP address
- What content you purchased
- Payment behaviour
- If your payment has been successful etc.
- From publicly available sources (where possible) to keep your information up to date (e.g. Google Searches or Company websites).
Personal information we collect
Personal Information is any information that we can use to identify, locate or contact you. It also includes other information that may be associated with your Personal Information, such as demographic data. We may collect the following types of Personal Information:
- Contact Information that allows us to communicate with you, such as your name, username, mailing address, telephone number, email address or other addresses that allow us to send you messages.
- Transaction Data about your purchases or other transactions when using our services or services provided by contractual partners (e.g. mobile operators and content providers)
- Information about your Interactions with SLA Digital
The purposes and legal basis for processing your information
SLA Digital processes your information to the minimum extent necessary. We may use your personal information to:
- Fulfil a contract with you or as needed to fulfil a contract between you and a content provider or between you and your mobile operator or other entity, where SLA Digital is providing carrier billing payment services or acting as a data processor
- Provide you with marketing communications, provided you have given your consent for us to do so
- Fulfil the legal obligations that are applicable to us around the World
We may also process your Personal Information for the purposes of our own legitimate interests or for the legitimate interests of others, provided that processing does not and shall not outweigh your rights and freedoms. In particular, we will process your Personal Information as needed to:
- Protect you, us or others from threats (such as security threats or fraud)
- Support crime/fraud monitoring and prevention, compliance audits, and security
- Enable or administer our business, such as for quality control, consolidated reporting, and customer support etc.
- Personalize your experience on SLA Digital sites by presenting products, marketing messages, offers, and content tailored to you
- Send you direct marketing related to SLA Digital if you have expressed an interest in our products or services
- Identify usage trends, conduct and perform marketing analysis, and data analysis
- Connect information you provide to SLA Digital with other information from you or about you
- Confirm compliance with the terms governing the use of SLA Digital sites.
Disclosure to third parties
We will not sell, rent, or lease your Personal Data.
- We share information, including analytics and about how and when users visit our sites, in order to improve or personalize the content and services offered to you or to provide you with information about products and services that may be of interest to you;
- We share information as needed to respond to your requests, for example for more information or for support or customer service;
- In connection with a proposed or actual corporate transaction such as a merger, consolidation, sale or restructuring, SLA Digital reserves the right to share information and Personal Data with prospective parties to the transaction, typically under confidentiality or non-disclosure agreements with those parties.
Information security and data retention
We use physical, technical, organizational, and administrative safeguards to help protect your Personal Information from unauthorized access or loss including encryption, firewalls and secure servers.
We will retain your Personal Information for as long as the information is needed for the purposes set out above and for any additional period that may be required or permitted by law. The length of time your Personal Information is retained depends on the purpose(s) for which it was collected, how it is used, and the requirements to comply with applicable laws.
You may request that we delete your Personal Information by contacting us via email at [email protected] or writing to SLA Digital at the address below. If we do not have a legal basis for retaining your information, we will delete it as required by applicable law.
Your rights in relation to personal information
Under the GDPR you have various rights regarding your personal data. If you wish to use any of these rights, please write to [email protected]
- Right to access and right to data portability
You generally have a right to know if SLA Digital is storing your Personal Information. If we are, you may ask us to provide a copy of your Personal Information and request that this data be provided in a format that is machine-readable.
- Right to erasure
You may also ask us to delete or restrict your Personal Information. If we are processing your Personal Information based on your consent, you have the right to withdraw your consent at any time.
- Right to rectification
You have the right to ask us to update your Personal Information if your information is incomplete or incorrect.
- Right to restrict processing and right to object
You have the right to object to our processing of your Personal Information and to ask us to ‘block’ or suppress processing of your Personal Information.
As stipulated by the GDPR there may be limitations to these rights.
If SLA Digital is processing your Personal Information as a data processor, we will refer you to the relevant data controller for assistance with these requests. SLA Digital supports its mobile operator and content provider partners in responding to requests as required by law.
Sensitive personal data
SLA Digital does not collect, share or process your sensitive personal data. SLA Digital does not knowingly provide services to, or collect Personal Data of, children without obtaining parental consent where it is required by law.
If you believe that we may have collected Personal Data from someone under the applicable age of consent without obtaining parental consent, please let us know by contacting us at [email protected]
When you visit our website or engage with our online ads we place cookies on your computer. Cookies are small text files that websites send to your computer or other Internet-connected devices to uniquely identify your browser or to store information or settings in your browser. Cookies allow us to recognise you when you return. They also help us provide a customised experience and can enable us to detect certain kinds of fraud.
The information we collect using cookies and other tools is only used in a non-identifiable way, without any reference to Personal Information. For example, we use the information we collect about all website users to optimise our websites and to understand website traffic patterns.
You can see which cookies our website uses by using a freely-available cookie checking service.
Opt-out of cookies
You are free to opt-out of cookies however you may not be able to use all the features and functionality of our website.
In many cases, you can manage cookie preferences and opt-out of having cookies and other data collection technologies used by adjusting the settings on your browser. All browsers are different, so visit the “help” section of your browser to learn about cookie preferences and other privacy settings that may be available. Please note that if you choose to remove or reject cookies or clear local storage, this could affect the features, availability, and functionality of our websites.
To opt-out of Google Analytics tracking please visit https://tools.google.com/dlpage/gaoptout
Social media platforms, forums, and public areas
From time to time, we may update this Privacy Notice to reflect new or different privacy practices. We will place a notice online when we make material changes to this the Privacy Notice.
This policy may vary from time to time. Please read this policy regularly before using the website, platform or the services and before submitting any data to SLA Digital, its partners or its mobile operator customers.
How can I contact SLA Digital
Who is SLA Digital’s supervisory authority
SLA Digital’s supervisory authority is the Information Commissioners Office (ICO).
Information Commissioner’s Office
14 Cromac Place
Tel: 028 9027 8757 or 0303 123 1114
Email: [email protected]
Filing a complaint
If after contacting SLA Digital you have concerns about our privacy practices or how we process your personal data, you have the right to file a complaint with the Information Commissioners Office (ICO).