Privacy Policy
Last updated: 17-May-23
We are Stirk Lamont and Associates, Ltd. of Innovation Centre, 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.
This Privacy Policy explains the privacy practices related to your use of SLA Digital’s websites, platforms and services.
By visiting SLA Digital’s sites, or submitting data to SLA Digital, you acknowledge and agree to the practices described in this Privacy Policy.
How we collect your personal data
We collect your personal data 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 data we collect
We may collect the following types of personal data:
- 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.
- Online identifiers such as IP addresses, geographical data, device type, and language settings of your device at the time you visited our website
- 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 lawful basis for processing your information
The law on data protection sets out several different reasons why a company may collect and process your personal data and it is one of our duties to make sure you understand which of these lawful bases we are using to process your data. We may use your personal data under the following lawful bases:
Consent
Consent means SLA Digital has received a freely given, specific, informed, and unambiguous indication of the data subject’s agreement to the processing of their personal data.
In specific situations, we can collect and process your data with your consent:
- When you sign up to a newsletter
- When you tick a box to receive emails from SLA Digital
- By accepting the placement of non-essential cookies via our cookie notice
Performance of a Contract
In certain circumstances, we need your personal data 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.
Legal Compliance
Legal compliance means that SLA Digital are obliged to process personal data to comply with the law
- If the law requires us to, we may need to collect and process your data to fulfil the legal obligations that are applicable to us around the World. For example, we can pass on details of people involved in fraud or other criminal activity affecting us to law enforcement.
Legitimate Interest
Legitimate interest means SLA Digital has a genuine and legitimate reason to use your personal data and we are not harming any of your rights and interests.
We may process your Personal data 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 data as needed to:
- Protect you, us or others from threats (such as security threats or fraud)
- 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.
International transfers
SLA Digital is a global company, and the information we collect, including Personal Data, is processed by our staff. For the purposes of IT hosting and maintenance of your information, your personal data may be situated outside of the UK and the European Economic Area (EEA). We may share your information within our group of companies, which may require us to export your information described in this Privacy Policy across national boundaries.
We make sure that where transfers are made to countries without an adequacy decision under EU and UK GDPR, that appropriate safeguards are in place including data processing agreements and standard contractual clauses. Please contact us if you would like further details on the safeguards that we have put in place.
SLA Digital entities worldwide are governed by this Privacy Policy with regard to the information collected through SLA Digital.
Disclosure to third parties
We will not sell, rent, or lease your Personal Data.
SLA Digital may share information, including Personal Data and non-personal site usage information, with third parties such as suppliers and service providers, in accordance with this Privacy Policy and to provide services to SLA Digital or on our behalf, for example:
- 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.
SLA Digital may also share or disclose information, including personal data: if we have permission to make the disclosure; to enforce or apply policies or agreements with you; to comply with government, legal, or regulatory requirements; to prosecute and respond to investigations and legal proceedings; or to protect rights, people, or property (including for fraud protection and credit risk reduction).
Information security and data retention
We use physical, technical, organizational, and administrative safeguards to help protect your Personal data from unauthorized access or loss including encryption, firewalls and secure servers.
We will retain your Personal data 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 data 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 data by contacting us via email at [email protected] or writing to SLA Digital at the address below. If we do not have a lawful basis for retaining your information, we will delete it as required by applicable law.
Your rights in relation to personal data
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 data. If we are, you may ask us to provide a copy of your Personal data 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 data. If we are processing your personal data 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 data 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 data 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 data 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]
Cookies
Cookies and similar tracking technologies, such as tags, scripts and beacons, are small pieces of code (referred to as cookies hereafter) that are stored on a device (computer, mobile phone, tablet etc) and enable a website to “personalise” itself to users by remembering information about the user’s visit to the website.
When you visit our website or engage with our online ads or marketing emails we place cookies on your computer. Cookies help us provide a customised experience and can enable us to detect certain kinds of fraud.
We use cookies to:
- Store preferences you have made and display content to you in a more personalised way
- Evaluate our websites’ advertising and promotional effectiveness
- Gain insight into the nature of our audience so we can tailor our content
- Provide interest-based advertising on other websites and social media
- Obtain information about how visitors interact with our content, and to help us improve the experience when visiting our website.
Cookies are useful because they allow a website to recognise a user’s device. You can find more information about cookies at http://www.allaboutcookies.org and http://www.youronlinechoices.eu
We use the following types of cookies:
Strictly Necessary Cookies
These cookies are necessary for our websites to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of our websites may not then work.
Performance Cookies
These cookies allow us to precisely count visits and traffic sources so we can measure and improve the performance of our websites. They help us to know which pages are the most and least popular and see how visitors move around the sites.
Functional Cookies
These cookies enable our websites to provide enhanced functionality and personalisation. They may be set by us or by third party providers whose services we have added to our pages. If you do not allow these cookies then some or all of these services may not function properly.
Targeting Cookies
These cookies may be set through our websites by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. They are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising. If you reject targeting cookies you will still see adverts on our websites, but they will not be tailored to your likely interests using information collected from cookies and similar technologies on your device.
Social Media Cookies
These cookies are set by a range of social media services that we have added to our websites to enable you to share our content with your friends and networks. They are capable of tracking your browser across other sites and building up a profile of your interests. This may impact the content and messages you see on other websites you visit. If you do not allow these cookies you may not be able to use or see these sharing tools.
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. 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.
- Manage cookie settings in Chrome and Chrome Android and Chrome iOS
- Manage cookie settings in Firefox
- Manage cookie settings in Internet Explorer
- Manage cookie settings in Microsoft Edge
- Manage cookie settings in Safari and Safari iOS
To opt-out of Google Analytics tracking please visit https://tools.google.com/dlpage/gaoptout
Social media platforms, forums, and public areas
Content or information (including profile information such as name, location, pictures, etc.) that you choose to post or submit to publicly available portions of the sites, forums, or on social media platforms is non-confidential and is not subject to the protections of this Privacy Policy. Whether on SLA Digital sites, forums, or any social media platforms, you should exercise caution in deciding what information you publish or disclose. Your interaction with third-party social media platforms (such as Facebook or Twitter) is subject to and governed by, the terms applicable to those platforms.
Changes to this privacy policy
This policy is effective as of the date stated at the top of this privacy policy. We may change this privacy policy from time to time and post any changes on the site as soon as they go into effect.
Please refer to this Privacy Policy on a regular basis. For activities that require additional consent from you, we shall contact you before starting the activities.
How can I contact SLA Digital
You can contact SLA Digital regarding this Privacy Policy, for subject access requests, complaints and any other Personal data related enquiries at [email protected]
If you are located in the EU, Iceland, Liechtenstein, or Norway you may also contact AssureMore which is the representative of SLA Digital for data protection in accordance with Article 27 of the GDPR. AssureMore may be contacted regarding all data subject rights in accordance with Article 13 to 23 of the GDPR. This includes requesting information on personal data or any correction of personal data, or to withdraw any consent (Article 7(3) of GDPR). The address for AssureMore is as follows:
AssureMore
345, Block 21A, Marina Village, Malahide, County Dublin, Ireland
Email: [email protected]
Who is SLA Digital’s supervisory authority
SLA Digital’s supervisory authority is the Information Commissioners Office (ICO).
Information Commissioner’s Office
3rd Floor
14 Cromac Place
Belfast
BT7 2JB
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) or the relevant supervisory authority within your Member State. You can make a complaint with the ICO at https://ico.org.uk/make-a-complaint/data-protection-complaints/personal-information-complaint/
In Ireland, your supervisory authority is the Office of the Information Commissioner (OIC)
6 Earlsfort Terrace, Dublin 2, D02 W773.
Phone: +353-1-639 5689
Email: [email protected]