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[ LEGAL ]

PRIVACY POLICY

Last updated: March 1, 2022

1. Important Information and Who We Are

Purpose of this privacy policy

Seed understands the importance of privacy and aims to be transparent about how personal data is collected and processed through the use of this website. We will only collect and use personal data as described in this policy, consistent with our legal obligations and your rights. This website is not intended for children, and we do not knowingly collect data relating to minors.

Please read this policy alongside any other privacy notices we may provide on specific occasions when collecting or processing personal data, so that you are fully aware of how and why we use your data.

Controller

Seed Limited is the data controller responsible for this website. The Tomorrow Group comprises multiple legal entities. This privacy policy is issued on behalf of the Tomorrow Group, so when we mention “Seed”, “we”, “us” or “our” in this privacy policy, we are referring to the relevant company in the Tomorrow Group responsible for processing your data.

Data Privacy Manager

Legal entity: Seedd Limited

Email: dataprivacymanager@seedstudio.ai

Postal address: 22 Charterhouse Square, London EC1M 6DX

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.

Changes to the privacy policy

This privacy policy is kept under regular review. This version was last updated on March 1, 2022. It is important that you keep us informed of any changes to your personal data during your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

2. The Data We Collect About You

Personal data means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data

First name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.

Contact Data

Billing address, delivery address, email address and telephone numbers.

Financial Data

Bank account and payment card details.

Transaction Data

Details about payments to and from you and other details of products and services you have purchased from us.

Technical Data

Internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.

Profile Data

Your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.

Usage Data

Information about how you use our website, products and services.

Marketing & Communications Data

Your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

3. How Is Your Personal Data Collected?

We use different methods to collect data from and about you including through:

Direct interactions

You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

  • Apply for our products or services
  • Create an account on our website
  • Subscribe to our service or publications
  • Request marketing to be sent to you
  • Apply for a role at our company
  • Enter a competition, promotion or survey
  • Give us feedback or contact us

Automated technologies or interactions

As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our Cookie Policy for further details.

Third parties or publicly available sources

We will receive personal data about you from various third parties and public sources, including analytics providers such as Google Analytics, advertising networks, and search information providers.

Analytics & marketing technologies

Google Analytics: We use Google Analytics for remarketing, Display Network Impression Reporting, and Demographics and Interest Reporting. You may opt out via Google’s Ad Settings or the Google Analytics Opt-out Browser Add-on.

HubSpot: Marketing automation platform used for customer communication and website forms. HubSpot Privacy Policy.

Salesforce: CRM platform used for sales pipeline and revenue reporting. Salesforce Privacy Policy.

4. How We Use Your Personal Data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal obligation.

Purposes for which we will use your personal data

Purpose / Activity Type of Data Lawful Basis
To register you as a new customer Identity, Contact Performance of a contract with you
To process and deliver your order Identity, Contact, Financial, Transaction, Marketing & Communications Performance of a contract; Necessary for our legitimate interests (to recover debts)
To manage our relationship with you Identity, Contact, Profile, Marketing & Communications Performance of a contract; Necessary to comply with a legal obligation; Necessary for our legitimate interests
To administer and protect our business and this website Identity, Contact, Technical Necessary for our legitimate interests (running our business, IT services, network security, fraud prevention)
To deliver relevant website content and advertisements Identity, Contact, Profile, Usage, Marketing & Communications, Technical Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences Technical, Usage Necessary for our legitimate interests (to keep our website updated and relevant, to develop our business and inform our marketing strategy)

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.

5. Disclosures of Your Personal Data

We may share your personal data with the parties set out below for the purposes set out in section 4 above.

  • Internal Third Parties - other companies in the Tomorrow Group acting as joint controllers or processors
  • External Third Parties - service providers, professional advisers, and regulatory authorities
  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets

Service providers

Recipient Activity Sector Location
Xero Financial reporting, invoicing, bookkeeping Finance / Business Support US / NZ
Teamtailor Recruitment management Recruitment EU / EEA
Google SEO, PPC, Analytics, document management Digital Marketing US / EU
Salesforce Sales, revenue reporting, CRM Finance / Sales US / UK
Office 365 Office products and email servers Operations US
HubSpot Sales and marketing email management Sales / Marketing US / EU
Egnyte File management server Operations US

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. 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.

6. International Transfers

We share your personal data within the Tomorrow Group. This will involve transferring your data outside the UK. Many of our external third parties are also based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
  • Where we use certain service providers, we may use specific UK-approved contracts which give personal data the same protection it has in the UK.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

7. Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. 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 regulator of a breach where we are legally required to do so.

8. Data Retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see your legal rights below for further information.

9. Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data:

Request access

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

You have the right to 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.

Request erasure

You have the right to 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.

Object to processing

You have the right to object to processing of your personal data where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground.

Request restriction

You have the right to request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in certain scenarios.

Request transfer

You have the right to request the transfer of your personal data to you or to a third party in a structured, commonly used, machine-readable format.

Withdraw consent

You have the right to 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.

No fee usually required

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 could refuse to comply with your request in these circumstances.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

For further information, please visit the ICO Guide to Individual Rights.

10. Glossary

Tomorrow Group

The following companies: Found Group Limited, Seedd Limited, Disrupt Marketing Limited, and Braidr Limited.

Lawful Basis

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Third Parties

Internal Third Parties: Other companies in the Tomorrow Group acting as joint controllers or processors and providing IT and system administration services and undertaking leadership reporting.

External Third Parties: Service providers (as listed in section 5); professional advisers including lawyers, bankers, auditors and insurers; and HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.

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