Privacy Policy

Effective date: February 21, 2019

This Privacy Policy is issued on behalf of Sevan Multi-Site Solutions, LLC and its subsidiaries (together “Sevan“, “us“, “we“, or “our“). When Sevan processes your Personal Data, it is responsible as the Data Controller of that Personal Data for the purposes of data protection laws including, where applicable, the EU General Data Protection Regulation 2016 (“GDPR”).

The Data Controller responsible for the processing of your Personal Data in the UK is Sevan Multi-Site Solutions Limited, which is registered as a Data Controller with the ICO and its data protection registration number is ZA502533.

This Privacy Policy informs you of Sevan’s policy regarding the collection, use and disclosure of Personal Data when you use our Website, use our services, or communicate with us, both on this website and offline as a Corporate Contact.

Definitions

Cookies
Cookies are small files stored on your device (computer or mobile device).

Corporate Contact
A client, prospective client, business partner or general contact.

Data Controller
The natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any Personal Data are, or are to be, processed.

For the purpose of this Privacy Policy, we are a Data Controller of your Personal Data.

Data Processor
The natural or legal person who processes Personal Data on behalf of the Data Controller.

We may use the services of various Data Processors in order to process your Personal Data more effectively.

EEA
European Economic Area.

ICO
The United Kingdom Information Commissioner’s Office.

Location Data
Information about your location if you give us permission to do so.

Personal Data
Personal Data means data about a living individual who can be identified from such data (or from such data and other information either in our possession or likely to come into our possession).

UK
United Kingdom of Great Britain and Northern Ireland

Usage Data
Usage Data is data collected automatically by the Website either generated by the use of the Website or from the Website infrastructure itself (for example, the duration of a page visit). Please see below for further details regarding what Usage Data may include.

Website
The Website is www.sevansolutions.com operated by Sevan Multi-Site Solutions, LLC

Information Collection and Use

We collect several different types of information for various purposes, particularly in order to do business with you and to provide and improve our Website.

Types of Data Collected

Personal Data

You may provide us with Personal Data through the Website, by email, over the phone or otherwise communicate or be in contact with us in your capacity as a Corporate Contact, when you:

  • request additional information about our business or ask us to contact you;
  • receive our services;
  • do business with us, for example, in respect of a project we are working on with you; or
  • make any comment or contribution on the Website.

Personal Data includes, but is not limited to:

  • email address;
  • first name and last name;
  • phone number; and
  • address.

We may use your Personal Data to contact you with customer, service, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the instructions provided in any email we send or by contacting us.

Usage Data

We may also collect Usage Data. This Usage Data may include information such as your computer’s Internet Protocol (or IP) address, browser type, browser version, the pages of our Website that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

Location Data

We may use and store Location Data. We use this data to provide features of, improve and customise our Website.

You can enable or disable location services when you use our Website at any time by changing your device settings.

Cookies

We use cookies and similar tracking technologies to track the activity on our Website and hold certain information. We use both cookies which are set by us and by third parties. Please see our Cookies Policy for further details.

Use of Data and Legal Basis for Processing Personal Data

We have set out in the table below a description of all the ways we plan to use the data described above, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Please note that we may process your Personal Data for more than one lawful ground depending on the specific purpose for which we are using your Personal Data.

Purpose/ActivityType of dataLawful basis for processing including basis of legitimate interest
To do business with, or provide our services to, you, for example in respect of a construction or engineering project and to provide client support.Personal DataSuch processing is necessary for our legitimate interests in running our business, particularly in relation to managing projects.
To administer accounts and keep transaction records.Personal DataSuch processing is necessary for our legitimate interests in meeting our operational and risk management requirements.
To carry out our obligations arising from any contracts entered into with you.Personal DataIt is necessary for us to process your Personal Data in this way in order to enter into a contract with you and to fulfil our contractual obligations to you.
To provide you with information and materials that you request from us.Personal DataIt is in our legitimate interests to respond to your queries and provide any information and materials requested in order to generate and develop business.
To enforce any contracts entered into with you.Personal DataIt is in our legitimate interests to enforce any contracts against you where necessary.
If you are an existing client, to provide you with news and information about services which we offer that are similar to those that you have already purchased or enquired about, unless you have opted not to receive such information, and to notify you about changes to our Website.Personal DataIt is in our legitimate interests to market to our existing clients.
To detect, prevent and address technical or security issuesUsage Data

Location Data

Cookies

It is necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business re-organisation or group restructuring exercise).
To:

  • provide and maintain our Website;
  • allow you to participate in interactive features of our Website when you choose to do so;
  • gather analysis or valuable information so that we can improve our Website; and
  • monitor the usage of our Website.
Usage Data

Location Data

Cookies

It is in our legitimate interests to keep our website updated and relevant, to develop our business and to inform our marketing strategy.

 

Retention of Data

Sevan will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to satisfy any legal, regulatory, tax, accounting or reporting requirements, resolve disputes and enforce our contracts and policies.

Sevan will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Website, or we are legally obligated to retain this data for longer periods.

International Transfer of Personal Data

Your information, including Personal Data, may be transferred to – and maintained on – computers or servers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

If you are located outside the United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to the United States and process it there. For example, where we collect Personal Data about you in the United Kingdom, we will share that Personal Data with our offices in the United States.

Sevan will take all the steps necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organisation or a country unless there are adequate controls in place including the security of your data and other Personal Data.

Disclosure of Personal Data

Business Sale

If Sevan Multi-Site Solutions, LLC or one of its subsidiaries is involved in a merger, acquisition or asset sale, your Personal Data may be transferred to a third party as part of that merger, acquisition or asset sale.

Disclosure for Law Enforcement

Under certain circumstances, Sevan may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Legal Requirements

Sevan may disclose your Personal Data in the good faith belief that such action is necessary to:

  • comply with a legal obligation;
  • protect and defend the rights or property of Sevan;
  • prevent or investigate possible wrongdoing in connection with the Website;
  • protect the personal safety of users of the Website or the public; or
  • protect against legal liability.

Third Party Providers

Personal Data will also be shared with our third party service providers and business partners (including our appointed Data Processors) who assist with the running of the Website and the operation of our business. Our third party service providers and business partners are subject to security and confidentiality obligations and are only permitted to process your Personal Data for specified purposes and in accordance with our instructions.

Security of Data

We use appropriate technical and organisational security measures to protect Personal Data both online and offline from unauthorised use, loss, alteration or destruction. We use physical and procedural security measures to protect Personal Data from the point of collection to the point of destruction.

Where we appoint Data Processors, we take steps to ensure that appropriate security measures are in place to prevent unauthorized disclosure of Personal Data.

Despite these precautions, however, please note that no method of transmission over the Internet or method of electronic storage is 100% secure. While we use appropriate technical and organisational security measures to protect your Personal Data, we cannot guarantee the security of Personal Data transmitted over the Internet or that unauthorised persons will not obtain access to Personal Data.

Your Rights under GDPR

If you are located in the EEA, you have certain rights available to you under data protection laws. Sevan aims to take the required steps to allow you to correct, amend, delete or limit the use of your Personal Data.

If you wish to be informed about what Personal Data we hold about you or if you want it to be removed from our database, please contact us using the contact details provided at the end of this Privacy Policy.

In certain circumstances, you have the following rights:

The right to access, update or delete the Personal Data we have about you. You can request to access or update your Personal Data, or have Personal Data about you deleted, directly within your account settings section. If you are unable to perform these actions yourself, please contact us (using the contact details provided at the end of the Privacy Policy) to assist you.

The right of rectification. You have the right to have your Personal Data rectified if it is inaccurate or incomplete.

The right to object. You have the right to object to our processing of your Personal Data.

The right of restriction. You have the right to request that we restrict the processing of your Personal Data.

The right to data portability. You have the right to be provided with a copy of the Personal Data we have about you in a structured, machine-readable and commonly used format so that it can be transferred to another Data Controller.

The right to withdraw consent. You also have the right to withdraw your consent at any time where Sevan relied on your consent to process your Personal Data.

Please note that the above rights are not absolute and we may be entitled to refuse requests, wholly or partly, where exceptions under applicable laws apply. For example, we may refuse a request for erasure of Personal Data where the processing is necessary to comply with a legal obligation or necessary for the establishment, exercise or defence of legal claims

Please note also that we may ask you to verify your identity before responding to such requests.

Save as described in this Privacy Policy or provided under data protection laws, there is no charge for the exercise of your legal rights. However, if your requests are manifestly unfounded or excessive, in particular because of their repetitive character, we may either: (a) charge a reasonable fee taking into account the administrative costs of providing the information or taking the action requested; or (b) refuse to act on the request.

Complaints

If you have any questions or concerns regarding our Privacy Policy or practices, please contact us using the details as provided at the end of this Privacy Policy.

If you are located in the EEA, you have the right to complain to your national or State data protection authority about our collection and use of your Personal Data.  If you are in the UK, your national data protection authority is the ICO (https://ico.org.uk/).

We would, however, appreciate the chance to deal with your concerns before you approach your data protection authority so please contact us in the first instance.

Links to Other Sites

Our Website may contain links to other sites that are not operated by us. If you click a third party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and accept no responsibility for the content, privacy policies or practices of any third party sites or services.

Children’s Privacy

Our Website is not for use by anyone under the age of 18.

We do not knowingly collect Personal Data from anyone under the age of 18. If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us immediately. If we become aware that we have collected Personal Data from children without verification of parental consent, we will take steps to remove that information from our servers.

Changes to This Privacy Policy

We may update our Privacy Policy from time to time. Any changes will be posted on this page. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, please contact us by email at info@sevansolutions.com.