Data protection is of high priority for the management of YUDU Ltd. The use of the Internet pages of YUDU Ltd is possible without any indication of personal data; however, if a data subject (an individual who is the subject of personal data) wants to use special enterprise services via our websites, processing of personal data could become necessary. If the processing of personal data is necessary and there is no statutory basis for such processing, we generally obtain consent from the data subject.
The processing of personal data, such as the name, address, e-mail address, or telephone number of a data subject shall always be in line with the General Data Protection Regulation (GDPR), and in accordance with the country-specific data protection regulations applicable to YUDU Ltd. By means of this data protection declaration, our enterprise would like to inform the general public of the nature, scope, and purpose of the personal data we collect, use and process. Furthermore, data subjects are informed, by means of this data protection declaration, of the rights to which they are entitled.
As the controller, YUDU Ltd has implemented numerous technical and organisational measures to ensure the most complete protection of personal data processed through our this websites. However, Internet-based data transmissions may in principle have security gaps, so absolute protection may not be guaranteed. For this reason, every data subject is free to transfer personal data to us via alternative means, e.g. by telephone.
In some instances YUDU will only be acting as the processor and not the controller (see definitions below). This will be the case if your organisation has entered into an agreement for specific services and in these cases the data privacy provisions are governed by the provisions set out on www.sentinelresilience.com/about/gdpr.
This will also be the case if you have subscribed or registered for a YUDU service on a website that is not the property of YUDU Ltd. An example would be when you have signed up for an App or subscription on the Apple Appstore, Google Play store, Window Store or a website that belongs to a company, organisation or publisher that is not owned by YUDU Ltd. In these circumstances your recourse under GDPR regarding the control of your data should directed to those organisations. YUDU maintains responsibilities for the processing of the data and any matters concerning processing can be directed to YUDU Ltd.
8. Function of Blog Comments
9. Routine Erasure of Personal Data
10. Rights of Data Subject
11. Data Protection of Applications
12. Data Protection for Application & Google Analytics use
13. Legal Basis for Processing
The data protection declaration of YUDU Ltd is based on the terms used by the European legislator for the adoption of the General Data Protection Regulation (GDPR). Our data protection declaration should be legible and understandable for the general public, as well as our customers and business partners. To ensure this, we would like to first explain the terminology used.
In this data protection declaration, we use, inter alia, the following terms:
a) Personal data
Personal data means any information relating to an identified or identifiable natural person (“data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
b) Data subject
Data subject is any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing.
Processing is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organising, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
d) Restriction of processing
Restriction of processing is the marking of stored personal data with the aim of limiting their processing in the future.
Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.
Pseudonymisation is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.
g) Controller or controller responsible for the processing
Controller or controller responsible for the processing is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by UK or European Union law, the controller or the specific criteria for its nomination may be provided for by UK, European Union.
Processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
Recipient is a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with the UK, European Union or Member State law shall not be regarded as recipients; the processing of that data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.
j) Third party
Third party is a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.
Consent of the data subject is any freely given, specific, informed and unambiguous indication of the data subject's wishes by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to the data subject.
The Controller for the purposes of the General Data Protection Regulation (GDPR), other data protection laws applicable in Member states of the UK or European Union and other provisions related to data protection is:
Primrose Studios, Primrose Road
BB7 1DR Clitheroe
Phone: +44 1200420500
The Data Protection Officer of the controller is:
Primrose Studios, Primrose Road
BB7 1DR Clitheroe
Any data subject may, at any time, contact our Data Protection Officer directly with all questions and suggestions concerning data protection.
We use the HubSpot platform for managing your consent to cookies, analytics, lead capture forms and triggering third party advertising cookies. To achieve this we have installed the HubSpot tracking code on our website. This will set a number of different cookies when you land on our website, dependent on whether you consent to, or decline cookies. These break down as follows:
a) Necessary Cookies
These are essential cookies that do not require consent.
b) Analytics cookies
These are non-essential cookies controlled by the cookie consent banner you will see when landing on the website. You can opt out of these cookies by not giving consent.
These Cookies are used to deliver adverts more relevant to you and your buying needs. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of our digital advertising campaigns. They are placed by third party advertising networks on our behalf and with YUDU’s permission. They remember that you have visited sentinelresilience.com and this is shared with other organisations such as media owners.
We use HubSpot's cookie consent banner in combination with their Event API to control whether advertising cookies are triggered. You can opt out of these cookies by clicking decline on our cookie banner and continue to use the site.
More information about these types of Cookies and opt out information can be viewed below.
Facebook Pixel – this pixel allows us to track conversions and analytics data in order to measure and optimise our advertising campaigns. It also allows us to show you targeted advertising across the Facebook network with information relevant to the pages you visited on our website.
ii) Google Ads
Google Ads Conversion Cookies - let us track significant actions you performed on our website like contact form submissions. We use this information to optimise our Google Ads campaigns effectively.
Google Ads Remarketing Cookies – as a previous visitor, these let us show you ads across Google's Display Network that contain relevant information from pages you have viewed on our website.
LinkedIn Insight Tag – this tag allows us to track conversions and collect analytics data in order to monitor and optimise our advertising campaigns. It also allows us to show you adverts across the LinkedIn network with relevant information based on the pages you previously viewed on our website.
You can opt out of LinkedIn’s targeted advertising by updating the advertising settings on your profile. You can also visit the LinkedIn help section for more information on managing your advertising preferences on LinkedIn.
iv) Microsoft Advertising
Universal Event Tracking (UET) – we use this tag to track significant actions performed on our website, like when you complete a contact form. We use this information to optimise our Microsoft Advertising campaigns effectively.
As a previous visitor, this tag also allows us to show you ads across Microsoft's display network with information relevant to products you expressed interest in.
You can opt out of Microsoft Advertisig's use of conversion and remarketing cookies by visiting the Network Advertising Initiative opt-out page.
The website of YUDU Ltd collects a series of general data and information when a data subject or automated system calls up the website. This general data and information are stored in the server log files. Collected may be:
When using these general data and information, YUDU Ltd does not draw any conclusions about the data subject. Rather, this information is needed to:
Therefore, YUDU Ltd analyses anonymously collected data and information statistically, with the aim of increasing the data protection and data security of our enterprise, and to ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from all personal data provided by a data subject.
The data subject has the possibility to register on the website of the controller with the indication of personal data. Which personal data are transmitted to the controller is determined by the respective input mask used for the registration. The personal data entered by the data subject are collected and stored exclusively for internal use by the controller, and for his own purposes. The controller may request transfer to one or more processors (e.g. a parcel service) that also uses personal data for an internal purpose which is attributable to the controller.
By registering on the website of the controller, the IP address—assigned by the Internet service provider (ISP) and used by the data subject—date, and time of the registration are also stored. The storage of this data takes place against the background that this is the only way to prevent the misuse of our services, and, if necessary, to make it possible to investigate committed offences. This data is not passed on to third parties unless there is a statutory obligation to pass on the data, or if the transfer serves the aim of criminal prosecution.
The registration of the data subject, with the voluntary indication of personal data, is intended to enable the controller to offer the data subject contents or services that may only be offered to registered users due to the nature of the matter in question. Registered persons are free to change the personal data specified during the registration at any time, or to have them completely deleted from the data stock of the controller.
The data controller shall, at any time, provide information upon request to each data subject as to what personal data are stored about the data subject. In addition, the data controller shall correct or erase personal data at the request or indication of the data subject, insofar as there are no statutory storage obligations. A Data Protection Officer particularly designated in this data protection declaration, as well as the entirety of the controller’s employees are available to the data subject in this respect as contact persons.
The website of YUDU Ltd contains information that enables a quick electronic contact to us, as well as direct communication with us, which also includes a general address of the so-called electronic mail (e-mail address). If a data subject contacts the controller by e-mail or via a contact form, the personal data transmitted by the data subject are automatically stored. Such personal data transmitted on a voluntary basis by a data subject to the data controller are stored for the purpose of processing or contacting the data subject. There is no transfer of this personal data to third parties.
YUDU Ltd offers users the possibility to leave individual comments on individual blog contributions on a blog, which is on the website of the controller. A blog is a web-based, publicly-accessible portal, through which one or more people called bloggers or web-bloggers may post articles or write down thoughts in so-called blogposts. Blogposts may usually be commented by third parties.
If a data subject leaves a comment on the blog published on this website, the comments made by the data subject are also stored and published, as well as information on the date of the commentary and on the user's (pseudonym) chosen by the data subject. In addition, the IP address assigned by the Internet service provider (ISP) to the data subject is also logged.
This storage of the IP address takes place for security reasons, and in case the data subject violates the rights of third parties, or posts illegal content through a given comment. The storage of these personal data is, therefore, in the own interest of the data controller, so that he can exculpate in the event of an infringement. This collected personal data will not be passed to third parties, unless such a transfer is required by law or serves the aim of the defense of the data controller.
The data controller shall process and store the personal data of the data subject only for the period necessary to achieve the purpose of storage, or as far as this is granted by the UK or European legislator or other legislators in laws or regulations to which the controller is subject to.
If the storage purpose is not applicable, or if a storage period prescribed by the UK or European legislator or another competent legislator expires, the personal data are routinely blocked or erased in accordance with legal requirements.
a) Right of confirmation
Each data subject shall have the right granted by UK law or European legislation to obtain from the controller the confirmation as to whether or not personal data concerning him or her are being processed. If a data subject wishes to avail himself of this right of confirmation, he or she may, at any time, contact our Data Protection Officer or another employee of the controller.
b) Right of access
Each data subject shall have the right granted by UK Law or the European legislator to obtain from the controller free information about his or her personal data stored at any time and a copy of this information. Furthermore, the UK Law or European directives and regulations grant the data subject access to the following information:
Furthermore, the data subject shall have a right to obtain information as to whether personal data are transferred to a third country or to an international organisation. Where this is the case, the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer.
If a data subject wishes to avail himself of this right of access, he or she may at any time contact our Data Protection Officer or another employee of the controller.
c) Right to rectification
Each data subject shall have the right granted by the European legislator to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement. If a data subject wishes to exercise this right to rectification, he or she may, at any time, contact our Data Protection Officer or another employee of the controller.
d) Right to erasure (Right to be forgotten)
Each data subject shall have the right granted by UK Law or the European legislator to obtain from the controller the erasure of personal data concerning him or her without undue delay, and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies, as long as the processing is not necessary:
If one of the aforementioned reasons applies, and a data subject wishes to request the erasure of personal data stored by YUDU Ltd, the data subject may at any time contact our Data Protection Officer or another employee of the controller. The Data Protection Officer of YUDU Ltd or another employee shall promptly ensure that the erasure request is complied with immediately.
Where the controller has made personal data public and is obliged pursuant to Article 17(1) to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform other controllers processing the personal data that the data subject has requested erasure by such controllers of any links to, or copy or replication of, those personal data, as far as processing is not required. The Data Protection Officer of YUDU Ltd or another employee will arrange the necessary measures in individual cases.
e) Right of restriction of processing
Each data subject shall have the right granted by UK Law or the European legislator to obtain from the controller restriction of processing where one of the following applies:
If one of the aforementioned conditions is met, and a data subject wishes to request the restriction of the processing of personal data stored by YUDU Ltd, he or she may at any time contact our Data Protection Officer or another employee of the controller. The Data Protection Officer of YUDU Ltd or another employee will arrange the restriction of the processing.
f) Right to data portability
Each data subject shall have the right granted by UK Law or the European legislator, to receive the personal data concerning the data subject, which was provided to a controller, in a structured, commonly used and machine-readable format.
In Sentinel Hotline we provide a download button that will deliver all the information that is held on an account. The data subject shall have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, as long as the processing is based on consent pursuant to point
and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
Furthermore, in exercising rights to data portability pursuant to Article 20(1) of the GDPR, the data subject shall have the right to have personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.
In order to assert the right to data portability, the data subject may at any time contact the Data Protection Officer designated by YUDU Ltd or another employee.
g) Right to object
Each data subject shall have the right granted by UK Law or the European legislator to object, on grounds relating to the data subject’s particular situation, at any time, to processing of personal data concerning the data subject, which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to profiling based on these provisions.
In addition, the data subject has the right, on grounds relating to the data subject’s particular situation, to object to processing of personal data concerning him or her by YUDU Ltd for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
In order to exercise the right to object, the data subject may directly contact the Data Protection Officer of YUDU Ltd or another employee. In addition, the data subject is free in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to use his or her right to object by automated means using technical specifications.
h) Automated individual decision-making, including profiling
Each data subject shall have the right granted by UK Law or the European legislator not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her, or similarly significantly affects him or her, as long as the decision;
If the decision;
If the data subject wishes to exercise the rights concerning automated individual decision-making, he or she may at any time directly contact our Data Protection Officer of YUDU Ltd or another employee of the controller.
i) Right to withdraw data protection consent
Each data subject shall have the right granted by UK Law or the European legislator to withdraw consent to processing of personal data at any time.
If the data subject wishes to exercise the right to withdraw the consent, the data subject may at any time directly contact our Data Protection Officer of YUDU Ltd or another employee of the controller.
The data controller shall collect and process the personal data of applicants for the purpose of the processing of the application procedure.
The processing may also be carried out electronically. This is the case, in particular, if an applicant submits corresponding application documents by e-mail or by means of a web form on the website to the controller.
If the data controller concludes an employment contract with an applicant, the submitted data will be stored for the purpose of processing the employment relationship in compliance with legal requirements. If no employment contract is concluded with the applicant by the controller, the application documents shall be automatically erased two months after notification of the refusal decision, provided that no other legitimate interests of the controller are opposed to the erasure. Other legitimate interest in this relation is, e.g. a burden of proof in a procedure under the General Equal Treatment Act (AGG).
On this website, the controller has integrated the component of Google Analytics (with the anonymiser function). Google Analytics is a web analytics service. Web analytics is the collection, gathering, and analysis of data about the behaviour of visitors to websites. A web analysis service collects, inter alia, data about the website from which a person has come (the so-called referrer), which sub-pages were visited, or how often and for what duration a sub-page was viewed. Web analytics are mainly used for the optimisation of a website and in order to carry out a cost-benefit analysis of Internet advertising.
The operator of the Google Analytics component is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, United States.
For the web analytics through Google Analytics the controller uses the application "_gat. _anonymizeIp". By means of this application the IP address of the Internet connection of the data subject is abridged by Google and anonymised when accessing our websites from a Member State of the European Union or another Contracting State to the Agreement on the European Economic Area. For the web analytics through Google Analytics the controller uses the application "_gat. _anonymizeIp". By means of this application the IP address of the Internet connection of the data subject is abridged by Google and anonymised when accessing our websites from the UK or a Member State of the European Union or another Contracting State to the Agreement on the European Economic Area.
The purpose of the Google Analytics component is to analyse the traffic on our website. Google uses the collected data and information, inter alia, to evaluate the use of our website and to provide online reports, which show the activities on our websites, and to provide other services concerning the use of our Internet site for us.
Google Analytics places a cookie on the information technology system of the data subject. The definition of cookies is explained above. With the setting of the cookie, Google is enabled to analyse the use of our website. With each call-up to one of the individual pages of this Internet site, which is operated by the controller and into which a Google Analytics component was integrated, the Internet browser on the information technology system of the data subject will automatically submit data through the Google Analytics component for the purpose of online advertising and the settlement of commissions to Google. During the course of this technical procedure, the enterprise Google gains knowledge of personal information, such as the IP address of the data subject, which serves Google, inter alia, to understand the origin of visitors and clicks, and subsequently create commission settlements.
The cookie is used to store personal information, such as the access time, the location from which the access was made, and the frequency of visits of our website by the data subject. With each visit to our Internet site, such personal data, including the IP address of the Internet access used by the data subject, will be transmitted to Google in the United States of America. These personal data are stored by Google in the United States of America. Google may pass these personal data collected through the technical procedure to third parties.
The data subject may, as stated above, prevent the setting of cookies through our website at any time by means of a corresponding adjustment of the web browser used and thus permanently deny the setting of cookies. Such an adjustment to the Internet browser used would also prevent Google Analytics from setting a cookie on the information technology system of the data subject. In addition, cookies already in use by Google Analytics may be deleted at any time via a web browser or other software programs.
Further information and the applicable data protection provisions of Google may be retrieved under: https://www.google.com/intl/en/policies/privacy/ and under: http://www.google.com/analytics/terms/us.html.
Google Analytics is further explained under the following link: https://marketingplatform.google.com/about/analytics/.
Art. 6(1) lit. a GDPR serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is party, as is the case, for example, when processing operations are necessary for the supply of goods or to provide any other service, the processing is based on Article 6(1) lit. b GDPR.
The same applies to such processing operations that are necessary for carrying out pre-contractual measures, for example in the case of inquiries concerning our products or services. If our company subject to a legal obligation by which processing of personal data is required, such as for the fulfilment` of tax obligations, the processing is based on Art. 6(1) lit. c GDPR.
In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or of another natural person. This would be the case, for example, if a visitor were injured in our company and his name, age, health insurance data or other vital information would have to be passed on to a doctor, hospital or other third party. Then the processing would be based on Art. 6(1) lit. d GDPR.
Finally, processing operations could be based on Article 6(1) lit. f GDPR. This legal basis is used for processing operations which are not covered by any of the above mentioned legal grounds, if processing is necessary for the purposes of the legitimate interests pursued by our company or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data. Such processing operations are particularly permissible because they have been specifically mentioned by the Information Controllers Office under UK Law or the European legislator. TheICO and the European legislation considers that a legitimate interest could be assumed if the data subject is a client of the controller (Recital 47 Sentence 2 GDPR)
Where the processing of personal data is based on Article 6(1) lit. f GDPR our legitimate interest is to carry out our business in favour of the well-being of all our employees and the shareholders.
The criteria used to determine the period of storage of personal data is the respective statutory retention period. After expiration of that period, the corresponding data is normally routinely deleted, as long as it is no longer necessary for the fulfilment of the contract or the initiation of a contract.
We clarify that the provision of personal data is partly required by law (e.g. tax regulations) or can also result from contractual provisions (e.g. information on the contractual partner).
Sometimes it may be necessary in order to conclude a contract that the data subject provides us with personal data, which must subsequently be processed by us. The data subject is, for example, obliged to provide us with personal data when our company signs a contract with him or her. The non-provision of the personal data would have the consequence that the contract with the data subject could not be concluded.
Before personal data is provided by the data subject, the data subject may contact our Data Protection Officer if justified. Our Data Protection Officer clarifies to the data subject whether the provision of the personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data and the consequences of non-provision of the personal data.
As a responsible company, we do not use automatic decision-making or profiling.