Privacy
Policy

Last updated: 1 January 2025

1. Who We Are

STOCKSNAP LTD is a technology strategy consulting company registered in Scotland, United Kingdom. Our principal place of business is 2/1 51 Fergus Drive, Glasgow, G20 6AQ. We provide technology strategy consulting, software development, cloud computing, cybersecurity, data analytics, systems integration, DevOps, and digital transformation services to businesses across the United Kingdom.

For the purposes of data protection law, STOCKSNAP LTD is the data controller in respect of personal data collected and processed through our website at stocksnap.work and through the course of our business operations. As data controller, we are responsible for deciding how and why personal data is processed.

Our contact details for data protection purposes are: assist@stocksnap.work, or by post to 2/1 51 Fergus Drive, Glasgow, G20 6AQ, United Kingdom.

2. Scope of This Policy

This Privacy Policy applies to all personal data we collect and process in connection with the use of our website at stocksnap.work, the submission of enquiries and briefs through our contact form or by electronic mail, the performance of consulting and technology services under engagement agreements with our clients, recruitment and employment-related processing, and any other interaction between you and STOCKSNAP LTD where personal data is involved.

This policy does not apply to third-party websites, platforms, or services that may be linked to or from our website. We have no control over those third parties and accept no responsibility for their privacy practices. We encourage you to review the privacy policies of any third-party website you visit.

If you are a business client and your engagement with STOCKSNAP LTD involves the processing of personal data on your behalf, a separate data processing agreement will govern those arrangements in accordance with Article 28 of UK GDPR. This policy governs only the processing for which STOCKSNAP LTD acts as data controller.

3. Legal Basis for Processing

UK GDPR requires that every instance of personal data processing is supported by a valid legal basis. STOCKSNAP LTD processes personal data on the following legal bases, depending on the purpose and nature of the processing:

Contractual Necessity

Where processing is necessary to perform a contract to which you are a party, or to take steps at your request before entering into a contract, we rely on contractual necessity as our legal basis. This applies principally to the processing of client contact and engagement data required to deliver our consulting and technology services.

Legitimate Interests

Where processing is necessary for the purposes of our legitimate business interests, and where those interests are not overridden by your fundamental rights and freedoms, we rely on legitimate interests as our legal basis. Our legitimate interests include managing our business operations, communicating with prospective clients who have contacted us, maintaining and improving our website, protecting our business against fraud and security threats, and sending relevant service communications to existing clients.

Legal Obligation

Where processing is necessary to comply with a legal obligation to which STOCKSNAP LTD is subject, we rely on legal obligation as our legal basis. This applies to processing required under Scottish and UK law, including tax and accounting obligations, anti-money laundering requirements, and data subject rights requests.

Consent

Where we process personal data on the basis of consent, we will obtain that consent clearly and explicitly before commencing such processing. You have the right to withdraw your consent at any time by contacting us at assist@stocksnap.work. Withdrawal of consent will not affect the lawfulness of processing conducted prior to the withdrawal.

4. Personal Data We Collect

We collect and process the following categories of personal data, depending on the nature of your interaction with us:

Enquiry and Brief Submission Data

When you submit a brief or enquiry through our website contact form or by electronic mail, we collect your name, email address, company or organisation name, telephone number (if provided), and the content of your message including any description of your technology requirements. This data is used solely to respond to your enquiry and to determine whether an engagement is appropriate.

Client Engagement Data

In the course of providing services to clients, we collect and process personal data relating to the individuals within your organisation who are involved in the engagement. This may include names, job titles, email addresses, telephone numbers, and any personal data contained in documents, communications, or systems provided to us as part of the service scope. We process such data only as necessary to deliver the agreed services.

Website Usage Data

When you visit our website at stocksnap.work, our hosting and analytics systems may automatically collect technical information including your IP address (in anonymised form where possible), browser type and version, operating system, referring URL, the pages you visit on our website, the time and duration of your visit, and similar technical metadata. This data is processed for the purposes of maintaining website security and improving user experience.

Communications Data

If you contact us by electronic mail, telephone, or post, we retain records of those communications for the purposes of responding to you and maintaining an accurate record of interactions relevant to our business relationship. We do not record telephone calls without prior notification.

Supplier and Contractor Data

We process personal data relating to individual suppliers, contractors, and specialist practitioners who work with us in connection with client engagements. This includes contact details, professional qualifications, and contractual information necessary to manage those relationships.

5. How We Use Your Personal Data

We use personal data for the following purposes:

• To respond to enquiries and briefs submitted through our website or by other means
• To assess whether a consulting or development engagement is appropriate and to prepare proposals
• To deliver technology strategy consulting, software development, cloud, cybersecurity, data analytics, integration, DevOps, and digital transformation services under agreed contracts
• To manage the commercial aspects of client engagements including invoicing, payment processing, and contract administration
• To communicate with clients, contractors, and suppliers during the course of active and historic engagements
• To maintain accurate business records and to comply with our accounting and tax obligations under UK law
• To monitor and improve the performance, security, and content of our website
• To protect STOCKSNAP LTD against fraud, security threats, and unlawful activity
• To comply with our legal and regulatory obligations under Scottish and UK law

We do not use personal data for automated decision-making or profiling in a manner that produces legal or similarly significant effects on individuals. We do not sell personal data to third parties under any circumstances. We do not use personal data collected in connection with client service delivery for marketing purposes without explicit consent.

6. Data Retention

We retain personal data for no longer than is necessary for the purposes for which it was collected, subject to applicable legal requirements. Our standard retention periods are as follows:

Enquiry and Pre-Engagement Data

Personal data submitted through our contact form or by enquiry email where no engagement proceeds is retained for a period of twelve months from the date of the enquiry. After this period, we delete or anonymise this data unless you have requested further contact or unless a regulatory requirement obliges continued retention.

Client Engagement Records

Personal data held in connection with active and completed client engagements, including contracts, correspondence, invoices, project documentation, and related records, is retained for a period of seven years from the end of the financial year in which the engagement concluded. This retention period reflects our obligations under the Companies Act 2006, HMRC requirements, and applicable limitation periods for commercial disputes under the Limitation Act 1980.

Website Analytics Data

Technical data collected from website visits is retained for a maximum of twenty-six months before deletion or full anonymisation, in line with standard analytics best practice. Anonymised aggregate data may be retained indefinitely for statistical purposes.

Supplier and Contractor Records

Personal data relating to suppliers and contractors is retained for the duration of the commercial relationship and for a further period of six years following the termination of that relationship, for the same legal and accounting reasons applied to client engagement data.

7. Sharing and Disclosure of Personal Data

STOCKSNAP LTD does not sell, rent, or trade personal data with third parties for their own commercial purposes. We may share personal data in the following limited circumstances:

Service Providers and Sub-Processors

We engage trusted third-party service providers to support our business operations, including cloud hosting and infrastructure providers, email and communication platforms, accounting and finance software, and project management tools. These providers act as data processors under Article 28 of UK GDPR and are bound by data processing agreements requiring them to protect your personal data and to process it only on our documented instructions. We do not permit sub-processors to use your data for their own independent purposes.

Professional Advisers

We may share personal data with our legal advisers, accountants, auditors, and insurers where necessary for the conduct of our business and the management of legal and commercial matters. All such advisers are subject to professional confidentiality obligations.

Law Enforcement and Regulatory Authorities

We may disclose personal data to law enforcement agencies, regulatory bodies, courts, or other public authorities where we are required to do so by applicable law, court order, or regulatory requirement, or where we believe such disclosure is necessary to protect the safety, rights, or property of STOCKSNAP LTD, our clients, or third parties.

Business Transfers

In the event that STOCKSNAP LTD undergoes a corporate restructuring, merger, acquisition, or sale of all or a substantial part of its business assets, personal data held by us may be transferred to the acquiring entity as part of that transaction, subject to appropriate confidentiality protections and notification to affected individuals where required by law.

8. International Data Transfers

STOCKSNAP LTD is based in the United Kingdom and processes personal data primarily within the UK. Where we use third-party service providers who process data in countries outside the UK, we ensure that appropriate safeguards are in place to protect your data in accordance with UK GDPR requirements. These safeguards may include the UK International Data Transfer Agreement (UK IDTA), the UK Addendum to the EU Standard Contractual Clauses, or a decision by the UK Secretary of State that the destination country provides adequate data protection.

If you would like further information about the specific safeguards applied to any international transfer of your personal data, please contact us at assist@stocksnap.work.

9. Cookies and Tracking Technologies

Our website uses cookies and similar tracking technologies to support its operation and to enable us to understand how visitors interact with our content. Full details of the cookies we use, their purposes, and how you can manage your cookie preferences are set out in our Cookie Policy.

You can control cookie settings through your browser settings or through our cookie management tool. Please note that restricting certain cookies may affect the functionality of our website.

10. Security of Personal Data

We take the security of personal data seriously and implement appropriate technical and organisational measures to protect the personal data we hold against unauthorised or unlawful processing, accidental loss, destruction, or damage. Our security measures include encryption of data in transit and at rest where appropriate, access controls limiting personal data access to individuals who require it for their work functions, regular security assessments of our own systems and processes, staff awareness of data protection obligations, and secure disposal procedures for data that has reached the end of its retention period.

While we take every reasonable precaution to protect your personal data, no transmission of data over the internet and no storage system can be guaranteed to be absolutely secure. If you believe your personal data has been compromised, please notify us immediately at assist@stocksnap.work so that we can take appropriate action.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the Information Commissioner's Office (ICO) within 72 hours of becoming aware of the breach, in accordance with our obligations under UK GDPR Article 33. Where the breach is likely to result in a high risk to your rights and freedoms, we will also notify you directly without undue delay.

11. Your Rights Under UK GDPR

Under the UK General Data Protection Regulation and the Data Protection Act 2018, you have the following rights in relation to your personal data held by STOCKSNAP LTD:

Right of Access

You have the right to request a copy of the personal data we hold about you, along with information about how we process it. This is known as a Subject Access Request. We will respond to valid requests within one calendar month of receipt, though we may extend this period by a further two months where requests are complex or numerous, in which case we will notify you of the extension within the first month.

Right to Rectification

You have the right to require us to correct personal data that is inaccurate and to complete personal data that is incomplete. If you believe we hold inaccurate or incomplete data about you, please contact us and we will rectify it without undue delay.

Right to Erasure

You have the right to request that we erase your personal data in certain circumstances, including where the data is no longer necessary for the purpose for which it was collected, where you have withdrawn consent on which processing is based, where you have objected to processing and there are no overriding legitimate grounds, or where the data has been unlawfully processed. This right is subject to exceptions, including where retention is required to comply with a legal obligation or to establish, exercise, or defend legal claims.

Right to Restriction of Processing

You have the right to request that we restrict the processing of your personal data in certain circumstances, including where you contest the accuracy of the data, where you have objected to processing and verification is pending, or where the processing is unlawful but you do not want the data erased.

Right to Data Portability

Where processing is based on your consent or on a contract and is carried out by automated means, you have the right to receive the personal data you have provided to us in a structured, commonly used, machine-readable format, and to request that we transmit that data to another controller where technically feasible.

Right to Object

You have the right to object to the processing of your personal data where that processing is based on our legitimate interests. We will cease processing unless we can demonstrate compelling legitimate grounds that override your interests, rights, and freedoms, or where the processing is necessary for the establishment, exercise, or defence of legal claims.

Rights Related to Automated Decision-Making

You have the right not to be subject to decisions based solely on automated processing, including profiling, which produce legal or similarly significant effects. STOCKSNAP LTD does not make decisions about individuals based solely on automated processing.

12. How to Exercise Your Rights

To exercise any of your rights under UK GDPR, please contact us using the following details. We will respond to all valid requests within one calendar month without charge in the first instance, though we reserve the right to charge a reasonable administrative fee for manifestly unfounded or excessive requests, or to refuse to act on such requests after notifying you of our reasons.

You may contact us by electronic mail at assist@stocksnap.work, or by post addressed to: Data Protection, STOCKSNAP LTD, 2/1 51 Fergus Drive, Glasgow, G20 6AQ, United Kingdom. Please provide sufficient information to allow us to identify you and to verify that you are entitled to make the request. We may require proof of identity before processing requests in order to protect the personal data of the individuals concerned.

13. Complaints

If you are dissatisfied with the way in which STOCKSNAP LTD has handled your personal data, or if you believe we have not complied with our obligations under UK GDPR or the Data Protection Act 2018, we encourage you to contact us in the first instance at assist@stocksnap.work so that we may address your concern directly.

If you remain dissatisfied after contacting us, you have the right to lodge a complaint with the Information Commissioner's Office (ICO), the supervisory authority for data protection in the United Kingdom. The ICO can be contacted at: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. Telephone: 0303 123 1113. Website: ico.org.uk.

14. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our processing activities, changes in applicable law, or changes in the services we provide. Any material changes will be posted on this page with an updated effective date. We encourage you to review this policy periodically to stay informed about how we protect your personal data.

Where changes are significant, we may also notify existing clients directly by electronic mail. Your continued use of our website or services following the posting of changes constitutes your acknowledgement of the updated policy.

15. Contact

For any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by STOCKSNAP LTD, please contact us:

STOCKSNAP LTD
2/1 51 Fergus Drive
Glasgow, G20 6AQ
United Kingdom
Telephone: +44 7635 669922
Electronic mail: assist@stocksnap.work
Website: stocksnap.work