Procyon Limited Privacy & Data Protection Policy: Updated: 23rd May 2018
1. This Policy
At Procyon, we take privacy and the protection of your data very seriously.
This policy has been updated to ensure that we communicate, in the clearest
way possible, how we treat personal information that we gather as part of
We encourage You to read this Policy carefully. It will help You make
informed decisions about sharing your personal information with us. All
data that we collect and process, is in line with the requirements of the
2. Our services and your data
2.1 About Us
is a supplier of Audio Visual (AV) equipment and display technology,
and is a developer and supplier of software products and services
including online platforms, APIs and mobile applications concentrating
on the digital signage and associated technologies market.
The operation of our business and the services we provide to clients
involve the storage of data about the users of our systems, and data that
our users upload within our software and services.
That Data can include personal information.
"Personal information" is information about an identifiable individual, and
may include information such as the individual's name, email address and
what organisations and companies they work for, and digital likeness
Procyon does not directly collect information about or from children, and
our websites are not designed for use by, or marketed to children.
Our brands include Procyon, d|sign, CoolAV and InfoLocal.
2.2 Collection of your data
Procyon may collect personal information directly from You when You:
- Enquire about a product or service online, by phone, by email or in person
- Register to use a service
- Purchase a product or subscribe to use a service
- Use a software service
- Contact the Procyon support team
- Visit our Websites.
You can always choose not to provide Your personal information to Procyon
Limited, but it may mean that we are unable to provide you with a product,
service or support.
Personal Information may also be processed by Procyon when it is provided
to us by a client in the act of their usage of our software or services,
- Details of people that have signed into a venue, or expected visitors
- Content provided for use on digital displays.
Where a 3rd party is providing your data as part of their use of
one of Procyon's services, it is the responsibility of the organisation
entering personal data into the systems to make sure that they have a
legitimate basis, or informed consent to provide that data.
2.3 Processing (using) your data
Procyon Ltd will process (collect, store and use) the information you
provide in a manner compatible with the EU's General Data Protection
The use of the data may include:
- For administration of a provided service or contract
- To contact you regarding account management and service
- To tell you about other services and products we offer that may interest you
2.4 When will Procyon contact me
Procyon will contact you:
- as required by the examples in section 2.3
- to notify you in the event of a confirmed data breach.
- to confirm a request for data subject records
2.5 Aggregation of your non-personally identifiable data
By using Procyon's Services, You agree that Procyon can access, aggregate
and use non-personally identifiable data Procyon has collected from You.
This data will in no way identify You or any other individual. Procyon may
use this aggregated non-personally identifiable data to:
- assist us to better understand how our customers are using the Service
- provide our customers with further information regarding the uses and benefits of the Service
- enhance productivity, including by creating useful insights from that aggregated data and allowing You to benchmark Your performance against that aggregated data, and
- otherwise to improve the Service.
The company directors are responsible for ensuring that this notice is made
available to data subjects prior to Procyon Limited collecting/processing
their personal data.
3.2. Employees of Procyon
All Employees of Procyon Limited who interact with data subjects are
responsible for ensuring that this notice is drawn to the data subject's
attention and that if the information is to be used for marketing purposes,
that their consent to the processing of their data is secured directly.
We undertake not to ask irrelevant or unnecessary questions, or requests
for data beyond the scope of our business activities
3.4 Unauthorised Access
The information you provide will be subject to rigorous measures and
procedures to minimise the risk of unauthorised access or disclosure.
We endeavour to store your data securely in digital form only, on-premise
or in UK data centres.
3.6 Breaches of data
Should a data breach be detected, we will inform the necessary authority
and affected data subjects as soon as possible.
4. Privacy Notice
4.1 Contacting Procyon
A Data Protection Officer (DPO) or Data Protection Representative can be
contacted directly here:
Tel: 0800 999 3700 (Standard Office hours only)
4.2 Use of your data
The personal data Procyon may collect from you will be used for the
- Allowing you to access our products and services (Legitimate Interest)
- Administering our services to you (Legitimate Interest)
- Fulfilling and maintaining contracts you, or your employer may have with us (Contract)
- The marketing of our other products and services to you. (Consent)
Our legal basis for the processing of your personal data includes:
Consent - the individual has given clear consent for us to process their personal data for a specific purpose
Contract - the processing is necessary to fulfil a contract we have with either the individual or an organisation for which the individual is acting, or because they have asked us to take specific steps before entering into a contract
Legitimate Interest - the data is necessary for administering or maintaining a service we provide, or have previously provided (such as login credentials)
Procyon does not sell or transfer Personal Information to third parties
unless it is required as part of the service the client has requested from
us and we have consent to do so, or required to do so by law
Where consent is the legal basis for the processing of your personal data,
it may be given by phone, in email or by actively selecting the option to
give consent on a web page or in a mobile application or software program.
You can withdraw consent at any time by contacting us by phone, email, post
or web form or by following the appropriate option on marketing emails.
4.4 Data Retention
Procyon Limited will process personal data for as long as required by the
legitimate interest, or until consent is withdrawn and only for the
retention period in line with the GDPR.
We will endeavour to keep your information accurate and up to date, and not
keep it for longer than is necessary.
Procyon Limited is required to retain information in accordance with the
law, such as information needed for income tax and audit purposes. How long
certain kinds of personal data should be kept may also be governed by
specific business-sector requirements and agreed practices. Personal data
may be held in addition to these periods depending on individual business
4.5 Your Privacy Rights
At any point while Procyon is in possession of or is processing your
personal data, you, the data subject, have the following rights:
Right of access
- you have the right to request a copy of the information that we hold
about you. Procyon may request suitable identification to make sure you
are entitled to receive this information. See section 4.6 below.
Right of rectification
- you have a right to correct data that we hold about you that is
inaccurate or incomplete.
Right to be forgotten
- in certain circumstances you can ask for the data we hold about you
to be erased from our records.
Right to restriction of processing
- where certain conditions apply to have a right to restrict the
Right of portability
- you have the right to have the data we hold about you transferred to
Right to object
- you have the right to object to certain types of processing such as
Right to object to automated processing
, including profiling - you also have the right to be subject to the
legal effects of automated processing or profiling, if the decision
produces legal effects concerning you or significantly affects you in a
Right to judicial review
: if Procyon Limited refuses your request under rights of access, we
will provide you with a reason as to why. You have the right to
complain as outlined in clause 4.6 below.
All of the above requests will be forwarded on should there be a third
party involved in the processing of your personal data.
In the event that you wish to make a complaint about how your personal data
is being processed by Procyon Limited (or third parties as described), or
how your complaint has been handled, you have the right to lodge a
complaint directly with the supervisory authority and Procyon Limited's
data protection officer (DPO).
4.7 Requesting a copy of your data
Procyon Limited, at your request, can confirm what information we hold
about you and how it is processed. If Procyon Limited does hold personal
data about you, you can request the following information:
- Identity and the contact details of the person or organisation that
has determined how and why to process your data. In some cases, this will
be a representative in the EU.
- Contact details of the data protection officer, where applicable.
- The purpose of the processing as well as the legal basis for
- If the processing is based on the legitimate interests of Procyon
Limited or a third party, information about those interests.
- The categories of personal data collected, stored and processed.
- Recipient(s) or categories of recipients that the data is/will be
- If we intend to transfer the personal data to a third country or
international organisation, information about how we ensure this is done
securely. The EU has approved sending personal data to some countries
because they meet a minimum standard of data protection. In other cases, we
will ensure there are specific measures in place to secure your
- How long the data will be stored.
- Details of your rights to correct, erase, restrict or object to such
- Information about your right to withdraw consent at any time.
- How to lodge a complaint with the supervisory authority.
- Whether the provision of personal data is a statutory or contractual
requirement, or a requirement necessary to enter into a contract, as well
as whether you are obliged to provide the personal data and the possible
consequences of failing to provide such data.
- The source of personal data if it wasn't collected directly from
- Any details and information of automated decision making, such as
profiling, and any meaningful information about the logic involved, as well
as the significance and expected consequences of such processing.
In order to provide this information, we will need to verify your identify.
Procyon Limited accepts the following forms of ID when information on your
personal data is requested: