1. Important information and who we are
We own a search index database which: (i) is purpose-built for, and used by, online law enforcement investigators of internet crimes against children ( “ICAC” ), modern slavery, human trafficking, counter-terrorism and similar crimes and offences; and (ii) indexes imagery across the web to assist investigators to match online and offline personas in the retrieval of vital intelligence (our “Services” ).
We are the controllers of: (i) the personal data included in our search index (i.e. the “Indexed Content” as defined below); (ii) the records ( “User Data” ) we keep of the Services we provide to the representatives, admin users and the end user investigators ( “Users” ) of our law enforcement agency customers ( “LEACs” ), but always excluding the content of the Users’ searches; (iii) any other personal data we collect from our website which includes visitors accessing our website and other users that interact directly with us through our website ( “Website Data” ); and (iv) marketing data we collect from potential customers.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues 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.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
2. The data we collect about you
Personal data, or personal information, 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:
The User Data includes:
- Identity Data: first name, last name, username or similar identifier, title, of the representatives of the LEACs to which we provide our Services.
- Contact Data: includes billing address, delivery address, email address and telephone numbers of the representatives of the LEACs to which we provide our Services.
- Communications Data: records of our communications with the Users.
- Indexed Content: includes metadata and derived information extracted from images (image hashes, etc.) but not the images. This data, together with the image URL is indexed and stored in our search index. We do not store the images in our Service. The Indexed Content is generated through a continuous process of automated web crawling to locate suitable images for indexing. We select a broad range of websites on the open web and the dark web prioritising those sites that are most likely to yield useful results for our LEACs’ investigations.
- Website Data: includes information about how you use our website.
- Marketing Data: includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We do not knowingly 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. However, the Indexed Content could link to images containing any of the foregoing data if such information is published on the internet.
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 User Data by filling in forms or by corresponding with us by post, phone, email or otherwise or when using our Services.
- Website Data, automated technologies or interactions. As you interact with our website, we may automatically collect Website 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 settings (accessible from the footer of www.cameraforensics.com for further details.
- Third parties or publicly available sources. We collect the Indexed Content from information publicly available on the internet.
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.
Generally, we do not rely on consent as a legal basis for processing your personal data for the purposes listed below. We will get your consent for any new processing purposes - for example before sending third party direct marketing communications to you via email or text message. You have the right to subsequently withdraw such consent at any time by contacting us.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the lawful bases for processing we rely on to do so. We have also identified what our legitimate interests are where appropriate.
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 data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register a new LEAC||(a) Identity|
|Performance of a contract with a new LEAC|
|To process and deliver our LEAC's orders including:|
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
|(a) Performance of a contract with a LEAC|
(b) Necessary for our legitimate interests (to recover debts due to us)
|To manage our relationship with our LEACs which will include:|
(b) Asking them to take a survey
|(a) Performance of a contract with a LEAC|
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
|To provide our Services to our Customers||(a) Indexed Content||(a) Legitimate Interests (we feed our search Index with Indexed Content, to assist our Users (LEAC investigators) in their investigations and provide the Services to them).|
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity|
(d) Indexed Content
|(a) 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 reorganisation or group restructuring exercise) and to provide our Services|
(b) Necessary to comply with a legal obligation
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences||(a) Website Data||Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
Promotional offers and Marketing information from us
You will receive marketing communications from us if you have requested information or purchased services from us and you have opted to receive that marketing.
You can ask us 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.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, use of a product/service or other direct communications.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the lawful basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. Disclosures of your personal data
We may share your personal data with the parties set out below for the purposes set out in the table above.
- Business partners where doing so is necessary for the performance of our contractual relationship with our LEACs.
- Service providers who provide us with IT and system administration services or any other services we require to operate our business.
- Professional advisers including lawyers, bankers, auditors and insurers.
- HM Revenue & Customs (United Kingdom), regulators and other authorities.
- Our successors in title, our prospective sellers or buyers of our business or to our affiliates when we have a merger or re-organisation business or assets.
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.
Some of our LEAC’s are 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 that we only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
Please contact us if you want further information on the specific mechanisms used by us when transferring your personal data out of the UK.
6. 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.
7. Data retention
How long will you use my personal data for?
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.
In some circumstances you can ask us to delete your data: see your legal rights below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
8. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
- The right of access: You can request a copy of the Personal Data we hold about you and to check that we are lawfully processing it.
- The right to rectification: You can request correction of the Peronsl Data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- The right to erasure: You can ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- The right to restrict processing: You can request restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of your Personal Data in the following scenarios: (a) If you want us to establish the data’s accuracy; (b) Where our use of the data is unlawful but you do not want us to erase it; (c) Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; and (d) You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- The right to portability: You can request the transfer of your Personal Data to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- The right to object: You can object to processing of your Personal Data where we are relying on a legitimate interest (or those of a third party) and there is something about your situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Rights in relation to automated decision making and profiling: We do not carry out such activities.
9. Subject Access Request
You can make a Subject Access Request by contacting us at any time at email@example.com.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time Limit to Respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.
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. We will notify you if this is the case at the time.
It may not be possible for us to delete your Personal Data if we are required to keep it by law or if we hold it in connection with a contract with you. Similarly, access to your Personal Data may be refused if making the information available would reveal Personal Data about another person or if we are legally prevented from such disclosure.
If you wish to exercise any of the rights set out above, please contact us at firstname.lastname@example.org.