Lab 1 Privacy Statement

PRIVACY NOTICE

Last updated 24th June 2022


Introduction

Welcome to the Lab 1's privacy policy.

Lab 1 respects your privacy and is committed to protecting your personal data. This privacy policy explains what personal data we collect from: (i) entities contracting for Lab 1’s services (‘Lab 1 Customers’); and (ii) individuals engaging with Lab 1’s services through Lab 1 Customers (‘End Consumers’).

We keep our privacy policy under regular review. This version was last updated on 24 June 2022.

Controller

Lab 1 Limited, Cawley House, 149-155 Canal Street, Nottingham, Nottinghamshire, England, NG1 7HR is the controller and responsible for your personal data (collectively referred to as "Lab 1", "we", "us" or "our" in this privacy policy).

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.  

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact our DPO by email: dpo@lab-1.io

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 (www.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.

1. 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:

• Identity Data including title, first name, family name, date of birth, passport number, national insurance number, driving license number, employment role, employment function.

• Contact Data including postal address, email address (personal and work) and telephone numbers.

• Financial Data including bank account, payment card details and bitcoin address.

• Technical Data including internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the internet.

• Profile Data including your username, account ID, bearer token, social media handle and password.

• Marketing and Communications Data including your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not 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.

2. How is your personal data collected?

We use different methods to collect data from and about you including through:

• Direct interactions. Lab 1 Customers may give us Identity, Contact and Financial Data by filling in forms or corresponding with us. This includes personal data they provide when:

• applying for our services;

• creating an account on our website;

• signing up to use our services;

• giving us feedback or contacting us; and

• requesting marketing to be sent to you.

• Automated technologies. We will automatically collect Technical Data about Lab 1 Customers and End Consumers’ equipment, browsing actions and patterns. We collect this personal data by using search engine spiders and other similar technologies.

• Publicly available sources. We will obtain personal data about Lab 1 Customers and End Consumers from public sources as set out below:

(a) dark/deep web forums, ransomware websites, telegram channels, GitHub and Pastebin;

(b) cloud service providers such as Google.

(c) analytics providers

(d) advertising networks and

(e) search information providers

• Contact, Financial and Transaction Data from providers of technical, payment and delivery services

• Identity and Contact Data from data brokers or aggregators

• Identity and Contact Data from publicly available sources.

3. How we use your personal data

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Purpose 1

Purpose/Activity:

To register you as a Lab 1 Customer

Types of data:

(a) Identity

(b) Contact

(c) Financial

Lawful basis for  processing including basis of legitimate interest:

Performance of the services under the contract with the  Lab 1 Customer.

Purpose 2

Purpose/Activity:

To send Lab 1 Customers communications you have requested

Types of data:

Contact details

Lawful basis for  processing including basis of legitimate interest:

Consent

Purpose 3

Purpose/Activity:

To alert Lab 1 Customers to leaks and compromises of their  own data by processing data uploaded by the Lab 1 Customer and matching it  against the Lab 1 database.

Types of data:

(a) Identity

(b) Contact

(c) Profile

(f) Technical

Lawful basis for  processing including basis of legitimate interest:

Necessary for the legitimate interests of Lab 1 Customers  (detection of security risks and unlawful acts,  the prevention of fraud, and protecting Lab 1 Customers against future data  breaches and security issues)

Purpose 4

Purpose/Activity:

To provide Lab 1 Customers with reports on data leaks  involving high risk employees/officers which are a threat to the company.

Types of data:

(a) Identity

(b) Contact

(c) Profile

(f) Technical

Lawful basis for  processing including basis of legitimate interest:

Necessary for the legitimate interests of Lab 1 Customers  (to inform Lab 1 Customers of security risks involving executives)

Purpose 5

Purpose/Activity:

To provide Lab 1 Customers with reports on data leaks involving  third party suppliers or vendors within their supply chains.

Types of data:

(a) Identity

(b) Contact

(c) Profile

(f) Technical

Lawful basis for  processing including basis of legitimate interest:

Necessary for the legitimate interests of Lab 1 Customers  (to inform Lab 1 Customers of security risks within their supply chain)

Purpose 6

Purpose/Activity:

To provide Lab 1 Customers with reports on data leaks within  their organisation.

Types of data:

(a) Identity

(b) Contact

(c) Profile

(f) Technical

Lawful basis for  processing including basis of legitimate interest:

Necessary for the legitimate interests of Lab 1 Customers  (to inform Lab 1 Customers of security risks within their own organisation)

Purpose 7

Purpose/Activity:

To administer and protect our business (including data  analysis, testing, reporting and hosting of data)  

Types of data:

(a) Identity

(b) Contact

(c) Technical

Lawful basis for  processing including basis of legitimate interest:

Necessary for our legitimate interests (for running our  business and selling our services)

Purpose 8

Purpose/Activity:

To use data analytics to improve our website, services,  marketing, customer relationships and experiences

Types of data:

(a) Technical

Lawful basis for  processing including basis of legitimate interest:

Necessary for our legitimate interests (to define types of  customers for our services, to develop our business and to inform our  marketing strategy)

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us

We may use your Identity, Contact, Technical and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time 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 service purchase, service experience or other transactions.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.

4. Disclosures of your personal data

Lab 1 will not share personal data with third parties for purposes other than the following.  

We may share your personal data with the parties set out below for the purposes set out in the table Purposes for which we will use your personal data above.

• Third Parties such as Amazon Web Services and other cloud IT providers.

• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

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.

5. International transfers

We share your personal data within the Lab 1 Group. This will involve transferring your data outside the UK.

Some of our external third parties 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 at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.

• Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in 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.

8. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data:

• Request access to your personal data.

• Request correction of your personal data

• Request erasure of your personal data.

• Object to processing of your personal data.

• Request restriction of processing your personal data.

• Request transfer of your personal data.

• Right to withdraw consent.

To the extent that personal data is processed on the basis of legitimate interests, data subjects have the right to object to the processing of their personal data, provided that there are reasons arising from the data subjects' particular situation. For exercising the right to object or any of the other rights set out above, please contact us via email dpo@lab-1.io

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.