INTRODUCTION
Gibson Robotics Ltd
Company Number SC650555
Higgs Centre For Innovation, Royal Observatory Edinburgh, Blackford Hill , Edinburgh, EH9 3HJ, United Kingdom
Website Privacy Policy
1.1 Important information and who we are
Welcome to Gibson Robotics Ltd’s Privacy and Data Protection Policy (“Privacy Policy”).
At Gibson Robotics Ltd (“we”, “us”, or “our”) we are committed to protecting and respectingyour privacy and Personal Data in compliance with the United Kingdom General DataProtection Regulation (“GDPR”), the Data Protection Act 2018 and all other mandatory lawsand regulations of the United Kingdom.This Privacy Policy explains how we collect, process and keep your data safe. The PrivacyPolicy will tell you about your privacy rights, how the law protects you, and inform ouremployees and staff members of all their obligations and protocols when processing data.The individuals from which we may gather and use data can include any people that theorganisation has a relationship with or may need to contact.This Privacy Policy applies to all our employees and staff members and all Personal Data processed at any time by us.
1.2 Who is Your Data Controller
Gibson Robotics Ltd is your Data Controller and responsible for your Personal Data. Weare not obliged by the GDPR to appoint a data protection officer and have not voluntarilyappointed one at this time. Therefore, any inquiries about your data should either be sentto us on email at ellie@gibsonrobotics.com or sent in a letter to Higgs Centre ForInnovation, Royal Observatory Edinburgh, Blackford Hill , Edinburgh, EH9 3HJ, UnitedKingdom. 1
1 December 2023
You have the right to make a complaint at any time to the Information Commissioner’sOffice (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). Wewould, however, appreciate the chance to deal with your concerns before you approachthe ICO so please contact us in the first instance.
1.3 Processing Data on Behalf of a Controller and Processors’ responsibility to you
In discharging our responsibilities as a Data Controller we have employees who will dealwith your data on our behalf (known as “Processors”). Therefore, the responsibilitiesdescribed below may be assigned to an individual, or may be taken to apply to theorganisation as a whole. The Data Controller and our Processors have the followingresponsibilities:
Ensure that all processing of Personal Data is governed by one of the legal baseslaid out in the GDPR (see 2.2 below for more information on those bases);
Ensure that Processors authorised to process Personal Data have committedthemselves to confidentiality or are under an appropriate statutory obligation ofconfidentiality;
Implement appropriate technical and organisational measures to ensure a level ofsecurity appropriate to the risk associated with the processing of Personal Data;
Obtain the prior specific or general authorisation of the Controller before engaginganother Processor;
Assist the Controller in the fulfilment of the Controller's obligation to respond torequests for exercising the data subject's rights;
Make available to the Controller all information necessary to demonstratecompliance with the obligations laid down in the GDPR and allow for and contributeto audits, including inspections, conducted by the Controller or another auditormandated by the Controller;
Maintain a record of all categories of processing activities carried out on behalf of aController;
Cooperate, on request, with the supervisory authority in the performance of itstasks;
Ensure that any person acting under the authority of the Processor who has accessto Personal Data does not process Personal Data except on instructions from theController; and
Notify the Controller without undue delay after becoming aware of a Personal DataBreach;
2 LEGAL BASIS FOR DATA COLLECTION
2.1 Types of Data / Privacy Policy Scope
“Personal Data” means any information about an individual from which that person canbe identified. It does not include data where the identity has been removed (anonymousdata). 2
We may collect, use, store and transfer different kinds of Personal Data about you whichwe have grouped together below. Not all of the following types of data will necessarily becollected from you but this is the full scope of data that we collect and when we collect itfrom you:
Profile/Identity Data: This is data relating to your first name, last name, gender, dateof birth.
Contact Data: This is data relating to your phone number, addresses, emailaddresses, phone numbers.
work experience: this is data relating to previous work history and relevantinformation provided for the purposes of applying for a role.
We do not collect any Special Categories of Personal Data about you (this includes detailsabout your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation,political opinions, trade union membership, information about your health, and geneticand biometric data). Nor do we collect any information about criminal convictions andoffences.
2.2 The Legal Basis for Collecting That Data
There are a number of justifiable reasons under the GDPR that allow collection andprocessing of Personal Data. The main avenues we rely on are:
“Consent”: Certain situations allow us to collect your Personal Data, such as whenyou tick a box that confirms you are happy to receive email newsletters from us, or‘opt in’ to a service.
“Contractual Obligations”: We may require certain information from you in orderto fulfil our contractual obligations and provide you with the promised service.
“Legal Compliance”: We’re required by law to collect and process certain types ofdata, such as fraudulent activity or other illegal actions.
“Legitimate Interest”: We might need to collect certain information from you to beable to meet our legitimate interests - this covers aspects that can be reasonablyexpected as part of running our business, that will not have a material impact onyour rights, freedom or interests. Examples could be your address, so that we knowwhere to deliver something to, or your name, so that we have a record of who tocontact moving forwards.
3 HOW WE USE YOUR PERSONAL DATA
3.1 Our Uses
We will only use your Personal Data when the law allows us to. Set out below is a tablecontaining the different types of Personal Data we collect and the lawful basis forprocessing that data. Please refer to section 2.2 for more information on the lawful basislisted in the table below.
Examples provided in the table below are indicative in nature and the purposes for whichwe use your data may be broader than described but we will never process your datawithout a legal basis for doing so and it is for a related purpose. For further inquiriesplease contact us. 3 Activity Type ofdata LegalJustification Lawful basis forprocessing data When an individual submits acontact form or applies for ajob role. Profile/IdentityData ConsentLegitimateInterestNecessity We need to process thisdata to respond to theindividual's request. When an individual submits acontact form or applies for ajob role. ContactData ConsentLegitimateInterestNecessity We need to process thisdata to respond to theindividual's request. 3.2 Change of Purpose
We will only use your Personal Data for the purposes for which we collected it, unless wereasonably consider that we need to use it for another reason and that reason iscompatible with the original purpose. If you wish to get an explanation as to how theprocessing 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 wewill explain the legal 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.
4 YOUR RIGHTS AND HOW YOU ARE PROTECTED BY US
4.1 How Does Gibson Robotics Ltd Protect Customers' Personal Data?
We are concerned with keeping your data secure and protecting it from inappropriatedisclosure. Any Personal Data collected by us is only accessible by a limited number ofemployees who have special access rights to such systems and are bound by obligationsof confidentiality. If and when we use subcontractors to store your data, we will notrelinquish control of your Personal Data or expose it to security risks that would not havearisen had the data remained in our possession. However, unfortunately no transmissionof data over the internet is guaranteed to be completely secure. It may be possible forthird parties not under the control of Gibson Robotics Ltd to intercept or accesstransmissions or private communications unlawfully. While we strive to protect yourPersonal Data, we cannot ensure or warrant the security of any Personal Data youtransmit to us. Any such transmission is done at your own risk. If you believe that yourinteraction with us is no longer secure, please contact us.
4.2 How to Request your Data and the Process for Obtaining it
You will not have to pay a fee to access your Personal Data (or to exercise any of the otherrights). However, if your request is clearly unfounded, we could refuse to comply with yourrequest.
We may need to request specific information from you to help us confirm your identityand ensure you have the right to access your Personal Data (or to exercise any of your 4 other rights). This is a security measure to ensure that Personal Data is not disclosed toany person who has no right to receive it. We may also contact you to ask you for furtherinformation in relation to your request to speed up our response.
5 YOUR DATA AND THIRD PARTIES
5.1 Will We Share Your Data With Third Parties? We may also share Personal Data with interested parties in the event that Gibson Robotics Ltd anticipates a change in control or the acquisition of all or part of our business or assetsor with interested parties in connection with the licensing of our technology. If Gibson Robotics Ltd is sold or makes a sale or transfer, we may, in our sole discretion,transfer, sell or assign your Personal Data to a third party as part of or in connection withthat transaction. Upon such transfer, the Privacy Policy of the acquiring entity may governthe further use of your Personal Data. In all other situations your data will still remainprotected in accordance with this Privacy Policy (as amended from time to time).
We may share your Personal Data at any time if required for legal reasons or in order toenforce our terms or this Privacy Policy.
5.2 Third-Party Links
This Site may include links to third-party websites, plug-ins and applications. Clicking onthose links or enabling those connections may allow third parties to collect or share dataabout you. We do not control these third-party websites and are not responsible for theirprivacy statements. When you leave our Site, we encourage you to read the privacy policyof every website you visit. 6 HOW LONG WILL WE RETAIN YOUR DATA FOR?
We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposeswe collected it for. We may retain your Personal Data for a longer period than usual in the eventof a complaint or if we reasonably believe there is a prospect of litigation in respect to ourrelationship with you.
7 INTERNATIONAL TRANSFER OF DATA
Your information may be stored and processed in the US or other countries or jurisdictionsoutside the US where Gibson Robotics Ltd has facilities. We are currently storing data in the EUand so, by using Gibson Robotics Ltd, you are permitting and consenting to the transfer ofinformation, including Personal Data, outside of the US.
8 NOTIFICATION OF CHANGES AND ACCEPTANCE OF POLICY
We keep our Privacy Policy under review and will place any updates on this webpage. Thisversion is dated 1 December 2023. By using Gibson Robotics Ltd, you consent to the collectionand use of data by us as set out in this Privacy Policy. Continued access or use of Gibson RoboticsLtd will constitute your express acceptance of any modifications to this Privacy Policy.
9
INTERPRETATION
All uses of the word "including" mean "including but not limited to" and the enumerated examples are not intended to in any way limit the term which they serve to illustrate. Any email 5 addresses set out in this policy may be used solely for the purpose for which they are stated tobe provided, and any unrelated correspondence will be ignored. Unless otherwise required bylaw, we reserve the right to not respond to emails, even if they relate to a legitimate subjectmatter for which we have provided an email address. As a matter of common sense, you aremore likely to get a reply if your request or question is polite, reasonable and there is norelatively obvious other way to deal with or answer your concern or question (e.g. FAQs, otherareas of our website etc.).
Our staff are not authorised to contract on behalf of Gibson Robotics Ltd, waive rights or makerepresentations (whether contractual or otherwise). If anything contained in an email from aGibson Robotics Ltd address contradicts anything in this policy, our terms or any official publicannouncement on our website, or is inconsistent with or amounts to a waiver of any GibsonRobotics Ltd rights, the email content will be read down to grant precedence to the latter. The only exception to this is genuine correspondence expressed to be from the Gibson Robotics Ltdlegal department.
