Privacy Policy UK & EU

1. Overview

See Me Please considers privacy to be important and is committed to protecting the personal data of all its clients, testers and users.

This Privacy Policy (Policy) sets out how we collect, hold, use and disclose information about all individuals who deal or interact with us including, without limitation, user testers, client organisations and subscribers (you). This Policy will inform you how we look after your personal data and tell you about your privacy rights and how the law protects you.

See Me Please operates a digital native, user testing platform aimed at providing organisations with insights and feedback from diverse and disabled users to improve the usability of their services, known as ‘See Me Please’. See Me Please clients are service providers and organisations (Client Organisations). Members of our Client Organisations utilise our platform to access digital accessibility insights and feedback provided by user testers (User Testers).

This Policy explains how we handle your personal data, whether you are a Client Organisation, a User Tester or if you subscribe to our news and updates.

Neither our website nor our direct services are intended for children, and we do not knowingly collect data relating to children and do not appoint children as User Testers.

We keep our privacy policy under regular review; this version was last updated on the date stated at the beginning of it.

2. Who We Are and Our Contact Details

See Me Please is made up of different legal entities, and you can find out more about us on our website: https://seemeplease.com/about

This Policy is issued on behalf of the See Me Please Group so when we say See Me Please, we, us, and our in this Policy, we are referring to the relevant See Me Please company in the group responsible for processing your personal data. As a UK or EU based individual, your personal data will be processed by our UK company, please see our details below. 

If you have any questions about this Policy or our privacy practices, please contact us in the following ways:

Full name of legal entity: SEE ME PLEASE LIMITED (Company Number: 15736988), incorporated and registered in England and Wales. 

Email Address: hello@seemeplease.com

Postal Address: 27 Old Gloucester St, Holborn,  London, United Kingdom, WC1N 3AX.

If you are based in the UK, or are working with our entity based in the UK, you have the right to make a complaint at any time to a relevant Data Protection Authority based within the UK. The UK regulator for data protection issues is the Information Commissioner's Office (ICO) (www.ico.org.uk).

If you are based in an EU member state, you have the right to make a complaint at any time to a relevant Data Protection Authority based within Europe. You can find the relevant European Data Protection Authority through the European Data Protection Board or the European Data Protection Supervisor (https://edpb.europa.eu/about-edpb/about-edpb/members_en).

3. The Privacy Laws that Apply to You

See Me Please is dedicated to following data protection laws that govern the collection and management of your personal information. In line with this commitment, we:

  • Ensure full transparency about how we collect and use your personal data.

  • Only gather personal data that is essential for the services we provide.

  • Clearly define the purpose for collecting your data and limit its use and sharing to those specific purposes.

  • Implement appropriate measures to protect the security of the personal data we hold.

The personal data of clients and individuals based:

  • in the UK, will be governed by, and processed in accordance with the privacy laws of the UK including: (i) the Data Protection Act 2018 (DPA); (ii) the Privacy and Electronic Communications (EC Directive) Regulations 2003 (PECR); and (iii) the UK GDPR, being the retained EU law version of the General Data Protection Regulation ((EU) 2016/679) and as defined by section 3(10) of the DPA. 

  • in an EU member state, or the European Economic Area (EEA), will be governed by, and processed in accordance with the privacy laws of the EU (as well that particular member state), as set out in the glossary at section 14 below.

The above are referred to in this Policy as the Privacy Laws.

Please note, notwithstanding the above, if you are a User Tester, or Client Organisation of or for our UK Company, but are based outside of the UK or EEA, your personal data will be governed by, and processed in accordance with the privacy laws of the UK and/or EU, regardless of your location.

Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

4. Your Personal Data – An Overview

Personal information, or personal data, is information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). 

As part of our business, we may collect personal information from, and about, you. We collect a variety of personal information that is reasonably necessary for the purposes of conducting and improving our business, products and services.

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.

If you provide any information to us, which may include personal data, you warrant and represent that you are entitled to do so.

Where See Me Please manages information on behalf of Client Organisations or User Testers, we do so in accordance with the Privacy Laws and the contractual arrangements we have with those parties.

Sections 5, 6 and 7 below set out the details of what data we collect and why we collect it depending on the type of user that you are. However generally, we will only use your personal data when the law allows us to, each of these are called a ‘legal basis’ for processing/using your personal data. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract that we are about to enter, 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.

  • In limited circumstances, where detailed below, we may also rely on consent as a legal basis for processing your personal data. 

Where we need to collect personal data by law, or under the terms of a contract (for example, if you are a Client Organisation) we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have, or are trying to enter into, with you (for example, to provide you with our services). In this case, we may have to cancel a service you have with us, but we will notify you if this is the case at the time.

As above, we have specified further detail on the information we collect depending on the type of user that you are in sections 5 to 7, but as an overview, we generally collect the following information and may use different methods to collect that information including through:

  • Direct interactions. You may give us your: 

    • identity, contact and financial information including first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, gender, photographs/images, billing address, delivery address, email address, telephone numbers, bank account and payment card details

    • by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you (i) enquire about or purchase our services, (ii) subscribe to our marketing, (iii) contact us, or (iv) give us feedback.

  • Automated technologies or interactions. As you interact with our website, we will automatically collect technical and usage data (including, information about how you use our website, 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 this website) about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please also see our cookie polic yhttps://seemeplease.com/Cookies_Policy_UK for further details.

  • Third parties or publicly available sources. We will receive personal data about you from various third parties as set out below:

    • Technical and Usage Data (including the information set out above) from analytics providers, such as Google, based outside the UK and EEA, and advertising networks, such as LinkedIn based outside the UK and EEA; 

    • Tester information from third-party recruitment websites or marketplaces to find user testers or clients such as specialised recruitment or social media platforms based outside the UK and EEA; 

    • Contact, and Financial Data (including the information set out above) from providers of technical, payment and delivery services, such as Stripe based outside the UK and EEA; 

    • Identity and Contact Data (including the information set out above) from publicly available sources, such as Companies House and the Electoral Register, based inside the UK and EEA;

    • Identity and Contact Data (including the information set out above) from Social Media and Professional Networks such as LinkedIn, to identify contact information for client organization representatives or to vet a tester’s professional background. Similarly, mention any other relevant social platforms (Twitter, Facebook groups, accessibility forums) used to source or verify individuals. 

    • Identity and Contact Data (including the information set out above) including audgemnting contac details or company information using third-party data services. 

    • If you are a User Tester, we may receive and share your personal data with our customers (the Client Organisations) which we act for in respect of a research opportunity that you choose to take part in, these Client Organisations may be based inside and outside of the UK and EEA. 

We may also collect, use and share Aggregated Data such as statistical or demographic data. Aggregated Data could be obtained from your personal data but is not considered personal data in law as it will not directly or indirectly reveal your identity. For example, we may aggregate some of your Technical and Usage Data to calculate the percentage of users accessing a specific website feature.

5. User Testers

5.1 Registering an Account- Onboarding as a User Tester

Should you meet See Me Please’s user testing eligibility criteria, you may be able to commence the process of registering an Account (otherwise known as User Tester Onboarding). When you create a user testing account with See Me Please, we collect personal information to register and manage your account. You may also update your profile with additional details after registration.

Once your participant account is set up, you will be considered for paid user testing and research studies and may be invited to participate in specific user testing projects. We may also use your registration details to communicate with you, such as notifying you about potential user testing, research opportunities or reminding you of upcoming study sessions you've selected to join.

Please note that we are unable to create your account or offer you research opportunities if the required information to register an account and satisfy eligibility criteria is not provided. 

See Me Please collects and processes User Tester’s personal data in a number of instances, which have been set out below. We generally collect this information directly from you. The nature of our business means that we are unable to invite you to participate in user testing opportunities you decide to remain anonymous.

5.2 During User Tester Account Registration

When you register an account as a user tester, we collect a range of personal data to set up your account, including:

  • Email

  • Password (Hashed)

  • Name

  • Gender

  • Town/suburb location

  • Date of birth

  • Occupation status

  • Mobile phone number

  • user preferences and assisted technology preferences and information which may include (without limitation) screen readers and voice controls;

  • transactional information which may include (without limitation) your method of payment or bank account details for the purpose of compensating you;

  • identification information and documentation; and 

  • participant status - if a user tester breaches See Me Please’s Terms and Conditions when using the platform and services, they may become ineligible to take part in future user testing projects. Should this occur, the status will be noted on the participant’s account record.

Each person retains the right to choose whether or not they participate in each User Tester Panel or to participate in any use research projects. 

5.3 Participating in a User Testing Project – Background 

Once you have been accepted to join the User Tester Panel (and you have registered an account), you will be eligible to participate in individual projects. Each User Tester will be asked to confirm whether or not they would like to participate in each  individual project. The project-specific information will outline details regarding who will have access to their personal data, and how their data will be used for each specific project.

If you choose not to participate, in a study or project, we will not collect any personal data about you in relation to that study and will continue to only process personal data collected in order to assess your application to join the User Testing Panel or set up an account. 

Any such information provided generally to set up an account or outside of a project will be used in accordance with section 7.   

User Testers retain the right to decline participation in any project if they do not agree with the specific data-sharing requirements associated with that project.

To participate in and complete user testing projects, you will generally be required to provide details about yourself, including your opinions and preferences.

The exact personal data that you are required to provide is dependent on the scope of the project being conducted which will be provided to you before you agree to participate in each project.

5.4 Legal Basis for Processing User Tester Data

As set out the section 4 above (the overview), we will process User Tester Data on the following legal basis: 

  • Where we need to perform the contract that we are about to enter, or have entered, into with you.  Each User Tester will enter into a contract with See Me Please which sets out the terms and conditions that apply to you as a User Tester including the details of payment that will be made in respect of your participation as part of the User Tester Panel, the information provided before you agree to participate in each project will set out any additional terms and conditions that apply.  We will therefore collect and process the personal data about you (as set out in sections 5.5 and 5.6) for the purposes of providing and receiving services under that contact as a User Tester in reliance on the legal basis of performance of a contract. 

  • 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. Some of the User Tester personal data that we collect may sit outside of the performance of a contract, for example: 

    • where we are using your personal information to identify projects or studies you may be interested in;

    • asking you to complete surveys about your participation in studies, or to leave a review; or

    • administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).

  • That information will be collected and used as it is necessary for our legitimate interests including: 

    • to keep our records updated and to study how User Testers use our services, particular in order to develop our services and grow our business;

    • 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;

    • to provide you with the option of participating in further projects.

  • Where we need to comply with a legal obligation. As we are paying our User Testers to participate in the projects, we may also have certain legal obligations that require us to collect and use the personal data of User Testers, such as financial data that we need to provide to HMRC, assessing your status as an independent contractor, or providing health and safety safeguards to protect our User Testers. 

  • Consent. Finally, where a project will involve the collection or use of sensitive personal data (also known as special category personal data) such as details about your race or ethnicity, religious or philosophical beliefs, sex life or sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data. 

  • We collect this information where that information is supplemental to a project and will always inform you in advance where this is the case. In any circumstances where a large amount of sensitive information will be collected, we will inform you in advance and (in addition to the legal basis set out about) may obtain your consent to process such sensitive information. 

5.5 User Tester Personal Information Collected by Us

Once a person has decided to join the User Tester Panel and has successfully registered an account including satisfying eligibility criteria, the Personal information of that User Tester may be collected in a number of ways, including:

  • through our website at https://seemeplease.com and its subdomains, web applications, mobile applications, proprietary software and desktop clients (collectively the Platform);

  • directly from the User Tester, including through digital accessibility testing and the provision of insight and feedback;

  • through marketing research and other user participation events;

  • through any of our other business activities or events; and

  • through our partner organisations.

Personal information of User Testers collected by us may include:

  • name, contact details (including street address, postal address, email address, phone number), gender and age;

  • videos, photographs, audio recordings, screen recordings or other materials provided by the User Tester including those that may contain their image, likeness, voice, written comments or other personal information;

  • location information;

  • user preferences and assisted technology preferences and information which may include (without limitation) screen readers and voice controls;

  • transactional information which may include (without limitation) bank account details for the purpose of compensating you;

  • identification information and documentation, specifically for the purpose of participating in user testing projects that require identity assurance;

  • usernames and passwords (which may be inadvertently shared in the course of user testing);

  • preferences and opinions;

  • any other information that the User Tester chooses to send to us; and

  • usage data and logs, which may include information such as their Internet Protocol (IP) address, browser type, browser version, device type, make and model clickstream/heatmap data, Single Sign-On profile information, the pages of our Platform visited, the features and functions of our Platform used, activities or actions they do while using our Platform, the time and date of their visit to our Platform, the time spent on any pages of our Platform, and other log related information relating to their use of our Services.

  • As above, in some circumstances, we may also collect sensitive personal data (also known as special category personal data) such as details about your race or ethnicity, religious or philosophical beliefs, sex life or sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data.

5.6 Use of User Tester Personal Information

We may use the personal information of User Testers for the following purposes, which our necessary for our legitimate interest, or the legitimate interests of others:

  • understanding digital accessibility and usability friction and informing organisations about real-world accessibility challenges;

  • undertaking research and capability building related to accessible online services;

  • collecting and developing aggregated insights on digital accessibility, usability and inclusivity and benchmarking data; and

  • building innovative models and technologies using data.

To confirm, in accordance with our terms and conditions, we would make you aware that all data that forms part of a project (including your participation) is collected under a contract that we have with the User Tester and the Client Organisation for services provided. As such, all data (in particular aggregated data and any analytical insights or models derived from the use of personal information) shall remain the exclusive property of See Me Please, and used or accesses by the relevant Client Organisations.  Such personal information is only provided to Client Organisations where it is required for the purposes that we have confirmed to you and restricted to what is necessary. 

Please see the terms and conditions for more detailed conditions related to the ownership of the data collected.  

5.7 Disclosure of User Tester Data

User Testers are engaged by us to test the accessibility and user experience of digital services and to provide us with feedback and insights. Such feedback and insights may be provided by User Testers in the format of videos, photographs, audio recordings, screen recordings or other digital or written materials including those that may contain the User Tester’s image, likeness, voice, opinions, preferences and other personal information (Tester Data).

Tester Data is shared by us with Client Organisations as specified in the project information provided to the User Tester before their participation. We provide Tester Data to Client Organisations, to provide them with our services including without limitation to providing them with the feedback and insights of User Testers.

We endeavour to maintain the protection of Tester Data by providing it to Client Organisations via a secured, authenticated portal and in anonymised or aggregated form, where possible.

User Testers may decline to participate in any project if they are not comfortable with the data-sharing requirements.

See Me Please takes all reasonable steps to ensure that Tester Data is only used by Client Organisations for user research or capability uplift related to the design and usability of online services and is not shared with stakeholders outside the Client Organisation, however this cannot be guaranteed. See Me Please cannot control how other parties interpret and use Tester Data.

By providing Tester Data to See Me Please, you acknowledge and agree that:

  • participating in testing and providing Tester Data is entirely voluntary;

  • See Me Please will collect, use, share and disclose your Tester Data and personal information in accordance with this Privacy Policy and any other project specific information or (as required) consents provided to, or by, you;

  • See Me Please will share your Tester Data and personal information with Client Organisations; and

  • See Me Please will not be held liable for any use, non-use, or misuse of your Tester Data or personal information by Client Organisations or third parties.

6 Client Organisations

6.1 Client Organisation Personal Information Collected by Us

When you sign up for an account with See Me Please as a representative of a Client Organisation, we collect personal data from you in your capacity as a member of that organisation. We process this data on behalf of our client (the data controller) for the purpose of registering your account with See Me Please. By creating an account, you will be able to access the See Me Please platform and utilise our services to view your organisation’s user research insights or broader research insights and benchmarking data.

Please note that we cannot set up your account without the necessary information. As our current and prospective Client Organisations are typically companies, corporations, or government agencies, personal data collected is generally limited to the details of nominated contact persons or employees interested in accessing insights. 

This information is processed under various circumstances, as outlined below. We will collect this data directly from you (e.g., through a webform or event registration) or from other sources, such as your employer (our client) or LinkedIn. Due to the nature of our business, we are unable to provide user insights services anonymously.

6.2 Legal Basis for Processing Client Organisation Data

We will process Client Organisation Data on the legal basis set out the section 4 above (the overview), however, more specifically we will process Client Organisation Data:

  • Where we need to perform the contract that we are about to enter, or have entered, into with you.  Each Client Organisation will enter into a contract with See Me Please, any personal data that we collect and process under that agreement or contract will be processed for the purposes of providing, and the client organisation receiving) services under that contact in reliance on the legal basis of performance of a contract. 

  • 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, for example where we need to: 

    • administer and protect our business and the website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data); 

    • register you as a new client and recover debts due to us; 

    • keep our records updated and to study how our clients use our services, particular in order to develop our services and grow our business; and

    • 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.

  • Where we need to comply with a legal obligation.

6.3 How We Collect Data on Organisations

Personal information of Client Organisations may be collected in a number of ways, including:

  • through our Platform;

  • directly from that party, including through conversations or written correspondence;

  • through any of our other business activities or events; and

  • through our partner organisations.

  • Personal information of members from our Client Organisations collected by us may include:

  • name and contact details (including street address, postal address, email address, phone number);

  • location information;

  • reasons for using any of our products and services;

  • Working with Vulnerable People Clearances

  • any other information that the Client Organisation chooses to send to us; and

  • usage data and logs, which may include information such as Internet Protocol (IP) address, browser type, browser version, device type, make and model clickstream/heatmap data, Single Sign-On profile information, pages of our Platform visited, the features and functions of our Platform used, activities or actions while using our Platform, the time and date of visit(s) to our Platform, time spent on any pages of our Platform, and other log related information relating to use of our Services.

6.4 Use of Client Organisation Data

When collecting and using the personal information of our Client Organisation, as you have entered into a contract with us, for the purposes of providing the products or services under that contract, we will use and collect your personal information we need to perform the contract that we are about to enter, or have entered, into with you. In addition, we rely on the legal basis of ‘legitimate interest’ on the following basis, and for the following purposes:

  • developing and improving our products, services and user satisfaction;

  • providing support (including technical support) to the Client Organisation in relation to the use of our products and services;

  • promoting and marketing our products and services;

  • internal research and statistical purposes (including market segmentation and customer value analysis) and internal business operations (including fulfilling any legal requirements);

  • enabling us to forward other information or material which we believe may be of interest to that party, or which the party has indicated it may be interested in receiving, which may include (without limitation) our newsletter, accessibility research and insights, news and industry developments; and

  • any other purpose reasonably related to our business interests.

6.5 Disclosure of Client Organisation Data

We do not disclose the personal information of Client Organisations to any third party, other than those requiring this information to assist us or those that are directly related to the purposes for which the information was collected, including:

  • to external service providers, so that they can provide products and services in connection with the operation and improvement of our business including, without limitation, our professional advisors, consultants, engineers, administrators, interpreters and data entry service providers;

  • to our affiliates, including but not limited to other organisations and businesses within our group of organisations, employees and contractors;

  • to provide services to, or respond to or fulfill requests from the Client Organisation;

  • as permitted under the Privacy Laws or any other applicable law;

  • if the Client Organisation would reasonably expect that their personal information would be passed to the person to whom the personal information is disclosed;

  • any relevant authority or enforcement body where we reasonably believe that disclosure is required to bring legal action against a third party;

  • entities that we propose to merge with or be acquired by; and

  • in some cases, with the consent of the Client Organisation.

All aggregated data (be it anonymised or identifiable) and any analytical insights or models derived from the use of personal information shall remain the exclusive property of See Me Please, and any use or access by Client Organisations shall be strictly subject to a non‐exclusive, revocable licence that does not confer any ownership rights, as set out in our contract with the Client Organisation.

Granular, project-specific insights that See Me Please is commissioned to deliver on behalf of client organisations will not be shared with other organisations. However, See Me Please may use these project insights more broadly for purposes such as research, benchmarking, and developing innovative models and solutions.

7. Subscribers and Other Parties

7.1 Personal Information Collected by Us

If you subscribe to our newsletter or marketing database or otherwise deal or interact with us in any way, your Personal Information may be collected:

  • through our Platform;

  • directly from you, including through conversations or written correspondence with us;

  • through any of our other business activities or events;

  • through our partner organisations; and

  • through persons seeking employment with us and/or by otherwise having some form of contact with a person, such as by personal contact, mail, telephone, email, video teleconferencing, Internet or other forms of telecommunication.

  • Personal information collected by us may include:

  • your name and contact details (including email address, phone number);

  • any other information that you choose to send to us; and

  • usage data and logs, which may include information such as your Internet Protocol (IP) address, browser type, browser version, device type, make and model clickstream/heatmap data, Single Sign-On profile information, the pages of our Platform that you visit, the features and functions of our Platform you use, activities or actions you do while using our Platform, the time and date of your visit to our Platform, the time spent on any pages of our Platform, and other log related information relating to your use of our services.

7.2 Use of Personal Information

When collecting and using the personal information of our subscribers and other parties if you have entered into a contract with us, for the purposes of providing or receiving the products or services under that contract, we will use and collect your personal information we need to perform the contract that we are about to enter, or have entered, into with you. In addition, we rely on the legal basis of ‘legitimate interest’ on the following basis, and for the following purposes We may use personal information for:

  • providing support to you (including technical support) in relation to the use of our products and services;

  • promoting and marketing our products and services to you;

  • internal research and statistical purposes (including market segmentation and customer value analysis) and internal business operations (including fulfilling any legal requirements);

  • enabling us to forward to you other information or material which we believe may be of interest to you, or which you have indicated you may be interested in receiving, which may include (without limitation) our newsletter, accessibility research and insights, news and industry developments; and

  • any other purpose reasonably related to our business interests.

7.3 Disclosure Generally

We do not disclose your personal information to any third party, other than those requiring this information to assist us or those that are directly related to the purposes for which the information was collected, including:

  • to external service providers, so that they can provide products and services in connection with the operation and improvement of our business including, without limitation, our professional advisors, consultants, engineers, administrators and data entry service providers;

  • to our affiliates, including but not limited to other organisations and businesses within our group of organisations, employees and contractors;

  • to provide services to, or respond to or fulfill requests from, you;

  • as permitted under the Privacy Laws or any other applicable law;

  • if you would reasonably expect that your personal information would be passed to the person to whom the personal information is disclosed;

  • any relevant authority or enforcement body where we reasonably believe that disclosure is required to bring legal action against a third party;

  • entities that we propose to merge with or be acquired by; and

  • in some cases, with your consent.

8. Data Security and Retention

We will implement and maintain security measures consistent with internationally recognised standards to protect all personal information which we hold from misuse, interference, loss, unauthorised access, modification or disclosure.

  • The precautionary steps we take to protect personal information may include:

  • providing Tester Data to Client Organisations via a secured, authenticated portal and in anonymised or aggregated form, where appropriate and possible;

  • adopting measures to protect our computer systems and networks for storing, processing and transmitting personal information;

  • adoption of procedural and personnel measures for limiting access to personal information by our staff;

  • adoption of procedural measures and processes for limiting access to Tester Data to members of Client Organisations;

  • regularly reviewing our information collection, storage and processing practices;

  • conducting routine security reviews; and

  • secured encrypted servers, password protection for electronic files and multifactor authentication procedures.

We also take steps to ensure that the personal information we collect is accurate, up-to-date and complete. These steps may include maintaining and updating personal information when it is apparent that updating is required, or we are otherwise advised by you that your personal information has changed.

In the event of a data breach that is likely to result in serious harm to any individual, we will promptly assess the breach and notify affected individuals and the UK Information Commissioner’s Office as required under the Privacy Laws. We will take appropriate remedial steps to mitigate the effects of the breach and review our security measures to prevent recurrence.

We will retain personal information only for as long as is necessary to fulfil the purposes for which it was collected or as otherwise required or permitted by law. Once such purposes have been achieved or the retention period expires, personal information will be securely deleted or permanently de-identified, except where further retention is required for legal, regulatory, or legitimate business purposes.

To decide the appropriate retention period, 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.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes

9. Cookies and Web Beacons

Cookies are files with a small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your computer's or mobile device’s storage drive. Like many sites, we use cookies and other similar technologies to collect information and remember your preferences. You can instruct your browser to refuse all cookies, or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some features of our Services or our other products and services.

Web beacons (also known as clear gifs, pixel tags or web bugs) are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of users or to access cookies. Unlike cookies which are stored on the user’s computer or mobile device storage drive, web beacons are embedded invisibly on web pages (or in e-mail). Web beacons may be used to deliver or communicate with cookies, to count users who have visited certain pages and to understand usage patterns. Like many sites, we use web beacons to collect information which is done in accordance with this Policy.

For more information about the cookies or web beacons that we use, please see https://seemeplease.com/Cookies_Policy_UK

10. Overseas Disclosure

We may share your personal data:

  • within the See Me Please Group, and that may involve transferring your data outside the UK and EEA to various overseas territories such as Australia, Ireland the US and any other locations where See Me Please operates

  • to our service providers, which as per section 4 (the overview) may be outside of the UK and EEA. Including AWS who manage our servers and is based in the United States.

  • with our customers who are based outside of the UK and EEA and have requested our services to provide User Testers for participation in projects. 

  • with our User Testers who are based outside of the UK and EEA, who may receive personal information relating to Client Organisations when receiving information about projects.

Additionally, we may disclose personal information to outsourced information technology service providers, including cloud computing providers and data storage providers, and other third party service providers who are not in the UK or EEA or who may transfer or store your personal information outside the UK or EEA.

Whenever we transfer your personal data out of the UK and EEA, 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 the country is not deemed to have an adequate level of protection, we (i) will use specific contracts approved for use in the UK and EEA (called Standard Contractual Terms and/or International Data Transfer Agreements) which give personal data the same protection it has in the UK and EEA, and (ii) undertake a data transfer risk assessment to ensure the protection of your data. 

Please note that the UK and the EU are deemed to afford individuals with a similar degree of protection as one another, but Australia currently is not (as at the date of this policy) deemed to have a similar degree of protection. As such, we will ensure appropriate safeguards are in place if and when we transfer any personal data to our Australian company. 

11. Your Legal Rights 

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

  • request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data that we hold about you and to check that we are lawfully processing it.

  • request correction of your personal 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.

  • request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local laws. Please 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.

  • 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 particular 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.

  • request restriction of processing your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (i) if you want us to establish the data's accuracy; (ii) where our use of the data is unlawful but you do not want us to erase it; (iii) 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; (iv) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

  • request 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. Please 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.

  • withdraw consent where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us using the details in section 2 above. 

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 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.

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 a number of requests. In this case, we will notify you and keep you updated.

Last Updated on: July 24, 2025 (Version: 1.0.0)
Privacy_Policy_UK_v1.0_2025-07-17 – See Me Please – See Me Please