Parallel North Privacy Policy

1. Who We Are

Parallel North is a software platform developed and operated by 7 Degrees Media Limited. Parallel North is a trading name and is not a separate legal entity.

For personal information collected and processed by us for our own purposes, 7 Degrees Media Limited is the Data Controller. This may include information relating to Parallel North customers, account holders, authorised users, people making enquiries, prospective customers, website visitors, billing contacts, support users and people receiving our own marketing.

Where a customer uses our platform to process personal information concerning its customers, prospects, employees, suppliers or other contacts, that customer will normally be the Data Controller and 7 Degrees Media Limited will act as Data Processor on its behalf.

2. Services Covered by this Policy

This Privacy Policy applies to the Parallel North platform, including Parallel North CRM, Parallel North Mailer, Parallel North Social Scheduler, Parallel North Planner, Parallel North websites, APIs, integrations, automation, artificial intelligence features, associated support services and future Parallel North services that refer to this Privacy Policy.

3. Data Controller Details

Where 7 Degrees Media Limited determines the purposes and means of processing personal information, the Data Controller is:

7 Degrees Media Limited
Trading as: Parallel North
Company number: [COMPANY NUMBER]
Registered office: [REGISTERED OFFICE]
ICO registration number: [ICO REGISTRATION NUMBER]

Privacy contact: [PRIVACY EMAIL ADDRESS]

4. Data Controller and Data Processor Roles

7 Degrees Media Limited generally acts as Data Controller for information used to create and administer accounts, manage subscriptions, issue invoices, provide support, manage customer relationships, maintain security, prevent fraud or abuse, maintain technical logs, comply with legal obligations, improve our own Services, communicate operational information and market Parallel North where legally permitted.

Where a Customer places information relating to its own contacts or other individuals into Parallel North and determines why that information is being processed, the Customer is normally the Data Controller. 7 Degrees Media Limited processes it on the Customer's documented instructions as Data Processor. Examples include CRM contact records, mailing lists, customer notes, marketing data, email campaign recipients, email histories, connected mailbox content, calendar information, documents, social media accounts, tasks and meeting information.

Our processing obligations in these circumstances are governed by our agreement with the Customer and our Data Processing Agreement.

5. Information We Collect About Parallel North Users

When you create or use an account, we may collect your name, work email address, telephone number, employer or organisation, role or job title, username, authentication information, account preferences, permissions, subscription information, support information and communication preferences.

6. Billing Information

We may process billing names, billing addresses, company information, VAT information, subscription details, invoice histories, payment status and transaction references.

Payment information may be processed by a payment provider. Where payment card information is entered directly through a third-party payment processor, Parallel North may not receive or store complete card details.

7. Technical and Usage Information

We may process IP address, browser, operating system, device type, login times, session information, access logs, application activity, error records, security events, integration activity, feature usage and diagnostic information for security, support, service reliability and improvement.

8. Communications with Us

If you contact Parallel North, we may process email correspondence, support requests, chat messages, telephone notes, feedback, complaints, account enquiries and other communications. We may retain these records where necessary to manage our relationship with you and maintain appropriate business records.

9. Customer Data Processed Through Parallel North

Customers may submit or connect personal information concerning other people, including names, contact details, company details, CRM records, notes, communication histories, sales records, marketing preferences, tags, segmentation data, enquiries, tasks, appointments, calendars, emails, documents, files, social media information, analytics and custom fields.

The Customer is normally responsible for determining why that information is being processed.

10. Parallel North CRM

CRM may process contact details, organisation records, notes, activities, opportunities, sales histories, communication histories, tasks, marketing preferences, custom fields and relationship information entered, imported or connected by a Customer. We process this information to provide CRM functionality requested by the Customer.

11. Parallel North Mailer

Mailer may process names, email addresses, subscriber information, contact lists, segmentation information, subscription status, marketing preferences, suppression information, campaign membership, delivery, bounce, complaint, unsubscribe and engagement information.

The Customer is responsible for determining whether its use of such functionality is appropriate and lawful.

12. Email Tracking

Mailer may measure whether an email appears to have been opened, links clicked, approximate engagement time, delivery status and device or technical information. Tracking technologies have limitations and should not necessarily be treated as definitive evidence that an individual viewed a communication. Customers are responsible for providing appropriate privacy information where required.

13. Unsubscribe and Suppression Information

Where someone unsubscribes or objects to marketing sent through Parallel North, limited information may be retained in a suppression record, such as an email address or identifier needed to ensure the person is not inadvertently re-added. Suppression records may be retained after other customer records have been removed where necessary to respect preferences or comply with legal requirements.

14. Parallel North Social Scheduler

If a Customer connects a social media account, we may process account identifiers, page and profile information, authentication tokens, permissions, scheduled posts, media, publication information, account analytics and technical status information made available by the platform. This is processed to provide functionality requested by the Customer.

15. Parallel North Planner

Planner may process connected calendars, meetings, appointments, email metadata and content, CRM records, tasks, deadlines, documents, files, notes, projects, business priorities and meeting information to create daily plans, identify tasks, suggest priorities, summarise communications, prepare meeting information, analyse documents, identify deadlines, recommend actions, draft content and organise workloads.

16. Connected Email Accounts

Where a Customer connects an email account, Parallel North may access permitted email metadata, sender and recipient information, subject lines, message content, attachments, folders and message status. We access connected mailbox information only to the extent required to provide requested functionality.

17. Connected Calendars

Where a calendar is connected, we may process event names, dates, times, attendees, locations, descriptions, meeting links and availability. The exact information available depends on permissions and the relevant integration.

18. Documents and Files

Customers may upload documents or files for storage, analysis or use within the Services. Those documents may contain personal information. We process uploaded material to provide requested functionality. Customers are responsible for determining whether it is appropriate to upload the information concerned.

19. Artificial Intelligence

Parallel North may use artificial intelligence, machine learning or automated processing for summarisation, drafting, categorisation, segmentation, information extraction, recommendations, planning, prioritisation, analysis, automation and natural-language interaction. AI functionality may use systems operated by 7 Degrees Media Limited, self-hosted models or selected third-party providers.

20. Personal Information and AI

Where personal information is included in an AI request, we process it only where appropriate for the relevant functionality and our role in relation to that information. Where we act as Data Processor, processing follows our agreement and documented Customer instructions. We seek to minimise unnecessary personal information sent to AI systems.

21. AI Training

We do not sell Customer Data to AI providers. We do not knowingly permit Customer Data to be used to train unrelated general-purpose AI models unless this has been clearly disclosed, authorised where required, supported by an appropriate legal basis and covered by appropriate contractual arrangements. Where possible and appropriate, we may use self-hosted AI infrastructure.

22. Automated Decision-Making and Profiling

Some features may analyse, categorise or segment information automatically. Parallel North is generally designed to assist users rather than replace human judgement. Unless specifically disclosed, 7 Degrees Media Limited does not use Customer Data to make solely automated decisions about individuals that have legal or similarly significant effects. Customers are responsible for assessing their own use for additional legal obligations.

23. How We Use Personal Information as Controller

Where we act as Controller, we may process personal information to create accounts, authenticate users, provide Services, manage subscriptions and payments, issue invoices, provide support, respond to enquiries, manage relationships, maintain security, prevent abuse and fraud, investigate incidents, monitor performance, improve reliability, understand platform use, develop features, maintain records, comply with law, establish or defend claims, communicate service information and market Services where permitted.

24. Lawful Bases

Where we act as Controller, we identify an appropriate lawful basis. Depending on the circumstances this may be contract, legitimate interests, consent, legal obligation or another lawful basis permitted by applicable data protection law.

Legitimate interests may include operating our business, maintaining security, preventing fraud, managing relationships, improving reliability and appropriate business-to-business marketing. Consent can be withdrawn where applicable.

25. Parallel North's Own Marketing

We may send information concerning Parallel North products, services, features or related offerings where permitted by law. You may opt out using the unsubscribe mechanism or by contacting us. Operational or account communications may still be sent where necessary to provide or administer the Services.

26. Marketing Sent by Customers

Customers may use Mailer to send their own communications. The Customer determines the recipient, purpose, lawful basis, required permission and content, and is normally the Data Controller. Questions about a Customer communication should normally be directed to the organisation identified as sender.

27. Cookies and Similar Technologies

Parallel North websites and applications may use cookies, local storage and similar technologies for authentication, security, sessions, preferences, functionality, analytics and performance monitoring. Where permission is required by law for non-essential technology, an appropriate consent mechanism will be provided. Further information may be provided in a separate Cookie Policy.

28. Service Providers and Subprocessors

We may use trusted third parties for hosting, cloud infrastructure, email delivery, payments, authentication, monitoring, analytics, support, storage, AI processing, social media integrations, email integrations and calendar integrations. Providers receive access only to information reasonably necessary for their services and appropriate data protection contracts will be used where required. A list of material subprocessors may be made available separately.

29. Third-Party Services

Parallel North may connect to Microsoft, Google, social media platforms, email providers, payment processors, AI providers and other Customer-selected software. When a third party processes personal information for its own purposes, its own privacy policy applies.

30. International Transfers

Some suppliers or integrations may process information outside the United Kingdom. Where personal information is subject to a restricted international transfer, we will use an appropriate mechanism where required, including UK adequacy regulations, approved contractual safeguards, an International Data Transfer Agreement, an appropriate UK Addendum or another permitted mechanism.

31. Data Security

We take appropriate technical and organisational measures designed to protect personal information, which may include encryption in transit and at rest, access controls, authentication, user permissions, administrative restrictions, network security, monitoring, logging, backups, vulnerability management, updates and incident response. No online service can guarantee absolute security.

32. Access to Customer Data

Access to Customer Data by personnel acting for 7 Degrees Media Limited is restricted to circumstances reasonably necessary for technical support, maintenance, security, incident investigation, service operation or legal compliance. Appropriate confidentiality obligations apply.

33. Personal Data Breaches

We maintain procedures for suspected personal data breaches. Where we act as Processor and become aware of a breach affecting Customer Personal Data, we will notify the relevant Customer without undue delay as required by legal and contractual obligations. Where we act as Controller, we will assess the incident and make required notifications to the ICO or affected individuals.

34. Data Retention

We retain personal information only for as long as reasonably necessary for its purpose and applicable legal, contractual, accounting, security and regulatory requirements. Retention periods vary according to the information, purpose, legal and contractual requirements and security needs.

35. Customer Data Retention

Customer Data normally remains available while the account is active. Following cancellation or termination, data may remain available for a limited period, active copies may be deleted and information may temporarily remain in secure backups until normal backup cycles overwrite it. Information may be retained for legal compliance, security, fraud prevention, disputes or suppression of unwanted marketing.

36. Data Minimisation

We aim to process only personal information reasonably necessary for the relevant purpose. Customers should also avoid collecting or storing unnecessary personal information within Parallel North.

37. Accuracy

Where we act as Controller, we take reasonable steps to ensure personal information is accurate and, where appropriate, up to date. Where we act as Processor, the relevant Customer is primarily responsible for the accuracy of Customer Data.

38. Special Category Personal Data

Parallel North is not generally intended as a specialist system for highly sensitive information concerning health, racial or ethnic origin, beliefs, political opinions, trade union membership, genetic or biometric information, sexual life or sexual orientation.

Where such information is processed, the Customer is responsible for an appropriate lawful basis, any additional condition required by law and suitable safeguards. Certain plans or functions may prohibit particular categories of sensitive data.

39. Criminal Offence Data

Customers should not routinely store criminal offence information in Parallel North unless they have determined that doing so is lawful and appropriate and any additional legal requirements have been satisfied.

40. Children's Information

Parallel North is a business software service and is not intended for direct use by children. Customers should not intentionally process children's information unless they have determined that processing is lawful, appropriate and adequately protected.

41. Your Data Protection Rights

Depending on the circumstances and applicable law, individuals may have rights including to be informed, access, rectification, erasure, restriction, data portability, objection and rights relating to automated decision-making. These rights are not absolute and may be subject to exemptions or limitations.

42. Right to Object to Direct Marketing

You have the right to object to use of your personal information for direct marketing. Where you exercise this right against marketing carried out by 7 Degrees Media Limited as Controller, we will stop using your information for that marketing. We may retain limited suppression information so your objection continues to be respected.

43. Exercising Rights Where 7 Degrees Media Limited Is Controller

Where 7 Degrees Media Limited is Data Controller, contact us using the details in this Privacy Policy. We may verify your identity before fulfilling certain requests and will respond in accordance with applicable data protection law.

44. Exercising Rights Concerning Customer Data

If your information is held because one of our Customers placed it there, that Customer will normally be the Data Controller and you should usually contact that organisation directly. Where required, 7 Degrees Media Limited will assist the Customer with valid requests.

45. Data Protection Complaints

If you have concerns about how 7 Degrees Media Limited handled your personal information, submit a complaint using [PRIVACY / COMPLAINTS EMAIL]. We will investigate and respond in accordance with applicable legal requirements.

46. Information Commissioner's Office

You may raise concerns with the Information Commissioner's Office (ICO), the UK's independent data protection regulator. We welcome the opportunity to investigate your concerns directly, but you are not required to contact us first.

47. Changes to this Privacy Policy

We may update this Privacy Policy when Parallel North, our processing activities, service providers or legal requirements change, or when new features are introduced. The latest version will be published through the Parallel North website or application. Where a change materially affects processing, we will provide additional notice where appropriate.

48. Contact Us

For privacy questions, data protection requests or complaints, contact:

7 Degrees Media Limited
Trading as: Parallel North
Company number: [COMPANY NUMBER]
Registered office: [REGISTERED OFFICE]
ICO registration number: [ICO REGISTRATION NUMBER]

Email: [PRIVACY EMAIL ADDRESS]