What's in this policy?
This Policy aims to inform you of how we process your personal data in accordance with data protection laws, including the UK and EU GDPR. This Policy covers users of our website, https://www.logically.ai/ ("Website"), employees and other personnel of our customers, suppliers and other business partners as well as internet users publishing information on social media or publicly available websites.
Please read this Policy to ensure that you understand how we may process your personal data and your rights under data protection laws.
1. What personal data do we process about you and where do we get it?
When you use our Website and/or otherwise contact Logically
When visiting our Website, you may sign up to be provided with information about our products and services, request product information and/or make an enquiry through our online contact form or otherwise contact us directly, for example by phone or email. We will process any personal data you provide to us, such as your contact details (such as name, email address and/or phone number) and any other information you include in your enquiries or submissions.
We will also automatically collect the following information each time you visit the Website: browser type and version, how long you spend on a page and on our Website, type of device, screen resolution, operating system and interface, your domain name, if applicable, the website from which you are visiting us (referrer URL), webpage(s) you are visiting on our Website, the date and time of accessing our Website, and your internet protocol (IP) address.
When you publish information and/or posts on social media and other publicly available websites
Logically’s mission is to reduce and eventually eliminate the harms associated with mis- and disinformation. Logically therefore scans social media platforms and other sites to detect these harms and other potential threats. By virtue of the provision of some of our services to our customers or to develop our products and services, Logically may be processing your personal data, which you have published on the internet. Some of our products and services involve us ingesting large volumes of data sourced from social platforms and other websites. This means that we may, for example, process your personal data from your social media profile such as name, username, photograph, demographic information such as interests or gender, geolocation information, employment information, audio/visual information you post or interact with or the content of your posts. If your social media posts or the information you publish on a publicly available website contains personal data then we may process this as well, for example if you include personal data about yourself in a Twitter post. We use this information to identity emerging threats, including disinformation campaigns, produce reports, conduct fact-checking exercises.
Sensitive personal data
Some of the personal data that we process may be deemed sensitive under data protection laws, such as the UK GDPR. For example, we may process personal data relating to your racial or ethnic origin, political opinion, religious or philosophical beliefs, health data or data concerning a person’s sex life or sexual orientation. We will only process sensitive categories of personal data about you where this is authorised by data protection laws. This will be the case where we process this type of personal data about you because you have made it public by virtue of processing data from social media platforms or other websites. For example, if you reveal your political opinions in a publicly available Facebook post.
When we do business with our customers, suppliers and business partners
To the extent permitted by applicable law, Logically may collect and process personal data concerning our customers, suppliers, investors and business partners (and their representatives), such as name, contact details (for example, email address, telephone number, residential address), job title and employer-related information and other business- related information that you or your employer make available to us. We may also receive your personal data from distributors to incentivise sales and from other third parties who provide business development services to us.
When you participate in our events, including webinars and video conferences
We may collect personal data such as your name, job function/title, the company name of your employer, contact details (such as email address and phone number), the country and city where you are based, photos with your likeness, voice and/or video recordings, as part of registration and in the course of training events, meetings, conferences and other events we may organize and information about attendance at such events. We may receive some of this personal data from third parties if they help us organize these events or co-organise them with us.
2. Why do we process your personal data and on what basis?
We will only process your personal data where we have a valid lawful basis under data protection laws. The lawful bases on which we rely include processing data on the basis of our legitimate business interests as outlined below, on the basis of your consent, because we need it in order to fulfil or enter into a contract with you and/or to comply with a legal obligation.
Below we set out the purposes for which we may use your personal data.
Provision of products and services:
If you work for any of our clients or potential clients, we may process your personal data on the basis of our legitimate interests in order to provide our clients with products and services or information.
If you are a sole trader or a member of an unlimited partnership, we may need to process your personal data to enter into a to fulfil a contract.
This includes the processing of personal data for the facilitation and management of the provision of our services, the preparation of quotes and any applicable discounts and processing of payments. We may also process this data where we have a legal obligation to do so, such as for compliance with anti-money laundering and other business-related legal obligations that require us to process your personal data.
As stated above, we may also process your personal data by virtue of you making it publicly available on social media platforms and other website. This is for the purposes of providing our products and services to our clients. We do so on the basis of our legitimate interests in being able to deliver these services and meet our obligations under our customer contracts.
Supplier data: If you work for any of our suppliers or potential suppliers, we may process your personal data for our legitimate interests in procuring or purchasing products and services, including making payments, arranging for supply and/or deliveries and generally for the purposes of dealing with our suppliers.
If you are a sole trader or a member of an unlimited partnership, we may need to process your personal data to enter into a to fulfil a contract.
Improvement of our Website, products and services: We may analyse your visits to our Website, the use/demand for our products and services, the popularity of certain pages and the way you navigate the Website in order to improve our Website, our products and services, our marketing/advertising. It is in our legitimate interests to monitor usage of our Website, products and services and improve them for the operation, management and success of our business.
Marketing communications and materials: We may process your personal data to provide you with email newsletters, news alerts and other marketing materials and product information you have subscribed to or otherwise requested from us by completing our online form, or where we have other lawful grounds to provide you with such materials/advertise to you.
You can unsubscribe from receiving our marketing emails by by clicking on the unsubscribe link contained in each email]. In addition, you can unsubscribe from receiving any of our newsletters or marketing communications at any time by emailing us at: email@example.com.
We process personal data for marketing purposes either on the basis of your consent or on the basis of our legitimate interests.
Business sale or purchase: We may transfer your personal data to potential purchasers/sellers and their advisors, subject to appropriate confidentiality obligations, in the event we decide to dispose of all or parts of our business or its assets or during the course of a business acquisition.
Respond to any other requests or inquiries from you.
Establishment, exercise or defence of legal claims: We may need to process your personal data in connection with legal claims that we wish to establish, exercise or defend against (or prospective proceedings).
Compliance with applicable laws: Where required by law and/or in response to a request from a court or regulatory body, we may process your personal data in order to comply with the relevant obligations applicable to us.
Improve our business development approach: Our service providers may process your personal data to better market our services and products to you. We process data for this purpose on the basis of our legitimate interests to better run our business.
3. Who do we share your personal data with?
We may share your personal data with certain third parties, as described in more detail below.
Our affiliates may receive your personal data as necessary for the processing purposes described in section 2 of this Policy. Depending on the categories of personal data and the purposes for which the personal data is processed, different internal departments within Logically may receive your personal data. For example, relevant members of our fact checking teams, analyst teams, engineering teams may be located in multiple Logically entities across multiple jurisdictions.
Service providers acting on our behalf
Certain third party service providers may process your personal data under appropriate instructions on our behalf, as necessary to support us with the processing described above, such as:
- IT providers such as companies that provide software, computing services and / or hardware, including IT support (for example, data management, IT service management and storage services, web-hosting, video and / or voice conferencing, email services, digital communication platforms, companies providing machine translations, data analytics providers, etc.);
- support services such as companies that provide business support services (for example, marketing and business development strategy, mailing vendors, etc.);
- companies that provide financial administration services (for example, services and product payment services management, etc.);
- companies that provide training and event organisation services (for example, suppliers providing training platforms, event organisers, etc.).
These service providers are bound by law and/or contract to protect the confidentiality and security of personal data, and to only use personal data to provide requested services to us and in accordance with applicable law.
Other companies, vendors, suppliers, business partners and public entities
We may also share personal data with other companies and business partners as follows:
- financial institutions in connection with our banking and financial arrangements;
- professional advisors such as lawyers, accountants and auditors;
- in relation to prospective or actual strategic transactions involving Logically (such as mergers and acquisitions), third parties involved in such transactions; or
- other public authorities such as law enforcement agencies, governmental authorities, courts, tribunals, opposing or other related parties to the proceedings and their professional advisors.
Where we share personal data with these third parties we will do so on the basis of our legitimate interests, including our legitimate interests in procuring or purchasing services or for the defence, exercise or establishment of legal claims or to comply with our legal obligations.
4. International transfers of personal data
Due to the global nature of our operations, some of the recipients of your personal data may be Logically affiliates located in countries outside the UK and EEA, which do not provide an adequate level of data protection as required under the UK GDPR and EU GDPR. Where such international data transfers take place, such as to Logically entities in the US or India, it will be on the basis of an appropriate safeguard approved by the Information Commissioner’s Office (“ICO”) and/or EU Commission, such as the ICO’s international data transfer addendum and the EU Commission’s standard contractual clauses.
Some of the third parties with whom we share personal data are also located outside the UK and EEA, in third countries which do not provide an adequate level of data protection as defined by the UK GDPR and EU GDPR. Transfers to third parties located in countries which are not deemed to provide an adequate level of data protection take place using a lawful data transfer mechanism, such as the ICO’s international data transfer agreement, the ICO’s UK Addendum, the EU Commission’s Standard Contractual Clauses, Binding Corporate Rules, approved Codes of Conduct and Certifications, or on the basis of permissible statutory derogations, or any other relevant data transfer clauses issued by the UK Secretary of State or the UK Information Commissioner (and approved by the Parliament).
5. How long do we keep your personal data?
Your personal data will be retained for as long as necessary to fulfil the purposes we have outlined in section 2 of this Policy, including to provide you with the services and products requested, information relating to them and to maintain our business relationship.
We may retain your personal data after the termination of our business relationship if it is necessary to comply with applicable laws or surviving contractual provisions or if we need your personal data to establish, exercise or defend a legal claim.
If you would like to know more about the retention periods applicable to your personal data, you can contact us using details provided in section 12 below.
6. What if you provide us with someone else’s personal data?
In certain circumstances, you might provide us with another person’s personal data – (for example, contact details of your colleagues who can assist with certain orders). In these cases, we require you to inform that person that you will be sharing their personal data with us and the purposes for which you will share it. Please provide them with a link to or copy of this Policy and our contact details. Please also let them know that they should contact us if they have any additional questions about how we will use their personal data.
7. Your data protection rights
Under data protection laws, you may be able to exercise the following rights regarding your personal data:
You may have the right to obtain from us confirmation if personal data is being processed by us, and related information; and the right to obtain a copy of your personal data undergoing the processing.
You may have the right to request the rectification of inaccurate personal data and to have incomplete data completed.
Where we process your personal data on the basis of our legitimate interests, you may have the right to object to this processing for reasons relating to your particular situation. If this is the case, we will stop this processing of your personal data unless we can demonstrate compelling reasons why we need to process it, which override your rights and freedoms or where we need to process it for the purposes of legal claims. Where we process your personal data for direct marketing purposes, you may have the right to object to our processing of your personal data for this at any time.
You may have the right to receive your personal data that you have provided to us, in a structured, commonly used and machine-readable format and to transmit it to other data controllers without hindrance. This right only exists if the processing is based on your consent or a contract and the processing is carried out by automated means.
You may request that we restrict the processing of your personal data in certain cases, (so that we must suspend the processing, except for storage, with your consent or for legal claims) including for example where you object to us processing your personal data on the basis of our legitimate interests or where you want to establish the accuracy or the reason we are processing your personal data.
You may request to erase your personal data if (i) it is no longer necessary for the purposes for which we have collected it, (ii) you have withdrawn your consent and no other legal ground for the processing exists, (iii) you objected and no overriding legitimate grounds for the processing exist, or (iv) the processing is unlawful, or erasure is required to comply with a legal obligation.
Right to lodge a complaint
You have the right to lodge a complaint with a supervisory authority. This is the Information Commissioner’s Office in the UK but we would ask that you please get in touch with us in the first instance so that we can try to resolve your issue.
Right to refuse or withdraw consent
In case we ask for your consent to processing, you are free to refuse to give consent and you can withdraw your consent at any time without any adverse negative consequences. The lawfulness of any processing of your personal data that occurred prior to the withdrawal of your consent will not be affected.
Please be aware that not all of these rights are absolute and that there may be situations in which you cannot exercise them or they are not relevant.
8. Existence of automated decision-making
In order to provide its services to its clients, Logically may engage in automated decision- making and profiling. For example, identifying Coordinated Inauthentic Behaviour (CIB) patterns that assist analyst workflows to investigate narratives.
You have certain rights in relation to this type of processing, including the right not to be subject to solely automated decisions, including profiling. For more information about your rights, please see section 7.
10. Data security
We use encryption (HTTPS/SSL) to protect data transmitted to and from our site. However, it is important to note that data transmission over the Internet is never 100% secure. You should therefore take reasonable measures to ensure your account is secured. You use our services at your own risk, and you are responsible for taking reasonable measures to secure your account.
11. Third party embeds, third party links, downloads and media files
Logically often uses content hosted on other sites (such as articles and videos from news publications). This content is not hosted by Logically and therefore these files send data back to the hosted site as if you were visiting that site directly. Logically cannot control the data or what is done with the data collected from third parties in these cases, therefore third party embeds on Logically services are not covered by this Policy.
Any downloadable documents, files or media made available on this Website are provided to you at your own risk. While all precautions have been undertaken to ensure only genuine downloads are available, we advise you to verify their authenticity using third party anti-virus software or similar applications. We accept no responsibility for third party downloads and downloads provided by external third party websites and similarly advise you to verify their authenticity using third party anti-virus software or similar applications.
12. Questions and contact information
If you have any questions about this Policy or if you want to exercise your rights, please contact us using the contact details set out below:
By email at: firstname.lastname@example.org
By post at:
Data Protection Officer
C A P House,
9-12 Long Lane,
13. Changes to this Policy
We may update this Policy from time to time in response to changing legal, regulatory or operational requirements. We will notify you of any such changes, including when they will take effect, by updating the "Effective date" below or as otherwise required by applicable law.
Effective date: 12 October 2022