GDPR Compliance

GDPR Privacy Notice – Shazam Tech

Last updated: May 24, 2025

Purpose of this notice

This Privacy Notice provides mandatory information as required under Articles 13 and 14 of the European General Data Protection Regulation (GDPR) regarding the transparency of personal data processing. Definitions of certain terms within this notice are explained in the appendix.

In the UK, the 2018 General Data Protection Act (DPA2018) applies to the processing of personal data. The DPA2018 Part 2 recognizes and aligns to the GDPR (the UK GDPR); in this document the requirements of the GDPR will therefore be deemed to include the processing of data in the EU, EEA, and the UK unless otherwise specified.

The Data Controller for personal data

The Data Controller for the personal data processed by us is the Client Company of Shazam Tech (the employer of the natural person whose data is collected; hereafter referred to as the Data Subject). The Data Controller may pass personal data of their employees to Shazam Tech in connection with the services being provided by Portway Systems to the Client.

Shazam Tech, as Data Processor acting on the instructions of the Data Controller under a written contract with them, will subsequently use that personal data where necessary within the services being supplied to the Client. It is this contract which forms the ‘Legal Basis’ for the processing of personal data carried out by Shazam Tech in these circumstances Shazam Tech will be a Data Controller only if it collects personal data directly from a Data Subject in relation to a separate contract with them.

Shazam Tech also acts as a Data Controller for any personal data held regarding its own employees, processing data under its Contract of Employment with those Data Subjects. In both cases, Shazam Tech processes personal data under Article 6.1(b) of the GDPR (performance of a contract) and Section 8 of the DPA2018.

Your Rights

As an EU or UK citizen, you have rights under the GDPR. These rights can be seen below. Shazam Tech will always fully respect your rights regarding the processing of your personal data and has provided below the details of the person to contact if you have any concerns or questions regarding how we process your data, or if you wish to exercise any rights you have under the GDPR.

Contact Details

The identity and contact detail for the Data Protection Officer within Shazam Tech is:

Mr. Doctor Bilal Ahmad, CEO

Shazam Tech

468A Stratford Rd, Birmingham

B11 4AE

Data Protection Principles

Shazam Tech has adopted the following principles to govern its collection and processing of Personal Data:

  • Personal Data shall be processed lawfully, fairly, and in a transparent manner.
  • The Personal Data collected will only be those specifically required to fulfil contracted services to Shazam Tech Clients. Such data may be collected directly from the Data Subject or provided to Shazam Tech via his/her employer. Such data will only be processed for that purpose.
  • Personal Data shall only be retained for as long as it is required to fulfil contractual requirements, or to provide statistics to our Client Company.
  • Personal Data shall be adequate, relevant, and limited to what is necessary in relation to the purposes for which they are collected and/or processed. Personal Data shall be accurate and, where necessary, kept up to date.
  • The Data Subject has the right to request from Shazam Tech access to and rectification or erasure of their personal data, to object to or request restriction of processing concerning the data, or the right to data portability. In each case, such a request must be put in writing as in Section 3 above.
  • The Data Subject has the right to make a complaint directly to a supervisory authority (Data Protection Authority) within their own country. Shazam Tech uses the EU Data Protection Authorities (DPAs) as our organization's independent recourse mechanism (IRM) for data transferred from the EU.
  • Personal Data shall only be processed based on the legal basis explained in Section 2 above, except where such interests are overridden by the fundamental rights and freedoms of the Data Subject which will always take precedence. If the Data Subject has provided specific additional consent to the processing, then such consent may be withdrawn at any time (but may then result in an inability to fulfil travel requirements).
  • Shazam Tech will not use personal data for any monitoring or profiling activity or process.

Transfers to Third Parties

Personal Data shall not be transferred to a country or territory outside the European Economic Area (EEA) or the UK unless the transfer is made to a country or territory recognised by the EU/UK as having an adequate level of Data Security, or is made with the consent of the Data Subject, or is made to satisfy the Legitimate Interest of Shazam Tech in regard to its contractual arrangements with its clients.

All internal group transfers of Personal Data shall be subject to written agreements under the Company's Intra Group Data Transfer Agreement (IGDTA) for internal data transfers, which are based on Standard Contractual Clauses recognised by the European Data Protection Authority.

Appendix - Definitions of Certain Terms

Personal Data

(Article 4 of the GDPR) "Personal data" means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Processing

(Article 4 of the GDPR) Means any operation or set of operations which is performed upon personal data or sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, erasure or destruction.

Legal Basis for Processing

(Article 6 of the GDPR) At least one of these must apply whenever personal data is processed:

  • Consent: The individual has given clear consent for the processing of their personal data for a specific purpose.
  • Contract: The processing is necessary for compliance with a contract.
  • Legal obligation: The processing is necessary to comply with the law (not including contractual obligations).
  • Vital interests: The processing is necessary to protect someone's life.
  • Public task: The processing is necessary to perform a task in the public interest, and the task or function has a clear basis in law.
  • Legitimate interests: The processing is necessary for the legitimate interests of the Data Controller unless there is a good reason to protect the individual's personal data which overrides those legitimate interests.

Data Controller

(Article 4 of the GDPR) The person or company that determines the purposes and the means of processing personal data.

Data Processor

(Article 4 of the GDPR) A natural or legal person, public authority, agency or any other body which processes personal data on behalf of the controller.

Data Subject Rights

(Chapter 3 of the GDPR) Each Data Subject has eight rights. These are:

  • The right to be informed – Anyone processing your personal data must make clear what they are processing, why, and who else the data may be passed to.
  • The right of access – Your right to see what data is held about you by a Data Controller.
  • The right to rectification – The right to have your data corrected or amended if what is held is incorrect in some way.
  • The right to erasure – Also known as “the right to be forgotten.” You may request that your data be erased in certain circumstances.
  • The right to restrict processing – The right to ask for a temporary halt to processing of personal data, such as in the case of a dispute or verification of data.
  • The right to data portability – The right to obtain and reuse your personal data for your own purposes across different services.
  • The right to object – In certain cases, you have the right to object to your data being processed.
  • Rights in relation to automated decision making and profiling – The GDPR provides safeguards against the risk that a potentially damaging decision is taken without human intervention.