Last Updated: 23/03/2021
This notice applies to personal data provided by our clients or prospective clients as well as any third party agents or suppliers whose data we process, but does not apply to information we hold in relation to our staff or contractors. In this notice “you” refers to any individual whose personal data we hold or process. This privacy notice is governed by the EU General Data Protection Regulation (the “GDPR”), the Data Protection Act 2018 and any other applicable data or privacy legislation.
This notice may be updated from time to time and you should check this page regularly for any updates. Changes to this notice are effective when they are posted on this page.
Personal data we collect and how we process this data
Below we have set out the categories of data we collect, the legal basis we rely on to process the data and how we process the data:
Contact information for our users who submit an enquiry to us, subscribe to our newsletter or subscribe to our services (such as for market reports). Contact information may include your name, surname, company name, job title, country of location, email address, address or telephone number (“Contact Information”).
If you subscribe to our newsletter, we will process your Contact Information on the basis that you have consented to this and will only send our newsletter to you for as long as you continue to consent. Otherwise, we process this information to provide our services and communicate with you (including with respect to customer care and support) on the basis of performing our contract with you or on the basis of our legitimate interest in providing our services to you.
Contact information which we hold because you are a third party relevant to the services we provide to our clients (you may for example be a payment processor or marketing software provider) (“Third Party Contact Information”).
We process this information when we provide services to our clients on the basis of the performance of our contract with you or on the basis of our legitimate interest in providing our services to our clients.
A record of any correspondence or communication between you and us (“Communication Information”).
We process this information when we monitor our relationship with you and provide services to you on the basis of the performance of our contract with you or on the basis of our legitimate interest in providing our services to you.
Subscription information which we hold when you subscribe to our services, such as the provision of market reports. Such information includes Contact Information and Financial Information (“Subscription Information”).
We process Subscription Information on the basis of performing our contract with you or on the basis of our legitimate interest in providing our services to you. Financial information which we hold in the context of providing services to you (“Financial Information”) such as billing and banking details.
We process this information when we provide services to you on the basis of the performance of our contract with you or on the basis of our legitimate interest in providing our services to you.
Cookie Information. A cookie is a small text file which asks permission to be placed on your computer’s hard drive or mobile device. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Where applicable and necessary, we process Cookie Information on the basis that you have consented to this in order to improve or communicate with you about our services and/or to customise the website according to your personal interests.
Marketing information. We may hold information about you in order to provide information about our services. This may include names, job titles, email addresses, phone numbers, addresses, and other information (“Marketing Information”).
We process this information in order to improve or customise our services, communicate with you about our services or for market research purposes, on the basis of our legitimate interests in communicating with you about our services or on the basis that you have consented to receiving the information.
We generally collect information from you directly however in certain circumstances, we may also collect it from a third party. If we do obtain your personal data from a third party your privacy rights under this notice are not affected and you are still able to exercise the rights contained within this privacy notice.
Our current data retention policy is to delete or destroy (to the extent we are able to) personal data after the following periods:
- Following an enquiry with us, we will remove your Contact Information and Communication Information from our CRM system after a period of [3 years] unless you subsequently subscribe to our services with us.
- In respect of records relating to a contract with us — 7 years from either the end of the contract or the date you last used our services (whichever is later).
- In respect of Cookie Information — such data is removed after [3 years]. After such period, only aggregated data (from which all personal data has been removed) is stored by us.
- In respect of Marketing Information — [3 years] from the last date on which you have interacted with us.
For any category of personal data not specifically defined in this notice, and unless otherwise specified by applicable law, the required retention period for any personal data will be deemed to be 7 years from the date of receipt by us of that data. The retention periods stated in this notice can be prolonged or shortened as may be required (for example, in the event that legal proceedings apply to the data or if there is an on-going investigation into the data).
We review the personal data (and the categories of personal data) we are holding on a regular basis to ensure the data is still relevant to our business and is accurate. If we discover that certain data we are holding is no longer necessary or accurate, we will take reasonable steps to correct or securely delete this data as may be required.
If you wish to request that data we hold about you is amended or deleted, please see below for your privacy rights.
Sharing your information
We may disclose information to third parties in the following circumstances:
- We may work with other professionals and providers in providing and delivering our services to you—this may include a payment processor, marketing software provider, CRM or website management provider.
- We may disclose information to our group companies.
- If we are sub-contracting services to a third party we may provide information to that third party in order to provide the relevant services.
- If we are under a duty to disclose or share your personal data in order to comply with any legal obligation (for example, if required to do so by a court order or for the purposes of prevention of fraud or other crime).
- In order to enforce any terms and conditions or agreements for our services that may apply.
- As part of a sale of some or all of our business and assets to any third party or as part of any business restructuring or reorganisation, but we will take steps with the aim of ensuring that your privacy rights continue to be protected.
- To protect our rights, property and safety, or the rights, property and safety of our users or other third parties. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
If we do supply your personal data to a third party we will take steps to ensure that your privacy rights are protected and that such third party complies with the terms of this notice.
Cookies and IP Address
- Strictly necessary cookies — which are an essential part of our service and affect the way you can use our site (e.g. security & authentication)
- Performance cookies — which are used for analytics (e.g. understanding usage on our website)
- Functionality cookies — which collect information about your device to help you customize our service (e.g. remembering your username, language, time zone settings or accessing inline help)
On your first visit to our site from your browser we will display a notice to notify you that we are using cookies but we will not load any cookies, except for Strictly Necessary Cookies, until you have provided your consent by clicking the “Accept” button. If you click the “Accept” button on our cookies notice, Performance and Functionality cookies will also be loaded.
Below is a list of the cookies currently set by us:
- WordPress login cookies
- WordPress test cookie
- WordPress settings and time cookies
- WooCommerce session cookie
- WooCommerce cart cookie
- WooCommerce notice dismiss cookie
As well as cookies that are set by domains we control (first-party cookies), you may also see cookies set by a third party (third-party cookies). These are set when you interact with certain parts of our service and are used by these third-party services to understand your preferences and sometimes tailor content they show you.
You can change the way your browser handles cookies if you wish. You could accept or reject them by default or be notified when a website is trying to set or update cookie. Exactly how you disable cookies depends on the browser or device you are using. The help feature on most browsers will tell you how you how you can manage and or disable cookies. If you disable cookies on your browser, certain features or parts of our service may not function correctly or will have a degraded experience.
An Internet Protocol (IP) address is a number assigned to your computer by your Internet Service Provider (ISP), so you can access the Internet. We may use your IP address to diagnose problems with our server, report aggregate information, and determine the fastest route for your computer to use in connecting to our service, and to administer and improve the online service.
We will take all reasonable steps to ensure that appropriate technical and organisational measures are carried out in order to safeguard the information we collect from you and protect against unlawful access and accidental loss or damage. These measures may include (as necessary):
- protecting our servers by both hardware and software firewalls;
- locating our data processing storage facilities in secure locations;
- encrypting all data stored on our server with an industry standard encryption method that encrypts the data between your computer and our server so that in the event of your network being insecure no data is passed in a format that could easily be deciphered;
- when necessary, disposing of or deleting your data so it is done so securely;
- regularly backing up and encrypting all data we hold.
We will ensure that our staff are aware of their privacy and data security obligations.
We will take reasonable steps to ensure that the employees of third parties working on our behalf are aware of their privacy and data security obligations.
This notice and our procedures for handling personal data will be reviewed as necessary.
Third party links
We have no control over and are not responsible or liable for the content, privacy policies or practices of any third-party sites or services.
Your privacy rights
With respect to your personal data, you have:
The right to be informed — a right to know about our personal data protection and processing activities, details of which are contained in this notice
The right to access — the right to request a copy of any personal data that we have about you
The right to rectification — the right to request a correction of any errors in or update of the personal data that we have about you
The right to erasure (the ‘right to be forgotten’) — the right to request that your personal data is deleted from our records
The right to restrict processing — the right to request that we no longer process your personal data in certain ways, whilst not requiring us to the delete the same data
The right to object to processing — the right to request that your personal data will not be processed
The right to data portability — the right to request that your personal data be transferred or exported to another organisation
The right to withdraw consent — the right to withdraw any permission you have given us to process your personal data
Rights in relation to automated decision making and profiling:
- The right not to be subject to automated decision-making (including profiling) when those decisions have a legal (or similarly significant effect) on you
- The right to request that your personal data will not be used to contact you for direct marketing purposes
All SARs and other requests or notifications in respect of your above rights must be sent to us in writing via our contact page.
We will endeavour to comply with such requests as soon as possible but in any event we will comply within one month of receipt (unless a longer period of time to respond is reasonable by virtue of the complexity or number of your requests).
If personal data we hold about you is subject to a breach or unauthorised disclosure or access, we will report this to our data protection manager or officer (if an officer has been appointed) and the Information Commissioner’s Office (ICO) (as necessary).
If a breach is likely to result in a risk to your data rights and freedoms, we will notify you as soon as possible.
Transferring your information outside the EEA
We will not transfer your personal data in a systematic way outside of the European Economic Area or UK (together the “EEA”) but there may be circumstances in which certain personal data is transferred outside of the EEA, in particular:
From time to time, some of our data processors (including third party payment processors or server providers), may be based outside of the EEA. In that case, we will ensure we have an agreement in place with such processors to provide adequate safeguards and a copy of such safeguards will be available on request.
If you use our services while you are outside the EEA, your information may be transferred outside the EEA in order to provide you with our services or communicate with you.
We may communicate with individuals or organisations outside of the EEA in providing our services. Those communications may include personal data (such as contact information).
From time to time your information may be stored in devices which are used by our staff outside of the EEA (but staff will be subject to our cyber-security policies).
If we transfer your information outside of the EEA, and the third country or international organisation in question has not been deemed by the EU Commission to have adequate data protection laws, we will provide appropriate safeguards and we will be responsible for ensuring your privacy rights continue to be protected as outlined in this notice.
If at any time you would like to contact us with your views about our privacy practices, or with any enquiry or complaint relating to your personal data or how it is handled, you can do so via our contact page.