Direct marketing 

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You may receive marketing from us if you: 

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• have enquired about our services on behalf of your organisation directly or via the Website and you have not opted out of receiving the marketing; 

• have worked with us either through your organisation being a client or a supplier of ours; and/or

• work for an organisation and your work contact details are available publicly online.

We may also analyse your Identity, Contact, Technical, and Website Usage Data to form a view on which of our services may be of interest to your organisation so that we can then send you relevant marketing communications. 

Third-party marketing 

We will get your express consent before we share your personal data with any third party for their own direct marketing purposes. However, for the avoidance of doubt, we do not sell personal data to any third party for marketing purposes (their purposes or ours). 

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Opting out of marketing 

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You can ask us to stop sending you marketing communications at any time by following the opt-out links within any marketing communication sent to you or by contacting us. 

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If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or client service purposes. 

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Cookies

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For more information about the cookies we use and how to change your cookie preferences, please see our cookie policy.

5. Disclosures of your personal data

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We may share your personal data where necessary with the parties set out below for the purposes set out in the table above.

• Cloud computing service providers such as Google. 

• IT service providers that help us manage our products, services and this Website.

• External consultants who provide us with consultancy or business development services. 

• Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services. 

• Data monitoring and analysis service providers such as Google. 

• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy. 

These third parties are mainly our service providers that provide us with a variety of administrative, statistical, and technical services. We will only provide service providers with the minimum amount of personal data they need to fulfil the services we request. Within the meaning of the UK GDPR, these are our processors. 

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6. International transfers

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Whenever we transfer your personal data out of the UK to countries which have laws that do not provide the same level of data protection as the UK law, we always ensure that a similar degree of protection is afforded to it by ensuring that the following safeguards are implemented:

• We will only transfer your personal data to countries that have been deemed by the ICO to provide an adequate level of protection for personal data.

• We may use specific standard contractual terms approved for use in the UK which give the transferred personal data the same protection as it has in the UK. To obtain further information about these contractual safeguards, please contact us.

7. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. 

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We will notify you and any applicable regulator of any personal data breach where we are legally required to do so.

8. Data retention

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How long will you use my personal data for?

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We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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To determine the appropriate retention period for personal data, 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.

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In some circumstances you can ask us to delete your data: see section 9 below for further information.

Where we anonymise personal data, we may use this information indefinitely without further notice to you.

9. Your rights

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You have a number of rights under data protection laws in relation to your personal data. 

You have the right to:

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

• Request correction of the 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 in certain circumstances. 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 law. 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) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.

• You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes (as set out in section 4 above). 

• Request the 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. 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.

• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:

  • if you want us to establish the data's accuracy;

  • where our use of the data is unlawful but you do not want us to erase it;

  • 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; or

  • you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

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.

What we may need from you

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.

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Time limit to respond

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. 

10. Third-party links  

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The 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 the Website, we encourage you to read the privacy policy of every website you visit.