Introduction

This Privacy Policy will help you understand what data we collect from you, why we collect it and what we do with it. This policy explains how we store and use your personal information when you use or interact with our website, or where we otherwise obtain or collect your personal information. This Privacy Policy applies to all services offered by us, except where otherwise noted.

This statement also explains how we protect any personal data we obtain directly or passively from you or which we obtain indirectly from other sources.

We reserve the right to change our privacy statement from time to time. We will update the Privacy Policy page content and last modified date on our website. This privacy statement was last modified 21.05.2018.

Privacy Statement

We are committed to keeping your personal data safe and to ensuring the integrity and security of any personal data we may process.

You should read this privacy notice very carefully as it contains important information on the way in which we will process your personal data, in particular:

  • The personal information we collect about you
  • Our legal bases for processing your personal information
  • What we do with your personal information
  • Who your personal information may be shared with
  • Your rights as a data subject under the Data Protection regulation

If you have any questions about this Privacy Policy, please contact our Data Champions, Amy Morley or Sarah Lee – amy.morley@aspectusgroup.com / sarah.lee@aspectusgroup.com / 020 7242 8867.

Who are we?

Aspectus Group is a trading name of Sparx Communications Limited, a company incorporated and registered in England with company number 03551888.  Aspectus is the Controller of personal data relating to individuals within its client firms, for the purposes of relationship management, marketing and business development. Aspectus is also a Processor of data for the purposes of offering PR, marketing and communication services on behalf of its clients.

Data Champion

Our Data Champion contact details are:

Amy Morley / Sarah Lee
Aspectus Group
Ground Floor
James House
22-24 Corsham Street
London
N1 6DR

TELEPHONE: +44(0)20 7242 8867
EMAIL: amy.morley@aspectusgroup.com / sarah.lee@aspectusgroup.com

If you have any queries or requests concerning your personal information or how we process it, please contact us either via the Data Champions as detailed above, or at Aspectus Group, Ground Floor, James House, 22-24 Corsham Street, London, N1 6DR; +44(0)27 242 8867; info@aspectusgroup.com

Personal information we collect or obtain about you

We collect personal data relating to you and your use of our services from a variety of sources.  These are detailed below.  Further sections of this Privacy Policy then describe what we do with this information.

Information gained directly from you

We will collect personal data, such as your name, business address, business and mobile telephone number and business email address via: Meetings, telephone calls and conversations, from business cards, when registering for services, and when using our website.

We may also collect your personal work-related data, which is gained indirectly or passively, such as:

  • Service data – personal data that are provided in the course of the use of our services
  • Enquiry data – information contained in any enquiry you submit to us regarding our services
  • Correspondence data – information contained in or relating to any communication that we have with you
  • Third party data – publicly available sources such as social media sites where you have a publicly accessible profile, such as LinkedIn or your company website 

This data may include:

  • Names
  • Job title
  • Company
  • Email address
  • Phone Number
  • Company Address

We protect the data obtained from third parties according to the practices described in this statement.

Cookies and Similar Technology

We use various technology to collect and store information about you when you use our website, including the use of cookies to identify your browser or device. In particular, we use Google Analytics, which is a product that helps us analyse the traffic to our website.

A cookie is a small text file that is downloaded onto ‘terminal equipment’ (e.g. a computer or smartphone). It allows us to recognise the device you are using and store some information about your preferences or past actions.

There are cookies we use that are strictly necessary and essential for the use of our website, without these you will not be able to complete online quotes or purchases.

We also use cookies for legitimate business interests to improve the website experience and to analyse the number of visitors to the website. You can choose not to allow the use of some of these cookies during any visit to our website. To update your preferences, click here.

Our website may contain links to other websites which are outside our control and are not covered by this privacy statement. If you access other sites using the links provided, the operators of these sites may collect information from you which will be used by them in accordance with their Privacy Policy, which may differ from ours. You must contact them to determine their Privacy Policy.

Our legal basis for processing your personal data

We may rely on a number of legal bases for collecting and further processing your personal data, which are:

  • Contractual Necessity
  • Legal Obligation
  • Legitimate Interest
  • Consent

Contractual Necessity

We collect personal information about you when you request our services. We will ask you to provide some information about yourself for security, identification and verification purposes.

We will also collect personal data for the purposes of the performance of a contract with you, such as:

  • Providing access and use of our services
  • Administering accounts with us
  • Communicating with you about our services
  • Legal Obligation

We may also process your personal information to allow us to comply with certain legal obligations to which we are subject. We will also work co-operatively with the national data protection authority, and the ICO, in relation to any data protection matters.

Legitimate Interest

We may use your personal data for our legitimate business interests, whilst carefully considering and balancing any potential impact on you and your rights as a data subject under the relevant data protection regulation.

This may include processing your personal data to allow us to provide the best services and customer experience and to ensure our service remains relevant and tailored to your needs.

We will always ensure that our legitimate interests will never override your rights and freedoms under the data protection regulation.

As an example, we may rely on our legitimate interest to process your personal data for the following purposes:

  • For Direct Marketing, relating to products and services that are compatible with the original purpose for which we originally gained the information
  • To communicate with you, including newsletters and marketing materials
  • To communicate important updates about our business or services, which we think may be of interest to you
  • For evidential purposes to effectively manage and maintain records of our relationships/communications with you
  • For business development related activity such as contacting you by telephone or email to arrange meetings with our experts in relation to work or knowledge sharing
  • To enhance, modify, personalise or otherwise improve our services and communications for the benefit of you
  • To better understand how you interact with our website and content in order to enhance your customer experience
  • To determine the effectiveness of promotional campaigns to inform marketing strategy
  • In addition, we may use its legitimate interests to perform statistical and other analysis on the personal data we collect, to help us understand and improve on how people use our products or services

Please note, you have the right to object to the processing for which we rely on legitimate interest as the legal basis. You can do so, and update you marketing preferences here.

Consent

We are required to gain your explicit consent prior to processing any sensitive information about you, or where we are processing your personal data for any other purpose, other than the original purpose for which it was gained.

Where we require such consent, we will provide you with sufficient information to allow you to make an informed decision. We will ensure that we only gain consent via a clear and affirmative act, freely given by you that indicates your consent to specific purposes.

You have the right to withdraw your consent at any time and can do so here.

How we use your personal data

We will only process your data where have a legal basis for doing so. We use data collected to communicate with you and to offer you our services. We may use your data to improve or maintain the services we offer to you. We will never share your data with any other third party, other than those stated in this policy, nor use your data for any other purpose, unless we firstly gain your explicit consent to do so.

You have the right to restrict the processing of your personal data. You have ability to choose which promotional communications you wish to receive and how you would like to receive them. To manage your subscriptions or contact details, please click here.

We categorise the use of your personal information for in different ways, namely:

Category of Personal Data Description Legal Basis for Processing Example
Personally Identifiable Information This is personal information, such as name, address or email Pre-Contractual or
Contractual
Enabling you to access and use our services
Special Category Information Data relating to your Physical or mental health or condition. Consent Prior to processing this data, you will provided with details on why we would like to process this information and how this will be used.  Such data will only be processed with your explicit consent.
Financial Information We hold invoice information relating to clients and the company accounting information, nothing personal

Your rights as a data subject

As a data subject, you can exercise certain rights in relation to the processing of your personal data, under the relevant data protection regulation, as detailed in the table below:

Your Right What this means How you can exercise this right
The Right of Access You have the right to confirmation on whether or not we are processing your personal data and, where that is the case, access to that data, including the following information:

  • The purpose of the processing
  • The recipients or categories of recipient to whom the personal data has been or will be disclosed.
  • The envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period

We shall provide a copy of the personal data being processed free of charge.

We will respond to your request within one month.

We will advise any other recipients to whom the personal data has been disclosed.

You can request this information at no charge from us by emailing amy.morley@aspectusgroup.com / sarah.lee@asepctusgroup.com or by telephoning +44 (0) 20 72442 8867
The Right to Rectification You shall have the right to obtain from us without undue delay the rectification of inaccurate personal data concerning you.

Taking into account the purposes of the processing, you shall also have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

We will respond to your request within one month.

We will advise any other recipients to whom the personal data has been disclosed.

You can request this information at no charge from us by emailing sarah.lee@aspectusgroup.com / amy.morley@aspectusgroup.com or by telephoning +44 (0) 20 72442 8867
The Right to Erasure In some circumstances you have the right to have your personal data erased and no longer processed where:

  • The personal data is no longer necessary in relation to the purposes for which they were collected or otherwise processed;
  • You withdraw consent on which the processing is based, and where there is no other legal ground for the processing;
  • You object to the processing and there are no overriding legitimate grounds for the processing
  • The personal data has been unlawfully processed;
  • The personal data has to be erased for compliance with a legal obligation.

We will respond to your request within one month.

We will advise any other recipients to whom the personal data has been disclosed.

You can request this information at no charge from us by emailing sarah.lee@aspectusgroup.com / amy.morley@aspectusgroup.com or by telephoning +44 (0) 20 72442 8867
The Right to Restrict Processing You have the right to obtain the restriction of processing where one of the following applies:

  • The accuracy of the personal data is contested, for a period enabling the verification of the accuracy of the personal data;
  • The processing is unlawful and you object to the erasure of the personal data and request the restriction of their use instead;
  • We no longer need the personal data for the purposes of the processing, but are required by you for the establishment, exercise or defence of legal claims;
  • You have objected to processing pending verification of whether our legitimate grounds override yours.

Where you have obtained restriction of processing, you have the right to be informed by us before the restriction of processing is lifted.

We will respond to your request within one month of your request.

We will advise any other recipients to whom the personal data has been disclosed.

We will advise any other recipients to whom the personal data has been disclosed.

You can request this information at no charge from us by emailing sarah.lee@aspectusgroup.com / amy.morley@aspectusgroup.com or by telephoning +44 (0) 20 72442 8867
The Right to Restrict Processing You have the right to obtain the restriction of processing where one of the following applies:

  • The accuracy of the personal data is contested, for a period enabling the verification of the accuracy of the personal data;
  • The processing is unlawful and you object to the erasure of the personal data and request the restriction of their use instead;
  • We no longer need the personal data for the purposes of the processing, but are required by you for the establishment, exercise or defence of legal claims;
  • You have objected to processing pending verification of whether our legitimate grounds override yours.

Where you have obtained restriction of processing, you have the right to be informed by us before the restriction of processing is lifted.

We will respond to your request within one month of your request.

We will advise any other recipients to whom the personal data has been disclosed.

We will advise any other recipients to whom the personal data has been disclosed.

You can request this information at no charge from us by emailing sarah.lee@aspectusgroup.com / amy.morley@aspectusgroup.com or by telephoning +44 (0) 20 72442 8867
The Right to Restrict Processing You have the right to obtain the restriction of processing where one of the following applies:

  • The accuracy of the personal data is contested, for a period enabling the verification of the accuracy of the personal data;
  • The processing is unlawful and you object to the erasure of the personal data and request the restriction of their use instead;
  • We no longer need the personal data for the purposes of the processing, but are required by you for the establishment, exercise or defence of legal claims;
  • You have objected to processing pending verification of whether our legitimate grounds override yours.

Where you have obtained restriction of processing, you have the right to be informed by us before the restriction of processing is lifted.

We will respond to your request within one month of your request.

We will advise any other recipients to whom the personal data has been disclosed.

We will advise any other recipients to whom the personal data has been disclosed.

You can request this information at no charge from us by emailing sarah.lee@aspectusgroup.com / amy.morley@aspectusgroup.com or by telephoning +44 (0) 20 72442 8867
The Right to Object You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on our legitimate interest.

You also have the right to object to processing for direct marketing purposes. Where you object to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.

We will respond to your request within one month of your request.

We will advise any other recipients to whom the personal data has been disclosed.

To object to us processing your personal data for direct marketing or other legitimate interest purposes, please click here.

This may take a maximum of 72 hours.

The Right to Data Portability You have the right to receive the personal data concerning you, which you have provided to us and have the right to transmit this data to another controller without hindrance from us to which the personal data have been provided, where:

  • The processing is based on consent or on a contract
  • The processing is carried out by automated means.

Where feasibly possible, you also have the right to have the personal data transmitted directly to another controller.

We will respond to your request within one month of your request.

You can request this information at no charge from us by emailing sarah.lee@aspectusgroup.com / amy.morley@aspectusgroup.com or by telephoning +44 (0) 20 72442 8867
The Right to Complain You have the right to lodge a complaint with the Information Commissioner’s Office (ICO). The contact details of the ICO are:

Website: ico.org.uk
Helpline: 0303 123 1113

The Right to Understand the Source of data gained indirectly You have the right to be informed of the source of any personal data that are not collected directly from you. You can request this information at no charge from us by emailing sarah.lee@aspectusgroup.com / amy.morley@aspectusgroup.com or by telephoning +44 (0) 20 72442 8867
The Right to be advised of any Automated decision-making Unless the information is necessary for entering into a contract with us, or you have given your explicit consent, you shall have the right not to be subject to a decision based solely on automated processing, which produces legal effects that affect you.

‘Automated decision-making’ is where a decision is made without human involvement.

We will respond to your request within one month of your request.

You can request this information at no charge from us by emailing sarah.lee@aspectusgroup.com / amy.morley@aspectusgroup.com or by telephoning +44 (0) 20 72442 8867
The Right to be advised of appropriate safeguards for the transfer of personal data to a third country Where personal data are transferred to a third country (outside of the EU) or to an international organisation, you shall have the right to be informed of the appropriate safeguards relating to the transfer. We will advise you of this prior to any such processing taking place.

Who we share your data with

We do not share data outside of the EU other than data shared with its US subsidiary. Our US subsidiary participates in the EU-US Privacy Shield, which is a mechanism recognised by the Information Commissioner’s Office (ICO) as complying with the data transfer requirements. This ensures adequate protection for the transfer of personal data.

We do not sell your personal data or other information to any third-party.

Security and Confidentiality

We are committed to transparency, ensuring that your privacy is protected and that your data is used and retained fairly, transparently and in accordance with the GDPR.

We will make sure that we have appropriate technical and organisational measures in place to keep your personal data secure and to protect against accidental or unlawful destruction, loss alteration, disclosure or access. We will provide a level of security appropriate to the risk presented by the nature of the processing we do. Your personal data will be held securely in our systems so that we can manage your relationship with us.

Retention Period

We will only keep your personal data for as long as necessary for the purposes for which it was gained. Personal data will be retained for the purposes of direct marketing, relationship management and business development, or where we have another legal basis for processing (such as consent).

We will review the personal data we hold in line with our retention policy, to check for accuracy and relevancy and to ensure that we continue to have a legal basis for processing. If the personal data is no longer necessary, or where we no longer have the legal basis for processing we will delete or fully anonymise the data we hold on you, in line with our Data Protection Policy. If your data becomes inaccurate, we will update it accordingly.

Complaints

We will be more than happy to help should you have any complaints about the processing of your personal data. You have the right to lodge a complaint with the Supervisory Authority, ICO, who are the national authority responsible for the protection of personal data. A complaint can be made to the ICO via their website (ico.org.uk) or through their helpline (0303 123 1113).