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 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
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.
Our Data Champion contact details are:
22-24 Corsham Street
TELEPHONE: +44(0)20 7242 8867
If you have any queries or requests concerning your personal information or how we process it, please contact us either via the Data Champion as detailed above, or at Aspectus Group, Ground Floor, James House, 22-24 Corsham Street, London, N1 6DR; +44(0)27 242 8867; firstname.lastname@example.org
Personal information we collect or obtain about you
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:
- Job title
- 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
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
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
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.
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.
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 (your rights). 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
|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|
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.
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.
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 (your rights). A complaint can be made to the ICO via their website (ico.org.uk) or through their helpline (0303 123 1113).