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2019

Privacy Policy

Introduction

 

Welcome to the Auspex International (“AUSPEX”, “we”, “us” or “our”) privacy policy. 

 

We respect the privacy of all data subjects and we are committed to protecting personal data, especially as it relates to our work commitments and company mission. This privacy policy will inform you as to how we look after your personal data (regardless of how it may have been collected by us or transferred to us) and tell you about your privacy rights and how the law protects you. 

 

We will not use or share your information with anyone except as described here. To the extent that this policy relates to use of our website, by doing so (including voluntarily submitting information directly or indirectly) you agree to the terms of this privacy policy. We may amend this policy from time to time without notice and your continued use of the website or other interaction with us (for example by phone or email) will confirm your agreement to the new terms. Any updates to the privacy policy will appear on this webpage. 

Purpose

 

This privacy policy aims to give you information on how Auspex collects and processes your personal data, including any data you may provide through this website, information we may collect through our research activities and resources that we may gain access from or on behalf of our clients.

 

We do not knowingly collect data on persons below 18 years of age and we do not normally include content in our communications or our website that is reasonably considered unsuitable for children. If you are aware of any such occurrences, please inform us so we can address them accordingly.

 

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

 

Controller

Auspex International is the controller and responsible for your personal data. This however may not be the case for personal data that we are merely processing on behalf of our clients, for whose data we may or may not be a controller under applicable law. 

 

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us using the details set out below. 

Contact details

 

Full name of legal entity: Auspex International Limited

 

Email address: info@auspexinternational.com

 

Postal address: c/o DSC Metropolitan Ltd, 1 The Courtyard, Chalvington BN27 3TD, United Kingdom 

 

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO directly, so please contact us in the first instance. 

Changes to the privacy policy and your duty to inform us of changes

 

We keep our privacy policy under regular review. This version was last updated on August 5th, 2019. Historic versions can be obtained by contacting us.

 

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

 

Third-party links

This 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. Note that this policy does not apply to any third-party websites that may be accessible through our own. We are not responsible for the practices employed by websites or pages not under our control and we do not endorse any of these websites or pages, their services, products or content. Please read over the rules and policies of third-party websites before using them.

 

The data we collect about you

 

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity was never collected or has been removed (anonymous or anonymised data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes information such as your name, date of birth or gender.

  • Contact Data includes information such as postal and email addresses, phone numbers and social media handles.

  • Financial Data includes information such as bank account and payment card details.

  • Transaction Data includes information such as details about payments to and from you in relation to our products and services.

  • Technical Data includes information such as internet protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our websites. 

  • Profile Data includes such as your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.  

  • Usage Data includes information such as how you use our websites, products and services. 

  • Marketing and Communications Data includes information such as your preferences in receiving marketing from us (including third parties operating on our behalf and our group companies) and your communication preferences.

  • Research and Client Data includes information collected or acquired by us for or on behalf of clients.

 

We also collect, use and share Aggregated Data such as statistical or demographic data. Aggregated Data could be derived from your personal data but is not considered personal data as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

 

We may collect or process sensitive data about you (as defined in the GDPR) in the context of our research and data-driven client projects, but this will always happen with your prior consent, in full compliance with all applicable laws and only to the extent necessary for the purposes of the project. For more information, you may get in touch with our DPO.

 

If you fail to provide personal data

 

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform as expected in our relationship with you.

How we collect personal data

 

We use different methods to collect data, including through:

  1. Direct interactions. You may give us your data by filling in forms, by participating in our research activities or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you -

    • enquire about our products or services;

    • create an account on our website;

    • subscribe to our newsletters or publications; 

    • request marketing materials to be sent to you;

    • enter a competition, promotion or survey; or

    • give us feedback or contact us for any reason. 
       

  2. Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. We use these data to improve your interaction with us and our business’ activities. 
     

  3. Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below: 
     

    1. Technical Data from the following parties:

      1. analytics providers; 

      2. advertising networks; and

      3. search information providers.

    2. Contact, Financial and Transaction Data from providers of technical, payment and delivery services.

    3. Identity and Contact Data from data brokers or aggregators, and publicly available sources.

    4. Research and Client Data, including:

      1. all types of data mentioned above that a client may have legally acquired, whether commercially available, gathered on proprietary digital assets, or in relation to organisation membership or other relationship; and

      2. data gathered by or through third-party service providers, including opinion, behavioural and other pertinent information.

 

How we use personal data

 

We will only use personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
 

  • Where we need to perform the contract we are about to enter into or have entered into with you.

  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

  • Where we need to comply with a legal obligation.

 

Generally, we endeavour to rely on consent as a legal basis for processing your personal data, including for the purpose of sending third party direct marketing communications. Nevertheless, we will from time to time rely on legitimate interest, contract performance or other legal justification for data processing as may be permissible under applicable law, some examples of which are shown below. Note that you have the right to withdraw consent to marketing at any time by contacting us.

 

Purposes for which we will use personal data

 

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below. 

Promotional offers from us 

 

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you. 

 

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us, or if you have opted in to receiving that marketing.

 

Marketing 

 

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

 

Opting out

 

You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting us at any time. 

 

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase.

 

Cookies

 

We use cookies to improve your interaction with us and our business’ activities. Cookies are small data files stored on your computer’s hard drive that help us first and foremost automatically provide you with personalized content which you requested. Cookies are harmless files that cannot access or affect other files or damage your computer. Although most browsers’ default settings accept cookies, you can customize your browser settings to refuse cookies or to warn you when cookies are detected. The table below shows which cookies we use and what they do.

Change of purpose 

 

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. 

 

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so or ask for your consent to proceed.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

 

Disclosures of your personal data

 

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

  • Our affiliated companies acting as joint controllers or processors within or outside the EEA, who may provide data analytics, IT and system administration services or undertake leadership reporting. 

  • Our third party service providers acting as processors based in EEA and Non-EEA countries.

  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in EEA and Non EEA countries who provide consultancy services.

  • HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.

  • 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. 
     

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

 

International transfers

 

We ensure your personal data is protected by requiring all our group companies to follow the same rules when processing your personal data. These rules are called "binding corporate rules". For further details, see European Commission: Binding corporate rules. 

 

Many of our external third parties are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.

 

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented 
 

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.

  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.  

  • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
     

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA. 

 

Data security

 

We are continuously improving our  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. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. 

 

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data retention

 

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.

 

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.

 

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us. By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

 

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

 

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

 

Your legal rights

 

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights: 
 

  • Request access to your personal data.

  • Request correction of your personal data.

  • Request erasure of your personal data.

  • Object to processing of your personal data.

  • Request restriction of processing your personal data.

  • Request transfer of your personal data.

  • Right to withdraw consent.

 

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.

 

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. 

 

Glossary

 

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

 

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

 

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

 

Consent means a freely given, specific, informed and unambiguous indication of your wishes by which you, by a statement or by a clear affirmative action, signify agreement to the processing of personal data relating to you. It can be withdrawn at any time. For more information, refer to the ICO website.