Privacy Culture Limited (“PCL”) is committed to building your confidence and trust by complying with data protection legislation and best practices that protect your privacy and safeguards your personal information.
This Privacy Notice explains how we collect, use, store, share and protect your personal information.
We are registered with the UK Information Commissioner's Office.
Our data protection registration number is ZA551135
1. Who is responsible for personal information?
Name: Privacy Culture Limited (“PCL”)
Address: Bouverie House, 154-160 Fleet St, London EC4A 2DQ.
Email: [email protected]
Phone number: +44 (0) 20 7112 9360
2. What personal information do we collect?
The information that we collect may include:
- Personal identifiers such as your name, date of birth, title, address, and contact details including postal address, post-code, email, telephone number, and organisation's name.
- Occasionally, as part of the functions described in this policy, we may need to process special category of data. We endeavour to do so only when necessary and we will treat and process such data with great care and in accordance with the applicable data protection laws.
3. How do we collect your personal information?
We collect data directly from you when you:
- Subscribe to our newsletters and email notifications.
- Communicate with us through our website via our 'Get in Touch' form or email or call us in order to find out more about our services and the Horizon platform.
- Individuals and organisations with whom you have either confirmed consent or otherwise have lawful basis to share data with us based on legitimate interest and after informing you consequently, such as data brokers.
- Apply to join our team.
- When you visit and use our website.
We also collect information from other sources:
- Partnerships with trusted third parties and stake holders such as OneTrust, DPWF, PrivSec including security and privacy specialist tech providers.
- Individuals and organisations with whom you have confirmed consent.
- Website and system management tools that help deliver our platforms/services.
- Publicly available information.
- Government, tax or law enforcement agencies.
4. Why do we collect and use your personal information?
We may collect use your personal data for the following:
- To respond to enquiries submitted or to provide products or services to our clients, and subscribers.
- To enable you to use our services and to participate in any of our programmes.
- To respond to complaints made by or about you relating to our website, services, and programmes.
- We may also process your personal information for our legitimate business interests; that is, in order to facilitate the management of our business. This includes the following purposes:
- To enhance, modify, personalise or improve our services to the benefit of clients and prospective customers.
- To provide postal and/or email communications which we think will be of interest to you.
- To send surveys and feedback requests to improve our services to the benefit of clients and prospective customers.
- To enhance the security of our information systems or identify and prevent fraud.
- To conduct research and make statistical analysis and administration, including analysis of trends, carrying out actuarial work, tailoring products and services, risk assessment and analysis of costs in relation to our services. We will always ensure that such data is depersonalised or aggregated and can therefore not be personally identifiable to you.
Whenever we process data for these purposes, we will ensure that we always keep your information rights in high regard and take account of these rights.
5. Your Marketing and Contact Preferences
PCL is committed to respecting your preference to receive marketing and advertising information from us. We may contact you with information about our products, programmes, events, courses or other resources that may be of interest to you.
You can change or update your marketing communication by clicking the 'Unsubscribe' link included in every email communication we send to you or by contacting us on the contact details provided in this Privacy Notice.
Email & Text Marketing
PCL will ask for your permission to contact you by email or text for marketing purposes.
We may call to update you on our services and programmes. If you have registered your number with the Telephone Preference Service (TPS) or Corporate Telephone Service Preference (CTPS), we will only make marketing calls if you have expressly granted us permission to do so.
If you tell us that you no longer wish to receive our direct marketing communications, we will take steps to respect your modified direct marketing preferences and will keep a record of your request to avoid contacting you again in the future with direct marketing content.
6. Your data protection rights and choices
Under Data Protection laws you are entitled to exercise the following rights:
- Access: you have the right to request access to and/or a copy of your personal information.
- Rectification: you have the right to ask us to modify your personal information that you think is inaccurate or incomplete. Please do not hesitate to contact us, so that we can keep your personal information up to date.
- Erasure: you have the right to request the deletion of the personal information we hold about you. Please note that PCL may need to retain some, minimal information in order to respect your request to be excluded from processing.
- Restriction: you have the right to ask us to limit the processing of your personal information.
- Data Portability: you have the right to request that your personal information is provided to you in a machine-readable format.
- Object: you have the right to object to the processing of your personal information if it is based on legitimate or public interest.
- Automated decision-making: you have the right not to be subject to decisions based only on automated processing.
- Consent: you can withdraw your consent at any time by contacting us on the details provided in this Privacy Notice.
- You can choose whether to have marketing communications from us by email, text or telephone. You can update your contact preferences by contacting us using the information in this Notice.
- To know about the cookies that PCL uses so that you can decide whether to give us permission to place a cookie on your device, please refer to our Cookies Policy, for more information.
To exercise your rights please sent us your request to the address provided in this Notice. If you are not satisfied with our response, you may report to the Information Commissioner's Office (ICO). Details on how to do so can be found on the ICO's website at https://ico.co.uk.
For more information about your information rights visit www.ico.org.uk
7. How long do we retain your personal data?
The length of time that we hold your personal data varies depending on the type of information and its use. We will only keep your personal data for as long as it is necessary to provide the services and/or products that you have requested, for the execution of a contract or for such other essential purposes such as, complying with our legal obligations, resolving disputes, investigating disciplinary matters and enforcing our agreements. When your personal data is no longer necessary, it will be securely deleted or anonymised. If you have any questions about our Data Retention Policy, please contact us at [email protected].
8. Do we share your personal data?
Where necessary and in limited circumstances, we may share your personal information with third parties to the extent permitted by or required by law including to:
- Meet our legal obligations.
- Provide reasonable voluntary cooperation with a relevant police or regulatory investigation or any ongoing or prospective legal proceedings.
- In order to establish, exercise or defend our legal rights, including providing information to others for the purposes of fraud prevention and reducing credit risk.
In addition, we make use of expert third party service providers to help us to provide relevant services, such as expert IT providers helping us with our IT systems, or professional auditors. These third-party service providers may use your personal information in order to provide the agreed service to us, or to you on our behalf. We have contractual agreements in place with third party data providers and we ensure that they are fully compliant with data protection laws.
Your personal information may be held by us in one or more customer relationship management (CRM) database(s), consolidating details of your dealings with us across various services, to ensure we have clear and accurate records about your use of our services/programmes, to better understand your requirements and how we might provide other services/programmes to you.
We may share personal information within our advisory boards, panels and stakeholders, as needed for reasonable management, analysis, planning and decision making, including in relation to taking decisions regarding our service/programme offering.
9. International Transfers
In the occasion where your personal data is being transferred to countries outside the EEA either by us or by our third -party service providers acting on our behalf, PCL shall put in place all the necessary organisational and technical measures to ensure those transfers are adequately protected and guarantee the security and the lawful processing of your personal information in accordance with the law.
We take all appropriate technical and organisational measures to ensure that your personal information is protected, in compliance with our legal obligations. We protect your information using measures that reduce the risks of loss, misuse, unauthorised access, disclosure and alteration. 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.
12. Privacy Notice Updates
We keep our privacy notice under regular review in order to reflect the changes in law and/or our privacy practices. Please check our website from time to time. In the occasion of significant changes in the way we process your personal data, we will provide a prominent notice on our website. This Privacy Notice was last updated in February 2022.
13. Complains and queries
At PCL we do our best to meet the highest standards when handling personal information. For this reason, we take any complaints we receive about this very seriously. We encourage people to bring it to our attention if they think that our collection, use or storage of personal information is unfair, misleading or inappropriate.
We also welcome any suggestions for improving our procedures. Any correspondence should be sent to the contact details provided in this Notice. If you are not satisfied with our response, you may report to the Information Commissioner's Office (ICO). Details on how to do so can be found on the ICO's website at www.ico.org.uk.
14. How to contact us
Our principal address is at Bouverie House, 154-160 Fleet St, London EC4A 2DQ. You can contact us by emailing [email protected]
or [email protected]
You can also call us : +44 (0) 20 7112 9360.