Purpose of this notice
This notice describes how we collect and use personal data about you, in accordance with the General Data Protection Regulation (“GDPR”) and any other national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK (“Data Protection Legislation”). It should be read in conjunction with our Terms and Conditions and Cookies Policy.
Please read the following carefully to understand our practices regarding your personal data and how we will treat it.
Orqoe Limited (“Orqoe, “we”, “us” and “our”) is a company registered in England and Wales with registered number 13827627. Registered office address: 63-66 Hatton Garden, London EC1N 8LE, United Kingdom.
For the purpose of the Data Protection Legislation and this notice, we are the ‘data controller’. This means that we are responsible for deciding how we hold and use personal data about you. We are required under the Data Protection Legislation to notify you of the information contained in this notice.
We have appointed a Data Protection Officer. Our Data Protection Officer is responsible for assisting with enquiries in relation to this notice or our treatment of your personal data. Should you wish to contact our Data Protection Officer, you can do so using the contact details noted in the ‘Contact us‘ section below.
Personal data is any information relating to an identifiable person who can be directly or indirectly identified by reference to that information.
Special category personal data:
– personal information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership
– genetic and biometric data
– data concerning health, sex life or sexual orientation
The kind of personal data we collect about you
The information we collect about you may include the following:
– your personal details (such as your name and contact information, including job title and email address)
– your demographic information such as post code, preferences and interests
– your billing information, transaction and payment card information
– information about how you use our website, IT, communication and other systems
– your responses to surveys, competitions and promotions
– your attendance at conferences, travel and accommodation arrangements and dietary requirements
– your photograph
– information we receive from other sources, such as publicly available information
This personal information is required to provide our services to you. If you do not provide personal information we ask for, it may delay or prevent us from providing the services to you.
How your personal data is collected
We collect most of this personal information directly from you – in person, at conferences, via our website and by digital & non-digital communication. However, we may also collect information:
– from your business
– from publicly available resources
– from an individual or business who you have authorised on your behalf
How and why we use your personal information
Under data protection law, we can only use your personal information if we have a proper reason for doing so, e.g.:
– to comply with our legal and regulatory obligations;
– for the performance of our contract with you or to take steps at your request before entering into a contract;
– for our legitimate interests or those of a third party; or
– where you have given consent.
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
The following explains what we use (process) your personal information for and our reasons for doing so:
What we use your personal information for:
– to provide our services
– ensuring business policies are adhered to, e.g. policies covering security and internet use
– operational reasons, such as improving efficiency, training and quality control
– ensuring the confidentiality of commercially sensitive information
– statistical analysis to help us manage our business, e.g. in relation to our services, partner firms, client representatives
– updating client records/internal record keeping
– ensuring safe working practices, staff administration and assessments
– marketing our services and those of selected third parties to: clients; prospective client; third parties who we may wish to engage to provide services for the benefit of our clients.
– for the performance of our contract with your firm
– for our legitimate interests or those of your firm or other third party, i.e. to make sure we are following our own internal procedures so we can deliver the best service to you
– for our legitimate interests or those of your firm or other third party, i.e. to be as efficient as we can so we can deliver the best service to you
– for our legitimate interests or those of your firm or other third party, i.e. to protect your commercially valuable information
– to comply with our legal and regulatory obligations
– for our legitimate interests or those of a third party, i.e. to promote our business to existing, prospective and former clients
We may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data.
If we believe that we need to process special categories of personal data, we will only do so with your explicit consent.
We may use your personal information to send you updates (by email) about our products and services, including our newsletter, client services information, upcoming conferences or new services.
We have a legitimate interest in processing your personal information for promotional purposes (see above ‘How and why we use your personal information’). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.
We will always treat your personal information with the utmost respect and never sell it to or share it with other organisations for marketing purposes.
You have the right to opt out of receiving promotional communications at any time by contacting us at email@example.com.
We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.
Who we share your personal information with
We may share your personal information with:
– third parties we use to help deliver our services to you, e.g. other professional services firms
– other third parties we use to help us run our business, e.g. website hosts; printers
– your business or other clients, e.g., when making referrals or recommendations
We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers to ensure they can only use your personal information to provide services to us and to you.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
We will not share your personal information with any other third party.
Where your personal information is held
Information may be held at our offices and those of our third party agencies, service providers, representatives and agents as described above.
Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below: ‘Transferring your personal information out of the EEA’.
Transferring your personal information out of the EEA
To deliver services to you, it is sometimes necessary for us to share your personal information outside the European Economic Area (EEA), e.g.:
– with your and our service providers located outside the EEA;
– if you are based outside the EEA;
These transfers are subject to special rules under European and UK data protection law.
Some of our external third parties are based outside the European Economic Area (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 that the safeguards required in the GDPR are in place before we transfer your personal information.
How long your personal information will be kept
We will keep your personal information while you remain a client or you remain a partner, employee, officer or representative of a client or we are otherwise providing services to you. Thereafter, we will keep limited personal information for as long as is necessary:
– to respond to any questions, complaints or claims made by you or on your behalf;
– to enable us to check whether individuals have previously been associated with clients;
– to contact you in connection with professional referrals;
– to show that we treated you fairly;
– to keep records required by law.
We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information. When it is no longer necessary to retain your personal information, we will delete or anonymise it.
You have the following rights, which you can exercise free of charge:
To be informed: The right to be informed about the collection and use of their personal data
Access: The right to be provided with a copy of your personal information (the right of access)
Rectification: The right to require us to correct any mistakes in your personal information
To be forgotten: The right to require us to delete your personal information – in certain situations
Restriction of processing: The right to require us to restrict processing of your personal information – in certain circumstances, e.g. if you contest the accuracy of the data
Data portability: The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party – in certain situations
To object: The right to object:
– at any time to your personal information being processed for direct marketing (including profiling);
– in certain other situations to our continued processing of your personal information, e.g. processing carried out for the purpose of our legitimate interests
Not to be subject to automated individual decision-making: The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you
For further information on each of those rights, including the circumstances in which they apply, please see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please:
– please contact us at firstname.lastname@example.org; and
– let us have enough information to identify you eg. your full name;
– let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
– let us know what right you want to exercise and the information to which your request relates.
Keeping your personal information secure
We have appropriate security measures to prevent personal information from being accidentally lost, or used or accessed unlawfully. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
How to complain
We hope that we can resolve any query or concern you may raise about our use of your information.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns or by telephone 0303 123 1113.
We may change this privacy notice from time to time – when we do we will post those changes on this page and make you aware via our website so you are always aware of what information we collect and how we use it.
If you have any questions regarding this notice or if you would like to speak to us about the manner in which we process your personal data, please contact our Data Protection Officer at email@example.com.
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