Last updated: 23 December 2022
© 2022 AlphaSights Ltd. All Rights Reserved.
It also describes your data protection rights, including a right to object to some of the processing which we carry out or where we rely on your consent, a right to withdraw this consent. More information about your rights, and how to exercise them, is set out in the “Your Legal Rights” section below.
Our website(s) are not intended for children and we do not knowingly collect data relating to children.
1. IMPORTANT INFORMATION AND WHO WE ARE
AlphaSights Ltd. is the controller and responsible for all personal data we collect through our various online and offline channels.
Our website(s) may include links to or functionality from 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. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
2. THE DATA WE MAY COLLECT ABOUT YOU
“Personal Data” means any personally identifiable information belonging to an identifiable natural person, including but not limited to, an identifier such as a name, an identification number, location data, an online identifier or factors specific to the physical, economic, cultural or social identity of that natural person.
We may collect, create, use, store and otherwise process the following different kinds of personal data (as applicable) about you which we have grouped together as follows:
We aggregate your Usage Data with the information of other website visitors, advisors and clients, creating a dataset of information about the usage of our online channels, our apps, products and services, and other general, grouped information about our user base. Although this dataset is aggregated and anonymised, meaning it cannot directly identify you as an individual, it provides a valuable insight into the use of our services and we will share it with select third parties.
In certain situations we may need to process, or ask third parties to process on our behalf, your special category personal data. Special category personal data means information that can reveal your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership as well as genetic or biometric data (if used to uniquely identify that person) and information concerning a person’s health, sex life, or sexual orientation.
From time to time we may ask you to confirm the accuracy of the personal data we process about you.
IF YOU FAIL TO PROVIDE PERSONAL DATA
You do not have to provide personal data to access our website(s) and online channels. However, we may have a legal obligation to collect and process your personal data, or we may require your personal data in order to provide you with specific products and services.
If you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you and/or the quality of the products and services we provide to you might be affected. In these circumstances, we may cancel a service you receive from us or stop proceeding with a contract we are trying to enter into with you, but we will notify you if this is the case at the time. Please note that this does not apply to the collection of:
You may however choose whether or not to receive marketing communications from us and we will only send you such communications in line with your communication preferences. For more information on your rights, please see below.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
Your personal data may be combined from these different sources for the purposes outlined below.
4. WHY WE PROCESS YOUR PERSONAL DATA
We rely on the following legal grounds to process your personal data for the following purposes:
5. SPECIAL CATEGORY DATA
Where we need to process special category data, data protection laws require us to have a second lawful basis. This includes:
6. RELYING ON OUR LEGITIMATE INTERESTS
We have carried out the balancing tests for all the data processing we carry out on the basis of our legitimate interests, which we have described above. You can obtain information on any of our balancing tests by contacting us using the details below.
7. OPTING OUT
You have an absolute right to opt out of direct marketing, or profiling we carry out for direct marketing, at any time. You can do this by following the instructions in the communication or by contacting us at the details below.
8. COOKIES AND RELATED TECHNOLOGIES
We also use other forms of technology such as web beacons and embedded scripts which serve a similar purpose to cookies and which allow us to monitor and improve our sites and online services. We use these in connection with cookies to help operate our websites and emails and collect information about online activity. When we talk about cookies in this Privacy & Cookies Notice, this term includes these similar technologies.
For more information on targeted advertising including which third parties place these cookies and to learn how to opt out of them, visit our Cookie Consent Tool.
How Can You Manage Cookies?
Session cookies are used for your current browser session and will expire shortly after you close your browser (subject to compliance requirements). Persistent cookies are used to enhance your experience between website visits and will remain on your computer until you delete them or until they expire. You always have the ability to manually delete cookies.
You can change your cookie preferences and withdraw your consent at any time using our Cookie Consent Tool .
You may also set your browser to block all cookies or to indicate when a cookie is being set, although our services may not function properly if your cookies are disabled. To find out how to control or disable cookies within most browsers, consult the “Help” section of your browser or device or visit www.allaboutcookies.org.
9. DISCLOSURES OF YOUR PERSONAL DATA
We will share your personal data with the third parties listed below for the purposes that are described in this Privacy & Cookies Policy or otherwise with your consent.
Service Providers: When we employ a third-party to perform a function on our behalf, we provide it with the personal data that it needs to perform its specific function. These companies are authorized to use your personal data only as necessary to provide these services to us. We use service providers for the purposes of delivering our products and services, managing your accounts, hosting, IT, security, support, billing, surveys, facilitating and recording conference calls, business development, marketing, identity verification services and communications. We also share personal data with our accountants, auditors, lawyers and other outside professional advisors to AlphaSights, subject to binding contractual obligations of confidentiality.
Clients: We share Identity Data, Contact Data, Due Diligence Data, Profile Data & Transaction Data relating to advisors with our clients in connection with a particular project as further described in our Compliance Due Diligence Packs and Terms of Service and Terms of Engagement.
Advisors: We share Identity Data relating to our clients with our advisors in connection with a particular project as further described in our Compliance Due Diligence Packs and Terms of Service.
Legal Requirements : We disclose personal data to government authorities, regulators or other third-parties if required to do so by law or in the good faith belief that such action is necessary to (a) comply with a subpoena, court order or similar legal obligation, (b) protect and defend our rights or property, (c) act in urgent circumstances to protect the personal safety of users of any website or the public, (d) protect against legal liability, (e) to investigate fraud or other unlawful activity or (f) or as otherwise required or permitted by law.
Business Transfers: As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, including in bankruptcy, your personal data may be part of the transferred assets. You will be notified via email and/or a prominent notice on our websites of any change in ownership or uses of your personal data, as well as any choices you may have regarding your personal data.
Third-Party Partners: We may share your personal data with selected third-party partners, including for their direct marketing purposes. We will obtain your prior consent for such a transfer where required by applicable law. We reserve the right to transfer and/or sell aggregate or group data about our users for lawful purposes.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law.
10. INTERNATIONAL TRANSFERS
Your personal data will be processed in or accessed from jurisdictions outside of the UK and the European Economic Area (EEA) by members of our group including in the US, Hong Kong, Dubai, China, Japan and South Korea for the purposes outlined above.
We will also transfer your personal data for these purposes to external third parties as highlighted in Section 8 outside of the UK and the EEA including in the US.
When we transfer your personal data outside of the UK or the EEA, we require that appropriate safeguards are in place in accordance with data protection laws.
When we transfer your personal data within our group, we make use of standard contractual data protection clauses or international data transfer agreements, which have been approved by the European Commission and the ICO.
For transfers of personal data to third parties outside the EEA (including the UK), we will ensure that at least one of the following safeguards apply:
For further information, including to obtain a copy of the documents used to protect your information, please contact us as described below.
11. DATA SECURITY
We have put in place appropriate 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 should only process your personal data on our instructions and be subject to a duty of confidentiality. We have also 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.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your personal data transmitted to our website; any transmission is at your own risk.
12. DATA RETENTION
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
We will only retain your personal data for as long as we believe necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, reporting or audit requirements. 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 requirements.
Details of retention periods for different aspects of your personal data are available by contacting us using the details below.
13. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include rights:
To request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
To request correction of the personal data that we hold about you This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
To request erasure of your personal data This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
To object to processing of your personal data. This is where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
To request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
To request the transfer of your personal data to you or to a third party We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
To withdraw consent This occurs at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
All these rights may be limited. Relevant exemptions are included in the GDPR, the Data Protection Act 2018, the California Consumer Privacy Act (the “CCPA”), and the Personal Information Protection Law of the People’s Republic of China. We will inform you of any relevant exemptions we rely upon when responding to any request you make.
If you wish to exercise any of the rights set out above, please see below details for how contact us.
14. 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 can refuse to comply with your request in these circumstances.
15. 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.
16. TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally it may 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. If you have any unresolved concerns, 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 so please contact us in the first instance.
17. HOW DO YOU GET IN TOUCH WITH US?
We hope we can satisfy any queries you may have about the way we process your personal data. If you have any concerns or would like to exercise any of your rights, please contact our Data Protection Officer by email at [email protected] or you can reach us at AlphaSights Ltd, Thames Court, 1 Queenhithe, London, EC4V 3DX, United Kingdom. If you are a California resident, you may contact us by email at [email protected] or at +1 (888) 369-1693 regarding your rights under the CCPA. Contact details for our other offices are available on our website.