29 February 2019
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 COLLECT ABOUT YOU
Personal data means any information which relates to an identified or identifiable living individual.
We collect, create, use, store and otherwise process the following different kinds of personal data about you which we have grouped together as follows:
· Identity Data, including first name, maiden name, last name, username or similar identifier, title, and gender.
· Due Diligence Data, including data you make publicly available (e.g. via social media and networking platforms) (where required to meet specific anti money laundering, counter terrorism financing and anti-bribery legislation or other regulatory requirements or where needed to research, filter and verify advisors or to screen for potential conflicts of interest). This is necessary to identify any adverse media or other legal or reputational concerns such as bankruptcy, political affiliations or criminal convictions or investigations.
· Contact Data, including your address(es), email address(es) and telephone number(s).
· Financial Data (if we pay you anything), including bank account details.
· Transaction Data, including interactions you may have had with us (e.g. parties entering and exiting our conference bridge, duration and time of interactions) and any advisor/client feedback.
· Profile Data, including your CV, professional background, languages spoken, location and country of residence, relevant qualifications, career history and moves and additional information provided through AlphaSights’ processes.
· Marketing and Communications Data, including your preferences in receiving marketing from us and third parties and your communication preferences.
· Technical Data, including 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 website(s) and online services.
· Usage Data, including information about how you use our website, social media pages, apps, products and services, including the URL clickstream to, through and from our online channels (including date and time); products you viewed or searched for, the content (and any ads) that you view or interact with, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs or acceptance of our Terms of Engagement), and methods used to browse away from the page.
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.
From time to time we will 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 but 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 the contract we have or are trying to enter into with you. In this case, we may cancel a service you receive from us, but we will notify you if this is the case at the time.
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:
- Direct interactions . You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email, surveys or otherwise.
- Automated technologies . As you interact with our online channels, we automatically collect Technical Data and Usage Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. See Section 7 for more detail.
- Third parties or publicly available sources . We receive personal data about you from various third parties and public sources such as Technical Data from analytics, technology and hosting providers, Identity, Contact, Profile and Due Diligence Data from business networks (e.g. Linkedin), media searches, background check providers, data brokers or aggregators and from commercially or publicly availably sources. Any searches we perform on clients and advisors will be proportionate to the purposes outlined below.
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:
- Where we need to perform a contract we are about to enter into or have entered into with you . This includes:
- verifying your identity;
- taking payments;
· provision of our products and services and sending you service-related communications;
· provision of client support including responding to your queries and investigating any complaints about the site and our products and services.
- 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. This includes:
· to administer our sites, conduct identity verification and other fraud detection activities;
· to research, filter, verify, train and monitor advisors and to screen for potential conflicts of interest in order to assess and recommend their appropriateness for a particular client engagement and to meet applicable legal, regulatory and compliance requirements;
· to monitor, maintain, develop and improve the performance of our sites, products and services and customer relationships, analyze trends, usage and activities in connection with our products and services, and optimize our marketing efforts and measure the effectiveness of our advertising campaigns and to grow and inform our marketing strategy;
· for our own internal functions such as keeping our sites secure, (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data), management and corporate reporting, internal research and analytics and to improve business efficacies;
· to enforce compliance with our terms and other policies or otherwise in connection with legal claims, compliance, regulatory, auditing, investigatory and disciplinary purposes as necessary (including disclosure of such information in connection with legal process or litigation);
· to create aggregate and statistical data (which cannot be used to identify you). For example, aggregate data may include data that describes the general demographics, usage or other characteristics of a site's users. We reserve the right to transfer and/or sell aggregate or group data about our users for lawful purposes.
- Where we need to comply with a legal or regulatory obligation. This includes:
· in response to requests by government or law enforcement authorities conducting an investigation.
- When you have expressly consented to us processing your personal data. This includes:
· where you ask us to send marketing information via a medium where we need your consent under applicable law (for example email marketing in some countries). For more information about how to modify your preferences about marketing communications, please see below and Section 6 and 12;
· where you give us consent to place cookies or similar technologies;
· on other occasions where we ask for your consent, for the purpose we explain at the time
Where consent is relied on, you have the right to withdraw it at any time by contacting us.
- Where you have manifestly made the personal data public.
- Where the processing is necessary in the reasons of substantial public interest as defined in the UK Data Protection Act 2018.
5. 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.
6. 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.
7. 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.
- To provide you with the service you have requested. We use these cookies to enable you to move around our sites and to use their features - for example, to provide a secure login. Because these cookies are essential to operate the websites and our products and services, there is no option to opt out of these cookies.
- To provide you with a better browsing experience based on the choices you make. We use these cookies to remember choices you make such as the country you visit our website from, language and search parameters. These can then be used to provide you with an experience more appropriate to your selections and to make the visits more tailored and pleasant. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites.
- To analyze and improve your browsing experience. We use these cookies to analyse site usage so we can measure and improve performance - for example, to make sure the website looks consistent, to gather statistics about its use and to know if you use certain functionality.
- To allow you to share information on social media. They are used when you share information using a social media sharing button or "like" button on our sites or apps, or when you engage with our content on or through a social site such as Facebook or Twitter.
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 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 .
8. 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, 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 require all third parties to respect the security of your personal data and to treat it in accordance with the law.
9. 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, 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:
· there is a decision by the European Commission or other applicable data protection law that the country to which the data is transferred provides an adequate level of data protection (including to US organisations which participate in the EU/UK-US Privacy Shield)
· in absence of such decision, our contracts with the relevant third parties include approved standard contractual data protection clauses approved by the European Commission and the UK Information Commissioner's Office;
· the third party has implemented Binding Corporate Rules; or
For further information, including to obtain a copy of the documents used to protect your information, please contact us as described below.
10. 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.
11. 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.
12. 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 both the GDPR and the Data Protection Act 2018. 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.
13. 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.
14. 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.
15. 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.
16. 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 get in touch at Legal@alphasights.com or you can reach us at AlphaSights Ltd, Thames Court, 1 Queenhithe, London, EC4V 3DX, United Kingdom Contact details for our other offices are available on our website.