NexantECA Ltd. Privacy Policy

Last Updated: October 2022

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint.

Key Terms

Some key terms used in this policy are:

We, us, our

NexantECA Limited and its affiliates

Personal information

Any information relating to an identified or identifiable individual

Special category personal information

Personal information revealing special categories of personal information such as racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership

 

Personal Information we collect about you

We may collect and use the following personal information about you:

  • your name and contact information, including email address, job title, telephone number and company details
  • Information to enable us to check and verify your identity, eg your date of birth
  • your gender information, if you choose to give this to us
  • your billing information, transaction and payment card information
  • your professional online presence, eg LinkedIn profile
  • your contact history and purchase history
  • information to enable us to undertake credit or other financial checks on you
  • Information about how you use our website, IT, communication and other systems

This personal information is required to provide products and/or services to you. If you do not provide personal information we ask for, it may delay or prevent us from providing products and/or services to you.

How your personal information is collected

We collect most of this personal information directly from you—in person, by telephone, text or email and/or via our website. However, we may also collect information:

  • from publicly accessible sources, eg Companies House or HM Land Registry;
  • directly from a third party, eg: sanctions screening providers; customer due diligence providers
  • from a third party with your consent
  • from cookies on our website—for more information on our use of cookies, please see our cookie policy

How and why we use your personal information

Under applicable data protection law, we can only use your personal information if we have a proper reason for doing, for example:

  • 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 table below explains what we use (process) your personal information for and our reasons for doing so:

What we use your personal information for

Our reasons

To provide products and/or services to you

For the performance of our contract with you or to take steps at your request before entering into a contract

To prevent and detect fraud

For our legitimate interests or those of a third party, ie to minimise fraud that could be damaging for us and for you

Conducting checks to identify our customers and verify their identity

Screening for financial and other sanctions or embargoes

To comply with our legal and regulatory obligations

Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies

To comply with our legal and regulatory obligations

Ensuring business policies are adhered to, eg policies covering security and internet use

For our legitimate interests or those of a third party, ie to make sure we are following our own internal procedures so we can deliver the best service to you

Operational reasons, such as improving efficiency, training and quality control

For our legitimate interests or those of a third party, ie to be as efficient as we can so we can deliver the best service for you at the best price

Ensuring the confidentiality of commercially sensitive information

For our legitimate interests or those of a third party, ie to protect trade secrets and other commercially valuable information

To comply with our legal and regulatory obligations

Statistical analysis to help us manage our business

For our legitimate interests or those of a third party, ie to be as efficient as we can so we can deliver the best service for you at the best price

Preventing unauthorised access and modifications to systems

For our legitimate interests or those of a third party, ie to prevent and detect criminal activity that could be damaging for us and for you

To comply with our legal and regulatory obligations

Updating customer records

For the performance of our contract with you or to take steps at your request before entering into a contract

To comply with our legal and regulatory obligations

For our legitimate interests or those of a third party, eg making sure that we can keep in touch with our customers about existing orders and new products

Statutory returns

To comply with our legal and regulatory obligations

Ensuring safe working practices, staff administration and assessments

To comply with our legal and regulatory obligations

For our legitimate interests or those of a third party, eg to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you

Marketing our services to:

—existing and former customers;

—third parties who have previously expressed an interest in our services;

—third parties with whom we have had no previous dealings.

For our legitimate interests or those of a third party, ie to promote our business to existing and former customers

Credit reference checks via external credit reference agencies

For our legitimate interests or those of a third party, ie to ensure our customers are likely to be able to pay for our products and services

Downloading of subscription reports

For our legitimate interests to verify the downloading of by clients  of NexantECA subscription reports

 

The above table does not apply to special category personal information, which we will only process with your explicit consent.

Promotional communications

We may use your personal information to send you updates (by email, text message, telephone or post) about our products and/or 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 or share it with other organisations for marketing purposes.

You have the right to opt out of receiving promotional communications at any time by:

We may ask you to confirm or update your marketing preferences if you instruct us to provide further products and/or 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 routinely share personal information with:

  • companies within the NexantECA group;
  • our website administrator, Chapter 3;
  • third party partners, HubSpot, Workable;
  • third parties approved by you, eg social media sites you choose to link your account to or third party payment; providers;
  • credit reference agencies;
  • our insurers;
  • our banks.

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 relating 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 may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

Where your personal information is held

Information may be held at our offices and those of our group companies, third party agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal information with’).

Some of these third parties may be based outside the UK. For more information, including on how we safeguard your personal information when this occurs, see below: ‘Transferring your personal information out of the UK'.

How long your personal information will be kept

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting 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.

By law we have to keep basic information about our clients for six years after they cease being clients for tax purposes. In some cases, we hold on to client related data until the statutory limitation period for bringing claims has passed.

In some circumstances we may 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.

Transferring your personal information out of the UK

We may share your personal data within the NexantECA Group. This will involve transferring your data outside the UK.

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

Whenever we transfer your personal data out of the UK, 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.
  • Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK (see ‘How to contact us’ below).

Your rights

You have the following rights, which you can exercise free of charge:

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, eg 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, eg 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 contact us or 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:

  • email, call or write to us —see below: ‘How to contact us’; and
  • let us have enough information to identify you;
  • 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.

If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

How to complain

We hope that we can resolve any query or concern you may raise about our use of your information.

For your information, the supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns or telephone: +44 (0)303 123 1113.

Changes to this privacy policy

We may change this privacy notice from time to time—when we do we will inform you via a notice on our website or by email.

How to contact us

Please contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you.

Our contact details are shown below:

Our Contact Details

Address: 110 Cannon Street, London EC4N 6EU

Email address: ContactUs@NexantECA.com

Phone number: +44 (0)20 7950 1600