Data Protection and Privacy Policy

 

INTRODUCTION

 

Welcome to Conflict Intelligence (“CI”) privacy notice.

CI respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from), or when you use our services and tell you about your privacy rights and how the law protects you.

 

This privacy notice deals with the specific areas set out below. Please use the glossary below to understand the meaning of some of the terms used in this privacy notice:

 

  • IMPORTANT INFORMATION AND WHO WE ARE
  • THE DATA WE COLLECT ABOUT YOU
  • HOW IS YOUR PERSONAL DATA COLLECTED
  • HOW WE USE YOUR PERSONAL DATA
  • DISCLOSURES OF YOUR PERSONAL DATA
  • INTERNATIONAL TRANSFERS
  • DATA SECURITY
  • DATA RETENTION
  • YOUR LEGAL RIGHTS
  • GLOSSARY
  • COOKIE POLICY

IMPORTANT INFORMATION AND WHO WE ARE

PURPOSE OF THIS PRIVACY NOTICE

 

This privacy notice aims to give you information on how CI collects and processes your personal data through your use of this website and in the course of its business. It tells you the specific ways we use and disclose that information. We take your privacy extremely seriously and never sell your data or pass it on to any third party for sales or marketing use. This privacy policy is effective with respect any data that we have collected, collect about and/or from you according to our terms and conditions of business

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

 

CI takes privacy seriously and we are committed to protecting it.

This policy explains when and why we collect personal information about you, how this information is used, the conditions under which it may be disclosed to others and how it is kept secure.

This is our main privacy policy. We may provide additional, specific privacy information to you as you interact with us in different ways (e.g. that we will only use certain information for specific purposes). To the extent that any of that information differs from what we say below, those specific statements will apply in those circumstances.

This policy may change from time to time so please check this page occasionally to ensure that you’re happy with any changes.

 

This policy was last updated on 23 May 2018

 

CONTROLLER

CI is the controller and responsible for your personal data (collectively referred to as “CI”, “we”, “us”, or “our” in this privacy notice.).

 

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

 

CONTACT DETAILS

Our full details are:

Full name of legal entity: Conflict Intelligence

Name and title of DPO: Gavin Emerson

Email address: info@conflictintelligence.co.uk

 

CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES

This version was last updated on 23 May 2018..

The data protection law in the UK will change on 25th May 2018.

 

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

 

THIRD-PARTY LINKS

This website may include links to 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.

 

THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed.

Through your use of this website, we may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Technical Data includes internet protocol (IP) address, your 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 this website.

Usage Data includes information about how you use our website.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

 

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

 

When you use our website, our services, interact with us online, or by phone, email or otherwise, the categories of information that we collect about you are as follows:

Personal information you give to us through engaging in correspondence with us by phone, email or otherwise.

The basic personal information we may ask for, or you may choose to give us, includes your name, your address, email address and phone number. We may retain details of any enquiry you make to us and records of any correspondence with us. We may also ask for, or you may choose to give us, other information for specific purposes in order to carry out your instructions.

We will seek to minimise the information we ask for to that which is needed to perform the relevant function or service at the time but always required for your retainer.

 

Personal information we collect about you:

We automatically collect the following information when you interact with us: e.g. details of transactions you carry out through the site, and your visits to our site, including, but not limited to, traffic data, location data, weblogs and other communication data, and the resources you access.

We also automatically collect technical information, including anonymous data collected by the hosting server for statistical purposes, the Internet protocol (IP) address used to connect your computer or device to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform. Please see our cookie policy for further information.

Personal information we may receive from other sources:

We obtain certain personal information about our clients from third parties such as the court, Cafcass, police and social services but again always pursuit your representation and instructions.

 

IF YOU FAIL TO PROVIDE PERSONAL DATA

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 (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

 

HOW IS YOUR PERSONAL DATA COLLECTED

We use different methods to collect data from and about you including through:

Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy below for further details

 

Third parties or publicly available sources. We may receive Technical Data from analytics providers such as Google based outside the EU.

 

Usage Data includes information about how you use our website.

 

We also will collect your personal information when you consult with us send us an email, communicate with us in any way which represents a voluntarily giving by you of information for the purposes of the contract. That information may include you or your contact name, physical address, email address, IP address, phone number as well as details including occupation, location, history and other demographic information. By giving us this information you agree to this information being collected, used, disclosed and transfer within the UK or outside the UK if your case requires it. You also agree to this information being stored by us as described in our terms conditions, cookie policy and this privacy policy.

 

HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your data (a) 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, and (b) where we need to comply with a legal or regulatory obligation. We process your personal data primarily on the basis of legitimate interest as a business but only if necessary for purpose we collect it for.

 

We will also process data on the basis of contractual and transactional obligation when necessary. In particular, we may process your data in order to make calls, emails and other types of communications to you and third parties in connection with your case. It will also be used in relation to account activity such as email, written and verbal communications and agreements and financial activities such as billing communications but most importantly to perform obligations under contract with you or third parties where necessary to pursue that contract.

 

 

COOKIES

 

Like many other websites, our website uses cookies (including Google Analytics cookies) to obtain an overall view of visitor habits and visitor volumes to our website. ‘Cookies’ are small pieces of information sent to your computer or device and stored on its hard drive to allow our websites to recognise you when you visit.

It is possible to switch off cookies by setting your browser preferences.

 

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about cookies we use, please see our cookie policy below.

 

 

CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

 

DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below for the purposes set out at paragraph 4 above:

  1. External Third Parties as set out in the glossary.
  2. Third Parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

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.

We may disclose your information to our third party service providers, agents, subcontractors and other organisations for the purposes of providing services to us or directly to you on our behalf.

Such third parties may include cloud service providers; hosting, email and content providers; marketing agencies and administrative services providers; assessors for our accreditations; payment processing companies and research companies (who may contact you to gather information relating to your experience of us and our products and services or on topical, policy and strategic issues facing the profession).

When we use third party service providers, we only disclose to them any personal information that is necessary for them to provide their service and we have a contract in place that requires them to keep your information secure and not to use it other than in accordance with our specific instructions.

 

We may share personal information with third parties in order to facilitate your instructions to act on your behalf. ; we may share your contact details with third parties for marketing purposes if you have given consent for this and we may share your details with third parties if this is necessary to fulfil a contract with you. We may transfer your personal information to a third party if we’re under a duty to disclose or share it in order to comply with any legal obligation, to detect or report a crime, to enforce or apply the terms of our contracts or our legal rights or to protect the rights, property or safety of our visitors and customers. We will always take steps with the aim of ensuring that your privacy rights continue to be protected.

 

INTERNATIONAL TRANSFERS

We do not transfer your personal data outside the European Economic Area (EEA).

 

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 and need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

 

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your information transmitted to our website and any transmission is at your own risk. Once we have received your personal information, we put in place reasonable and appropriate controls to ensure that it remains secure against accidental or unlawful destruction, loss, alteration, or unauthorised access.

Where we have given (or where you have chosen) a password which enables you to access an account, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Our website may contain links to other websites run by other organisations. This policy does not apply to those other websites so we encourage you to read their privacy statements. We cannot be responsible for the privacy policies and practices of other websites even if you access them using links that we provide. In addition, if you linked to our website from a third party website, we cannot be responsible for the privacy policies and practices of the owners and operators of that third party website and recommend that you check the policy of that third party website.

 

We have 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.

 

 

DATA RETENTION

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

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.

 

YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under the data protection laws in relation to your personal data. Your rights are listed below, and more detail can be found in the glossary below:

  • Request access to your personal data.
  • Request correction of your personal data.
  • Request erasure of your personal data.
  • Object to processing of your personal data.
  • Request restriction of processing your personal data.
  • Request transfer of your personal data.
  • Right to withdraw consent. Except in rare cases where additional time may be required, we will respond to you within one month from either (i) the date that we have confirmed your identity, or (ii) where we do not need to do this because we already have this information, from the date we received your request. Under data protection laws you have a legal right to ask to see a copy of the personal information that we hold about you. Such requests are called subject access requests. You will also need to provide one form of identification and proof of your address, for example, staff pass, driving licence, utility bill, and if appropriate, any particulars about the source or location of the information you are requesting. Further information about subject access requests can be found on the Information Commissioner’s website //ico.org.uk The accuracy of your information is important to us and we are working on ways to make it easier for you to review and correct the information that we hold about you. Where we rely on your consent as the legal basis for processing your personal information, as set out under section 4 on how we use your personal information, you may withdraw your consent at any time by contacting us. If you have provided consent for your details to be shared with a third party, and wish to withdraw this consent, please also contact the relevant third party in order to amend your preferences.

 

Objecting to our use of your personal information and automated decisions made about you –You may object to us using your personal information for direct marketing purposes and we will automatically comply with your request. If you would like to do so, please email or write to us at the above address

Erasing your personal information or restricting its processing. You may also ask us to restrict processing your personal information where you believe it is unlawful for us to do so, you have objected to its use and our investigation is pending or you require us to keep it in connection with legal proceedings. In these situations we may only process your personal information whilst its processing is restricted if we have your consent or are legally permitted to do so, for example for storage purposes, to protect the rights of another individual or company or in connection with legal proceedings.

NO FEE USUALLY REQUIRED 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.

 

TIME LIMIT TO RESPOND

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 may refuse to comply with your request in these circumstances.

 

Withdraw consent 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 services to you. We will advise you if this is the case at the time you withdraw your consent.

 

GLOSSARY

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted by law). You can obtain further information about how we assess our legitimate interests against any particular impact on you in respect of specific activities by contacting us.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

 

EXTERNAL THIRD PARTIES

Service providers acting as processors based in the UK who provide IT and system administration services.

Professional advisers acting as processors including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.

HM Revenue and Customs, regulators and other authorities acting as processors based in the UK who require reporting of processing activities in certain circumstances.

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.

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.

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 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.Withdraw consent 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 services to you. We will advise you if this is the case at the time you withdraw your consent.

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 information to perform a contract with you.

Object to processing of your personal data 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. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request correction of the 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.

YOUR LEGAL RIGHTS

 

COOKIE POLICY

Like many websites, the ES website uses cookies – small text files, typically of letters and numbers – to capture limited information about the site’s users. The information is transferred by the website to the cookie file of the browser on the hard drive of the user’s computer.

This site uses Google Analytics cookies. These allow us to measure the number of visitors, to see how visitors navigate the site and to see which resources they access. This helps us to develop new content and to improve the way the website works. These cookies do not enable us to identify individual users. Google provides further information about Analytics.

To prevent Google Analytics cookies being set, you may install the Google Analytics Opt-Out Browser Add-On.

For general information about cookies please visit www.allaboutcookies.org.