Quantuma Advisory Privacy Policy Notice (Rest of the World)

We may collect the following types of personal information about you:

• Contact details: information that allows us to identify and contact you directly such as your name, address email address, telephone number and addresses.
• Identification information: passport and other official identification details, information from a third party money laundering check provider, Companies House information, national insurance number, membership of relevant schemes.
• Details of your work history: This includes may include positions, roles, responsibilities, professional qualifications.
• Personal history and information: This includes hobbies, interests, marital status, family details and dietary requirements.
• Advisors appointed by you: including mortgage brokers, lawyers, financial advisors, surveyors;
• Business information: including property owned by you, transactions, amounts paid or owed and tenants.
• Responses to surveys, competitions and promotions: we keep records of any surveys you respond to or your entry into any competition or promotion we run.
• Creditworthiness: We may undertake investigations into your creditworthiness in order to establish whether to enter into or continue a business relationship with you 
• Details of your performance: when working with or for us or in relation to any project or work we are engaged in.
• How you use our website: we collect information about the pages you look at and how you use them, usernames and passwords.
• Videos, photographs and audio recordings: which you or other people take and provide to us or we take ourselves.
• Your usage of the IT systems we make available to visitors to our premises: for example our client internet and Wi-Fi facilities.
• Details of the correspondence (including e-mail correspondence) you send and receive from us and details of any claims: this includes letters and emails, SMS, MMS and other electronic communication and may in some cases include audio recording of telephone conversations.
• Subscription information: for example when you subscribe to one of our blogs or other materials.
• IP address information: your computer's IP address allows us to track your usage of our website.

If you are providing information regarding other individuals to us, it is your responsibility to ensure that you have the right to provide the information to us.
 

We do not generally collect, store and use the following “special categories” of more sensitive personal information regarding you:

• information about your race or ethnicity, religious beliefs, sexual orientation and political opinions;
• information about your trade union memberships;
• information about your health, including any medical condition, health and sickness records, medical records and health professional information; and
• biometric information about you, for example fingerprints, retina scans.

If we do collect any special category personal information, we do not currently rely on consent as a basis for processing special category personal information.

We will also not collect, store and use any criminal records information in relation to you.  If we do collect any criminal records information, we do not currently rely on consent as a basis for processing criminal records information.

Again if you are providing information regarding other individuals to us, it is your responsibility to ensure that you have the right to provide the information to us.

We will collect personal information from a number of sources. These may include the following:

• Directly from you: when you indicate that you may wish to attend an event, complete forms we provide to you, use our website, enter our competitions and promotions, make a claim, make a complaint, provide money laundering information to us contact us by phone, email or communicate with us directly in some other way.
• From referrals and recommendations: usually given by other people who know you or have a working relationship with you.
• Our website: provides us with information about how you use it and the devices that you use to connect to our website.
• Providers of information: which may include professional bodies or trade associations, credit reference agencies, money laundering check provider, Companies House, the Land Registry, LinkedIn and other web platforms.
• Journalists or other investigators: they may provide us with details or make enquires about you or matters concerning you or ourselves.
• Your employer or the organisation you work for: they may provide us with your name, position contact details and background information about you.
• Our professional advisors: such as lawyers, accountants, financial advisors, planning consultants, surveyors, consultants and other advisors. 
• Your professional advisors: such as lawyers, accountants, financial advisors, planning consultants, surveyors, consultants and other advisors.
• The Government, local authorities or relevant regulators: to assist with investigations, for example a data protection authorities (DPA), such as the Information Commissioner's Office (ICO), UK or applications to the local authority.

The table below describes the main purposes for which we process your personal information, the categories of your information involved and our lawful basis for being able to do this.  Which will apply will depend upon the nature of your relationship and interactions with us.

For some of your personal information you may have a legal, contractual or other requirement or obligation for you to provide us with your personal information.  If you do not provide us with the requested personal information we may not be able to properly perform our contract with you or the organisation you represent or comply with legal obligations and we may have to terminate our relationship.  For other personal information you may not be under an obligation to provide it to us, but if you do not provide it then we may not be able to properly perform our arrangements with you or the organisation you represent.

Where you have given us your consent to use your personal information in a particular manner, you have the right to withdraw this consent at any time, which you may do by contacting us as described in the “Contacting us” section below.  We will generally only ask for your consent for direct marketing.

Please note however that the withdrawal of your consent will not affect any use of the data made before you withdrew your consent and we may still be entitled to hold and process the relevant personal information to the extent that we are entitled to do so on bases other than your consent.  Withdrawing consent may also have the same effects as not providing the information in the first place, for example we may no longer be able to provide marketing information to you.

We may anonymise and aggregate any of the personal information we hold (so that it does not directly identify you).  We may use anonymised and aggregated information for purposes that include testing our IT systems, research, data analysis, improving our site and developing new products and services.

We may share personal information with the following parties:

• Organisations in the same group as us: in relation to joint events or joint work.
• Other companies in our supply chain: so that they can contact you about any issues in the supply chain or where your personal information is relevant to a subcontractor or party above us in the supply chain.
• Credit reference and other identification agencies: so that we can assess your creditworthiness and to verify your identity. These agencies may retain a footprint that a search has been undertaken.
• Third parties who ask for or want referrals: we may provide your details to a third party who is seeking services/products which are the same or similar to those that you provide.
• Marketing and public relations companies: to help us to develop, carry out and assess marketing and PR campaigns 
• Other service providers and advisors to us: such as companies that support our IT, help us analyse the data we hold, process payments, send communications to our customers, provide us with legal, property or financial advice and generally help us deliver our products and services to you or the organisation that you represent or for us to purchase them from you or the organisation you represent.
• Information providers: which may include credit reference agencies, money laundering check provider, Companies House, the Land Registry.
• Purchasers of our business: buyers or perspective buyers to whom we sell or negotiate to sell our business.
• The Government, local authorities, planning authorities or relevant regulators: where we are required to do so by law or to assist with their investigations, for example the Information Commissioner's Office.
• Police, law enforcement agencies and security services: to assist with the investigation and prevention of crime and the protection of national security.

We also use Google Analytics which sets cookies to collect information about how visitors use our website.  We use the information to compile reports and to help us improve the website. The cookies collect information in an anonymous form, including the number of visitors to the website and blog, where visitors have come to the website from and the pages they visited.  To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout.

We may provide third parties with aggregate statistical information and analytics about users of our products and services but we will make sure no one can be identified from this information before we disclose it.

We do not disclose personal information to anyone else except as set out above unless we have your consent or we are legally obliged to do so.  We do not sell your data.

Email, post and SMS marketing: from time to time, we may contact you by email, post or SMS with information about products or services we believe you may be interested in.

You can then let us know at any time that you do not wish to receive marketing messages by sending an email to us at marketing@quantuma.com or by using the by using the details set out in the “Contacting us” section below.  You can also unsubscribe from our marketing by clicking on the unsubscribe link in any marketing messages we send to you.

Our global presence means that your personal data may be transferred to and stored across the Quantuma Group in connection with the purposes described in this privacy statement. For example, when providing professional services to a client we may share personal information with Group firms in different jurisdictions that are involved in providing advice to that client. Some of these jurisdictions require different levels of protection in respect of personal information and, in certain instances, the laws in those countries may be less protective than the jurisdiction you are typically resident in. Transfers of personal data to another jurisdiction will be only:

• To a recipient in a country which provides an adequate level of protection for your personal protection; and/ or
• Under an agreement which satisfies the requirements of the UK GDPR and the EU GDPR for transfer of personal data to data processors or data controllers in another jurisdiction. 

We also use a number of suppliers and service providers in connection with the operation of our business who may have access to the personal information that we process, e.g. IT suppliers when providing us with software support, or cloud services. In all cases, your personal information is handled and protected in accordance with data protection law.  Where we use cloud services, our data will generally be hosted within the UK or EU, those being the locations which offer the highest level of data protection regulation of all the regions in which we operate. Where any personal data is processed by suppliers outside the EEA in countries that the UK and/or the EU have not assessed as providing an adequate level of protection, we ensure that personal data is adequately protected in accordance with applicable data protection law, and in particular Article 46 of the UK GDPR and the EU GDPR, by using the EU approved model contract clauses to cover the transfer or by ensuring that the supplier has Binding Corporate Rules in place.

If you require more details on the arrangements for any of the above then please contact us using the details in the “Contacting us” section below.
 

We will keep your personal information for as long as is necessary for the purpose for which it has been obtained and then for as long as there is any risk of a potential claim, which will be dependent upon the limitation period for the particular type of claim.  We have set out below the main retention periods which will apply:  

• For individual contacts at customers and suppliers this will be for as long as we continue to have a relationship with that customer or supplier and then for a period of 3 years afterwards.  
• For marketing contacts it will generally be a period of 2 years after we were last in contact with you.
• For website users it will generally be a period of 2 years after you used our website.
• For individuals seeking information, making complaints or otherwise corresponding with us it will generally be 6.5 years.
• For individuals attending an event it will generally be a period of 2 years after the event.

It is important to ensure that the personal information we hold about you is accurate and up-to-date, and you should let us know if anything changes, for example if you move position or work for a different organisation or change your phone number or email address. you can contact us by using the details set out in the “Contacting us” section below.

We have numerous security measures in place to protect the loss, misuse and alteration of information under our control, such as passwords and firewalls. We cannot, however, guarantee that these measures are, or will remain, adequate. We do, however, take data security very seriously and will use all reasonable endeavours to protect the integrity and security of the personal information we collect about you.

You have the following rights in relation to your personal information: 

• the right to be informed about how your personal information is being used;
• the right to access the personal information we hold about you; 
• the right to request the correction of inaccurate personal information we hold about you; 
• the right to request the erasure of your personal information in certain limited circumstances;
• the right to restrict processing of your personal information where certain requirements are met; 
• the right to object to the processing of your personal information;
• the right to request that we transfer elements of your data either to you or another service provider; and
• the right to object to certain automated decision making processes using your personal information. 

You should note that some of these rights, for example the right to require us to transfer your data to another service provider or the right to object to automated decision making, may not apply as they have specific requirements and exemptions which apply to them and they may not apply to personal information recorded and stored by us.  For example we do not use automated decision making in relation to your personal data.  However some have no conditions attached, so your right to withdraw consent or object to processing for direct marketing are absolute rights.

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
Whilst this privacy notice sets out a general summary of your legal rights in respect of personal information, this is a very complex area of law. More information about your legal rights can be found on the website of the DPA in your jurisdiction, the details of which can be found in “Client Facing Entities in the Quantuma Group”.

To exercise any of the above rights, or if you have any questions relating to your rights, please contact us by using the details set out in the "Contacting us" section below.

If you are unhappy with the way we are using your personal information you can also lodge a complaint with a DPA, usually in the country or state where you work, normally live or where any alleged infringement of data protection laws has occurred. Details of the DPAs where the Quantuma Group has offices can be found in “Client Facing Entities in the Quantuma Group".

We sometimes provide you with links to other websites, but these websites are not under our control. We are not liable to you for any issues arising in connection with their use of your information, the website content or the services offered to you by those websites.

We recommend that you check the privacy policy and terms and conditions on each website to see how each third party will process your information.

We may update this privacy notice from time to time. When we change this notice in a material way, we will update the version date at the bottom of this notice. For significant changes to this notice we will try to give you reasonable notice unless we are prevented from doing so. Where required by law we will seek your consent to changes in the way we use your personal information.

In the event of any query or complaint in connection with the information we hold about you, please email dataprotection@quantuma.com or you may write to us using the postal addresses in “Client Facing Entities in the Quantuma Group”.