Last Updated: 22/11/2022
1.1. www.quintelintelligence.com (Website) is a site operated by Quintel Intelligence Ltd trading as Quintel Intelligence is a company registered in England and Wales (Company Number 07926115) registered office at Tintagel House, 92 Albert Embankment, London, England, SE1 7TY(the Company, us, we, our).
1.2. The Company obtains, keeps and uses information about you for a number of specific lawful purposes. The Company is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. The Company is registered with ICO. Our registration number is ZA016162.
1.3. We take the security and privacy of data seriously and are committed to complying with our legal obligations under the Data Protection Act 2018 (the ‘2018 Act’) and the UK GDPR in respect of data privacy and security. We respect your personal data, and our use of your personal data is subject to the relevant UK and EU legislation.
2. Scope and purpose
2.1. This privacy notice aims to give you information on how the Company collects and processes your personal information including any data you may provide through this Website when you:
2.1.1. sign up to our newsletter;
2.1.3. enquire about our products and services (through website, in person, by email, post and telephone);
2.1.4. when you purchase one or more of our products or services;
2.1.5. when we process data about you as a result of the instructions that we receive from our client.
2.2. It is important that you read this Privacy Notice together with any other privacy notices we may provide on specific occasions. This Privacy Notice supplements the other notices and is not intended to override them. We are required to notify you of this information under the data protection legislation.
2.4. This policy applies to all data, whether it is stored electronically, on paper in a filing system or on other materials.
3. Changes to this policy
3.1. We will review and update this notice regularly in accordance with our data protection or regulatory obligations. We will circulate any new or modified policies or notices in relation to your data when it is adopted. It is important that you read and understand this notice before you share with us any personal data.
4. Data protection principles
4.1. When processing your data, the Company will comply with the following data protection principles:
4.1.1. we will process personal information lawfully, fairly and in a transparent manner.
4.1.2. we will collect personal information for specified, explicit and legitimate purposes only, and will not process it in a way that is incompatible with those legitimate purposes.
4.1.3. we will only process the personal information that is adequate, relevant and necessary for the relevant purposes.
4.1.4. we will keep accurate and up to date personal information and take reasonable steps to ensure that inaccurate personal information is deleted or corrected without delay.
4.1.5. we will keep personal information in a form which permits identification of data subjects (you) for no longer than is necessary for the purposes for which the information is processed.
4.1.6. we will take appropriate technical and organisational measures to ensure that personal information is kept secure and protected against unauthorised or unlawful processing, and against accidental loss, destruction or damage.
5. How we define data processing
5.1. The Company will process your personal data (including special categories of personal data and criminal offense data) in accordance with legal obligations.
5.2. ‘Processing’ means any operation which is performed on personal data such as collection, recording, organisation, structuring, storage, adaption, alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment, combination, restriction, destruction or erasure.
5.3. This includes processing personal data which forms part of a filing system and any automated processing.
6. What data (information) we collect
6.1. The Company processes information about you ‘data subject’ for a number of specific lawful purposes and we seek to ensure that our data collection and processing is always proportionate.
6.2. The Company processes information about you ‘data subject’ for a number of specific lawful purposes and we seek to ensure that our data collection and processing is always proportionate. Given the nature of our business we may collect Personal Data, Special Categories of Data and Criminal Conviction Data.
6.3. ‘Personal data’ is information which relates to a living person who can be identified from that data (data subject) on its own, or when taken together with other information which is likely to come into our possession. It includes any expression of opinion about the person and an indication of the intentions of us or others, in respect of that person. It does not include anonymised data.
6.4. ‘Special Categories of Personal Data’ is sometimes referred to as ‘sensitive personal data’ or ‘sensitive information’ and it includes information about your race, ethnic origin, politics, religious and philosophical beliefs, trade union membership, genetics, biometrics (where used for ID purposes), health, sex life or sexual orientation.
6.5. ‘Criminal Conviction Data’ is data relating to criminal convictions and offences, including data relating to criminal allegations, investigations and proceedings, information about penalties conditions or restrictions placed on an individual as part of the criminal justice process, civil measures which may lead to a criminal penalty if not adhered to. Criminal Conviction Data includes information relating to the absence of convictions.
7. Third Party Links
7.1. Our 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.
8. Categories of Data
8.1. We have grouped data into the following categories:
8.1.1. Identity Data which includes first name, maiden name, last name, marital status, title, date of birth, gender, national insurance number and any other information by which you can be identified.
8.1.2. Contact Datawhich includes addresses, email addresses and telephone numbers.
8.1.3. Transactional Data includes information in respect of records of fees agreed, fees charged, refunds issued and/or due and charges paid and/or outstanding.
8.1.4. Background Dataincludes details background information that you provide to us when enquiring about our services and any information that we obtain about you and/or any Third Party when we carry out our services. It may include sensitive data and criminal offence data.
8.1.5. Technical Dataincludes internet protocol (IP) address, 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.
8.1.6 Usage Dataincludes information about how you use our website, for example how long you stay on each page and how long you generally visit our website for.
8.1.7. Marketing Dataincludes your marketing and communication preferences as well as feedback.
8.1.8. 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.
9. Basis for processing data
9.1. We have to have a valid lawful basis in order to process your personal data. We will generally process your personal data in the following circumstances:
9.1.1. We need this information in order to take steps at your request prior to entering into a contact with you or for the performance of a contract to which you are a party.
9.1.2. Where it is necessary for our or our client’s legitimate interests and your interests and fundamental rights do not override those interests. We make sure we consider and balance any potential impact on data subjects (both positive and negative) and their rights before we process personal data for our or our client legitimate interests. We do not use personal data for activities where our or our client’s interests are overridden by the impact on data subject (unless we have data subject consent or are otherwise required or permitted to by law). Where we process information under this lawful basis, we will specify legitimate interests
9.1.3. Where we need to comply with a legal or regulatory obligation that we are subject
9.1.4. Where you have provided us consent. Generally, we do not rely on consent as a legal basis for processing your personal data but may in certain circumstances request for your explicit consent to process your data. If we do so, we will advise you on the purpose of that data collection, how we will process it and will request your explicit and clear consent for us to process that data for that purpose. Where we rely on your consent to process your data, you will be able to withdraw your consent at any time.
9.2. It is important that you are aware that where we process your data for the purposes of entering into a contract with you, legitimate interest or to comply with our legal obligations we can process your data for these purposes without your consent (without prejudice to your other rights).
9.3. Please note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground, we are relying on to process your personal data, where more than one ground has been set out below.
9.4. If we have lawful basis to collect your Personal Data and you refuse to provide it, we may be unable to enter into a contract with you.
10. Special categories of personal data
10.1. The Company may process sensitive personal information about data subjects. We may only use information relating to sensitive information where the law allows us or requires us to do so. This will usually be where such processing is necessary to carry out our obligations and provided, we do so in line with our Data Protection Policy.
10.2. We will only process sensitive personal information if:
10.2.1. we have a lawful basis for doing so; and
10.2.2. one of the special conditions for processing sensitive information applies.
10.3. The Company will not carry out automated decision-making (including profiling) based on any individual’s sensitive personal information. We have in place an Appropriate Policy Document (where applicable), a copy of which can be obtained from the DPO and have put safeguards in place which we are required by law to maintain when processing such data.
11. Criminal conviction data
11.1. The Company may process criminal conviction data about data subjects. We may only use information relating to criminal conviction data where the law allows us or requires us to do so. This will usually be where such processing is necessary to carry out our obligations, for our or our client legitimate business interests provided, we do so in accordance with applicable laws.
11.2. We will only criminal conviction data information if:
11.2.1. we have a lawful basis for doing so; and
11.2.2. one of the special conditions for processing criminal conviction data applies.
11.3. We have in place an Appropriate Policy Document (where applicable), a copy of which can be obtained from the DPO and have put safeguards in place which we are required by law to maintain when processing such data.
12. Website users
12.1. We have in place an Appropriate Policy Document (where applicable), a copy of which can be obtained from the DPO and have put safeguards in place which we are required by law to maintain when processing such data.
12.1.1. obtain this information from you or third parties such as analytics providers (eg google), which may be based outside the UK;
12.1.2. collect this information for the purpose of administering and protecting our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data;
12.1.3. collect this data as it is necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise);
12.1.4. will share the information we receive with relevant personnel within Company, i.e. those responsible for the IT aspect of the business and third-party service providers responsible for our website maintenance;
12.1.5. collect this information automatically when you use our website. If you do not wish for this information to be collected, please do not use our website.
13. Prospective clients
13.1. We will process Identity, Contact, Background and Marketing Data when you enquire about our services and products by filling in forms on our website, by corresponding with us by post, phone or email and when you visit our offices. We will:
13.1.1. obtain this information from you and third paries;
13.1.2. collect this information for the purpose of determining if we are able to provide you with services;
13.1.3. collect this data as it is necessary in order for us to enter into a contract with you and for our legitimate interests (to grow our business, maintain appropriate records, determine if we can provide you with services or promote our services) and to comply with our legal obligations;
13.1.4. share the information we receive with relevant personnel within Company, i.e. to pass messages or information so that that personnel may respond to your enquiry, make appointments, assess your situation and whether we can supply you with our products and services.
13.1.5. not be able to contact you or take necessary steps to enter into a contract with you, if you fail to provide necessary information.
13.2. You may also wish to provide us with sensitive data in relation to your health (i.e. disability) by requesting us to make reasonable adjustments on how we communicate with you or if we need to make special adjustments so that we can provide you with our services.
14.1. We will process your Identity, Contact, Background, Transaction and Marketing Data when when we provide you with services. We will:
14.1.1. obtain this information from you and publicly available sources;
14.1.2. obtain this information when you correspond with us by post, phone or email and when you visit our offices;
14.1.3. collect this data as it is necessary in order for us to enter into a contract with you and for our legitimate interests (to grow our business, maintain appropriate records, provide you with services, defend and exercise legal claims) and to comply with our legal obligations;
14.1.4. share the information we receive with relevant personnel within Company, i.e. to pass messages or information so that that personnel may respond to your enquiry, provide you with services, process payments and refunds, respond to concerns and feedback.
14.1.5. not be able to contact you or take necessary steps to enter into a contract with you, if you fail to provide necessary information.
14.2. You may also wish to provide us with sensitive data in relation to your health (i.e. disability) by requesting us to make reasonable adjustments on how we communicate with you or if we need to make special adjustments so that we can provide you with our services.
15. Third parties
15.1. Given the nature of our work, we may routinely process information about Third Parties as part of our services. We may process Identity, Contact and Background information about third parties. We may:
15.1.1. obtain this information from our clients, third paries, publicy available sources and other legal avenues including those that are outside of the UK.
15.1.2. collect this information for legitimate business interests of our clients (to grow their business, to carry out due diligence, for risk assessment, to prevent fraud, to ensure that they comply with their legal obligations, to defend and commence legal claims, to enforce their contractual and/or statutory rights etc);
15.1.3. collect this data as it is necessary in order for us to comply with our contractual terms and for our legitimate interests (maintain appropriate records, to defend legal claims, to enforce our contractual/statutory rights) and to comply with our legal obligations;
15.1.4. share the information we receive with relevant personnel within Company, our service providers and our instructing clients.
15.2. We may also process sensitive and criminal conviction data.
16. Purpose and legitimate business interests
16.1. The Company collects and processes data about data subjects for various purposes. The Company process information for the following purposes (on behalf of itself and its instructing clients) to:
16.1.1. maintain appropriate records*
16.1.2. detect and prevent fraud and other unlawful acts*
16.1.3. to provide services to clients, grow business and plan for the future*
16.1.4. to comply with regulatory and corporate governance obligations*
16.1.5. to ensure safe working*
16.1.6. to ensure compliance with insurance requirements*
16.1.7. for business development purposes*
16.1.8. to monitor safety, issues and conduct*
16.1.9. for reasons of substantial public interest*
16.1.10. to protect networks, and personal data against unauthorised access or data leakage*
16.1.11. to ensure business policies, such as those concerning data security, data protection, confidentiality and internet use, are adhered to*
16.1.12. for the purpose of administering and protecting the business and the Company website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data*
16.1.13. for the purposes of business reorganisation or restructuring exercise*
16.1.14. for operational reasons, such as maintaining records, recording transactions, training and quality control*
16.1.15. to ensure that commercially sensitive information is kept confidential*
16.1.16. for security vetting and investigating complaints and allegations of criminal offences and/or fraud*
16.1.17. to prevent unauthorised access and modifications to our systems*
16.1.18. as part of investigations by regulatory bodies, or in connection with legal proceedings or requests*
16.1.19. monitoring compliance with policies and contractual obligations*
16.1.20. the processing is necessary for the establishment, exercise or defence of legal claims
16.1.21. to decide the other terms of services*
16.1.22. to carry out the contractual obligations and to enforce contractual obligations*
16.1.23. for training and monitoring purposes and to ensure that we continue to provide quality service*
16.1.24. to determine whether we need to make reasonable adjustments because of disability*
16.1.25. to monitor diversity and equal opportunities*
16.1.26. to review and address issues that are raised or feedback received relating to the service*
16.1.27. to defend the Company in respect of any investigation or litigation and to comply with any court or tribunal orders for disclosure*
16.2. Purposes listed above which have an asterisk beside them are processed for our legitimate business interests.
17. Who we share the information with
17.1. We routinely share your personal data with relevant personnel within our Company but on a strictly need to know basis. We may also need to share some of the above categories of personal information with other parties. We may also be required to share some personal information with our regulators or as required to comply with the law.
17.2. It is important that you note that if we share your information with a third party who is another data controller, then that data controller will be responsible for determining how your data will be processed and we have no control over their processing activity (e.g. HMRC, bank, insurer). If a third party is a data controller, they must provide you with details on how they will process your data.
17.3. We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
17.4. We may disclose your data in order to enforce our contractual rights against you or to defend legal claims. We may also disclose your data to protect our rights, property and safety, or the rights, property and safety of others or to prevent fraud or other crime.
17.5. We may also need to share some personal data 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 before we share any data.
18. International transfers
18.1. We may share your information with third parties who are based outside the UK. These transfers are subject to special rules under UK GDPR.
18.2. The following countries to which we may transfer Personal Data have been assessed by the UK as providing an adequate level of protection for Personal Data: All countries of EEA, Andorra, Argentina, Canada (only covers data that is subject to Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA)), Faroe Islands, Guernsey, Israel, Japan (private sector organisations), Isle of Man, Jersey, New Zealand, Switzerland, Uruguay as providing adequate protection.
18.3. Except for the countries listed above, countries outside the UK do not have the same data protection laws as the United Kingdom. If we must share your data outside the UK, we will ensure the transfer complies with data protection law and will only do so where the recipient has provided appropriate safeguards, and if data subjects have enforceable rights and effective legal remedies. Our standard practice is to use standard data protection contract clauses which have been approved and that includes the measures and safeguards that must be in place to protect personal data and first requires a risk assessment to be undertaken.
18.4. Data protection legislation allows personal data to be transferred outside of the UK in some other limited circumstances such as where it is necessary to defend a legal claim.
19. Data security
19.1. Information may be held at our offices and third-party agencies, service providers, representatives and agents. We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need-to-know.
19.2. We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so. Where we process data about Third Parties, in an event of a breach, there may be some exemptions applicable which means that we may be unable to notify you in the event of a breach.
20. Data retention
20.1. We will not retain your data for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of data. Generally we keep your records for:
20.1.1. Website Users: data retained for 2 years;
20.1.2. Prospective Clients: data retained for 7 years;
20.1.3. Clients: data retained for 7 years;
20.1.4. Third Parties: data retained for 7 years.
20.2. We generally keep your personal data so that we can respond to any questions, respond to complaints or claims made by you or on your behalf, show that we treated you fairly, keep records required by law, prevent fraud, comply with our legal and/or regulatory requirements. When it is no longer necessary to retain your personal data, we will delete it securely.
20.3. 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.
20.4. In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.
21. Promotional communications
21.1. We may use your personal data to send you updates (by email, telephone or post) about developments that might be of interest to you and/or information about our services, including exclusive offers, promotions, invitations to seminars or information on our new services. We have a legitimate interest in processing your personal data for promotional purposes. This means we do not usually need your consent to send you promotional communications if you are our former or current client (consumer) or if you are a business or organisation. However, where consent is needed, we will ask for this consent separately and clearly. We will always treat your personal data with the utmost respect and never sell or share it with other organisations for marketing purposes.
21.2. You have the right to opt out of receiving promotional communications at any time by:
21.2.1. contacting our Data Protection Officer;
21.2.2. using the ‘unsubscribe’ link or ‘opt out’ link in any promotional emails;
21.2.3. updating your marketing preferences by contacting our Data Protection Officer.
21.3. We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.
21.4. We will not use your data for promotional purposes if you are a Third Party.
22. Your rights
22.1. Right to be Informed about the collection and use of your personal data. This Privacy Notice together with documents referred to herein provides you with this information.
22.2. Right to Access (Subject Access Request) to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it. If you wish to exercise this right:
22.2.1. 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 unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
22.2.2. 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.
22.2.3. 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.
22.3. Request Correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
22.4. Request Erasure of your personal information. In certain circumstances you have the right to have ask for some but not all of the information we hold and process to be erased (the right to be forgotten). This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).
22.5. Object to Processing of your personal information 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. You also have the right to object where we are processing your personal information for direct marketing purposes.
22.6. Request Restriction of Processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
22.7. Request the Transfer of your personal information to another party.
22.8. Rights in Relation to Automated Decision Making and Profiling your personal data. You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.
22.9. If you want to exercise any of the above-mentioned rights, please contact the DPO by telephone or in writing. We will respond to your request within one calendar month.
22.10. In certain circumstances we may not be able to comply with your request as we may be exempt or prevented from doing so by law. Where this is the case we will notify you and explain of why we are refusing to do so.
23. Your queries and complaints
23.1. Our Data Protection Officer, Paul Oakley is responsible for overseeing the 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 him by emailing to email@example.com, by calling him on 0203 948 1988 or by writing to Tintagel House, 92 Albert Embankment London SE1 7TY.
23.2. We hope that our DPO can resolve any query or concern you raise about our use of your information. However, if you feel that we have failed to address your concerns appropriately, you can contact the Information Commissioner at ico.org.uk/concerns/ or telephone: 0303 123 1113 for further information about your rights and how to make a formal complaint.