PRIVACY POLICY

BACKGROUND:

nine1three ltd. understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone whose personal data we process and will only collect and use personal data in ways that are described here, and in a manner that is consistent with Our obligations and your rights under the law.

Please read this Privacy Policy carefully and ensure that you understand it.

1. Definitions and Interpretation
In this Policy, the following terms shall have the following meanings:

2. Information About Us

2.1 We are nine1three ltd., a limited company registered in England under company number 14190528 whose registered address is 86-90 Paul Street, London, EC2A 4NE and whose main trading address is 86-90 Paul Street, London, EC2A 4NE. . We are the Data Controller your personal data that we process.

3. What Does This Policy Cover?
This Privacy Policy applies to all of the personal data that we process as a part of providing our services, and the use of our website. . Our website may contain links to other websites. Please note that We have no control over how your data is collected, stored, or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to them.

4. Your Rights

4.1 As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:

4.1.1 The right to be informed about Our collection and use of personal data;
4.1.2 The right of access to the personal data We hold about you;
4.1.3 The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us using the details in section 11);
4.1.4 The right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you (We only hold your personal data for a limited time, as explained in section 6 but if you would like Us to delete it sooner, please contact Us using the details in section 11);
4.1.5 The right to restrict (i.e. prevent) the processing of your personal data;
4.1.6 The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);
4.1.7 The right to object to Us using your personal data for particular purposes; and
4.1.8 Rights with respect to automated decision making and profiling.

4.2 If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided in section 11 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.

5. What Data Do We Collect?
Depending upon what services we are providing to you and your use of Our website, We may collect and process some or all of the following personal data (please also see section 10 on Our use of Cookies and similar technologies and Our Cookie Policy nine1three.com/privacy-policy/):

5.1 name;
5.2 business/company name
5.3 job title;
5.4 profession;
5.5 contact information such as email addresses and telephone numbers;
5.6 demographic information such as post code, preferences, and interests;
5.7 IP address;
5.8 web browser type and version;
5.9 operating system;
5.10 a list of URLs starting with a referring site, your activity on Our Site, and the site you exit to;

6. How Do We Use Your Data?

6.1 All personal data is processed and stored securely, for no longer than is necessary, for the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the Data GDPR at all times. For more details on security see section 7, below.

6.2 Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of your personal data (e.g. by subscribing to emails), or because it is in Our legitimate interests. Specifically, We may use your data for the following purposes:

6.2.1 Providing Our services and managing your Account;
6.2.2 Providing and managing your access to Our Site;
6.2.3 Personalising and tailoring your experience on Our Site;
6.2.4 Supplying Our products and services to you (please note that We require your personal data in order to enter into a contract with you);
6.2.5 Personalising and tailoring Our products and services for you;
6.2.6 Replying to emails from you;
6.2.7 Supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time by clicking “Unsubscribe from this list” or “Update subscription preferences” in our newsletter.
6.2.8 Market research;
6.2.9 Analysing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience;

6.3 Where We process data provided to us by you you will have gained all necessarily permission to share the data and for us to carry out the processing on your behalf
6.4 If the processing involves personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data or biometric data for the purpose of uniquely identifying a natural person, data concerning health or a person’s sex life or sexual orientation, or data relating to criminal convictions and offences (“sensitive data”), the processor shall apply specific restrictions and/or additional safeguards.
6.5 With your consent and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email and telephone or text message and post with information, news and offers on Our products and services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under any relevant legislation.
6.6 If you have provided consent, you have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it.
We will only retain personal data for as long as necessary to fulfil the purposes it was collected for, including compliance with any applicable legal, accounting or reporting requirements. To determine the appropriate retention period for personal data, We will take into account Our legal and regulatory obligations, the amount, nature and sensitivity of the data and potential risk from unauthorized use or disclosure of personal data.

7. Data Security – How and Where Do We Store Your Data?

7.1 Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure data collected by US, such as:

a) Measures of pseudonymisation and encryption of personal data

b) Measures for ensuring ongoing confidentiality, integrity, availability and resilience of processing systems and services

c) Measures for ensuring the ability to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident

d) Processes for regularly testing, assessing and evaluating the effectiveness of technical and organisational measures in order to ensure the security of the processing

e) Measures for user identification and authorisation

f) Measures for the protection of data during transmission

g) Measures for the protection of data during storage

h) Measures for ensuring physical security of locations at which personal data are processed

i) Measures for internal IT and IT security governance and management

j) Measures for ensuring data minimisation

k) Measures for ensuring data quality

l) Measures for ensuring limited data retention

m) Measures for ensuring accountability

8. Do We Share Your Data and International Transfers?

8.1 We may share your data with third parties as part of the services we provide or to help us improve the services we provide.
8.2 In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal obligations, a court order, or a governmental authority.

8.3 We may compile statistics about the use of Our website including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.
8.4 In some cases, the parties we use to process personal data on our behalf are based outside your jurisdiction, therefore their processing of your personal data will involve a transfer of such data outside of your jurisdiction. Similarly, we may be requested by a government regulator or authority based outside of your jurisdiction for your personal data. Where this is the case, we will only share the minimal amount of personal data necessary for the purpose of processing and, where possible, we will inform you of the transfer and share the personal data in an anonymized form.
8.5 Whenever we transfer your personal data out of your jurisdiction, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

8.5.1 We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection by your government; and/or
8.5.2 where we use certain service providers, we may use specific contracts approved by your data protection regulator, which gives personal data the same protection it has within your jurisdiction

9. What Happens If Our Business Changes Hands?

9.1 We may, from time to time, expand or reduce Our business and this may involve the sale and/or the transfer of control of all or part of Our business. Any personal data that you have provided will, where it is relevant to any part of Our business that is being transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use that data only for the same purposes for which it was originally collected by Us.
9.2 In the event that any of your data is to be transferred in such a manner, you will be contacted in advance and informed of the changes.

10. Our Use of Cookies

10.1 Our Site may place and access certain first party cookies on your computer or device. First party cookies are those placed directly by Us and are used only by Us. We use cookies to facilitate and improve your experience of Our website and to provide and improve Our products and services. We have carefully chosen these cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.
By using Our website you may also receive certain third party cookies on your computer or device. Third party cookies are those placed by websites, services, and/or parties other than Us. Third party cookies are used on Our website which allows certain functions and features of the website. We also use cookies for analytics purposes. These cookies track your movements and activities on the Our website and are designed to give us a better understanding of our users, thus enabling us to improve Our website and our services.
10.2 These cookies are not integral to the functioning of Our website and your use and experience of Our Website will not be impaired by refusing consent to them.
10.3 All cookies used by and on Our website are used in accordance with current cookie law.
10.4 Before cookies are placed on your computer or device, you will be shown a message requesting your consent to set those cookies requesting your consent to set those cookies. By giving your consent to the placing of cookies you are enabling Us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of cookies; however certain features of Our website may not function fully or as intended.
10.5 Certain features of Our website depend on cookies to function. These cookies are known as “strictly necessary”. These cookies are shown below in section

10.6. Your consent will not be sought to place these cookies, but it is still important that you are aware of them. You may still block these cookies by changing your internet browser’s settings as detailed below in section 10.10, but please be aware that Our website may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.
10.7 The following first party cookies may be placed on your computer or device:

10.8 Our website uses analytics services provided by Google Analytics. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling Us to better understand how Our website is used. This, in turn, enables Us to improve Our website and the products and services offered through it. You do not have to allow Us to use these cookies, however whilst Our use of them does not pose any risk to your safe use of Our website, ,it does enable Us to continually improve Our website, making it a better and more useful experience for you.
10.9 The analytics service(s) used by Our website use(s) Cookies to gather the required information.
10.10 The analytics service(s) used by Our website use(s) the aforementioned cookies.
10.11 In addition to the controls that We provide, you can choose to enable or disable cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party cookies. By default, most internet browsers accept cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
10.12 You can choose to delete cookies on your computer or device at any time, however you may lose any information that enables you to access Our website more quickly and efficiently including, but not limited to, login and personalisation settings.
10.13 It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.

11. Contacting Us
If you have any questions about the processing of your personal data or this or this Privacy Policy, please contact Us by email at info@nine1three.com by telephone on 02030361006, or by post at 86-90 Paul Street, London, EC2A 4NE. Please ensure that your query is clear, particularly if it is a request for information about the data We hold about you.

12. Changes to Our Privacy Policy
We may change this Privacy Policy from time to time (for example, if the law changes). Any changes will be immediately posted on Our Site. We recommend that you check this page regularly to keep up-to-date.