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Data Privacy Notice

We are SPEAK FIRST LIMITED with registered number 04778086 and address 36 Tyndall Court PE2 6LR. Our Data Protection Lead can be contacted here. We have produced this privacy notice in order to keep you informed of how we handle your personal data. All handling of your personal data is done in compliance with the General Data Protection Regulation (EU) 2016/679 (“Data Protection Legislation”). The terms “Personal Data”, “Special Categories of Personal Data”, “Personal Data Breach”, “Data Protection Officer”, “Data Controller”, “Data Processor”, “Data Subject” and “process” (in the context of usage of Personal Data) shall have the meanings given to them in the Data Protection Legislation. “Data Protection Lead” is the title given to the member of staff leading our data protection compliance programme in lieu of a requirement for a Data Protection Officer.

What are your rights?

When reading this notice, it might be helpful to understand that your rights arising under Data Protection Legislation include:

• The right to be informed of how your Personal Data is used (through this notice);
• The right to access any personal data held about you;
• The right to rectify any inaccurate or incomplete personal data held about you;
• The right to erasure where it cannot be justified that the information held satisfies any of the criteria outlined in this policy;
• The right to prevent processing for direct marketing purposes, scientific/historical research or in any such way that is likely to cause substantial damage to you or another, including through profile building; and
• The right to object to processing that results in decisions being made about you by automated processes and prevent those decisions being enacted.

You can exercise your right to access personal data held about you by getting in touch here with the subject line: “Subject Access Request”. When you submit a ‘subject access request’, you will need to provide confirmation of your identity by contacting us using the email address associated with your profile. This is provided free of charge and our response will be made within thirty (30) days unless our Data Protection Lead deems your request as being excessive or unfounded. If this is the case, we will inform you of our reasonable administration costs in advance and/or any associated delays, giving you the opportunity to choose whether you would like to pursue your request. If you believe we have made a mistake in evaluating your request, please see the section ‘Who can you complain to?’.

If you have questions about any of the rights mentioned in this section, please contact our Data Protection Lead here.

Who is the Data Controller?

• If we have collected your personal data directly from you for our own purposes, we are the Data Controller.
• If we have been passed your personal data from a third-party for a joint purpose that we both influence, we are the joint Data Controller. We will contact you to let you know before we first start to use your data, or, at the latest, within one month of acquiring it.
• If your data has been passed to us by a third party for processing under their instruction, that third party is the Data Controller. They should have notified you that they would be passing your personal data to us, SPEAK FIRST LIMITED, at the time they collected your data and within their own privacy notices/standards. For a list of Data Controllers that we process personal data for, the section below ‘Third Party Interests’.

What are the lawful bases for processing personal data?

Under Data Protection Legislation, there must be a ‘lawful basis’ for the use of personal data. The lawful bases are outlined in Article 6, Section 1 of the GDPR. They are sub-sections:
a) ‘your consent’;
b) ‘performance of a contract’;
c) ‘compliance with a legal obligation’;
d) ‘protection of your, or another’s vital interests’;
e) ‘public interest/official authority’; and
f) ‘our legitimate interests’.

What are SPEAK FIRST LIMITED’s ‘legitimate interests’?

Legitimate interests are a flexible basis upon which the law permits the processing of an individual’s personal data. To determine whether we have a legitimate interest in processing your data, we balance the needs and benefits to us against the risks and benefits for you of us processing your data. This balancing is performed as objectively as possible by our Data Protection Lead. You are able to object to our processing and we shall consider the extent to which this affects whether we have a legitimate interest. If you would like to find out more about our legitimate interests, please get in touch here.

About our processing of your data

We might collect, use, store and transfer different kinds of Personal Data about you which we have grouped together as follows:
Identity Data such as names, usernames or similar; marital status; title; date of birth; sex and gender.
Contact Data such as addresses; email addresses and telephone numbers.
Financial Data such as bank account and payment card information.
Transaction Data such as information about payments and details of purchases you have made.
Technical Data such as IP addresses; login data; browser info; time zone; location; browser plug-ins; operating systems; platforms and other technology on the device used to access this website.
Profile Data such as usernames; passwords; security answers; purchases/orders; interests; preferences; feedback and responses to surveys, blogs and messages.
Usage Data such as analytics relating to how you use the website.
Marketing and Communications Data such as your preferences about receiving communications from us or third parties.
Special Categories of Data such as details about race or ethnic origins, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, genetic or biometric data.
We also collect, use and share Aggregated Data such as statistical or demographic data. Aggregated Data can be derived from your Personal Data but is not itself Personal Data as it cannot be used to reveal your identity. If Aggregated Data is ever used in combination with your Personal Data and becomes identifiable, it will be treated in accordance with this notice.
SPEAK FIRST LIMITED does not collect any Special Categories of Personal Data about you or any information about criminal convictions/offences.

Client contracts:

What categories of information about you do we process?
• Identity data
• Contact data
• Financial data
• Transaction data

Why are we processing your data?

General performance of our contracts with clients, including administering the contract, contacting clients/their employees and complying with any other obligations. This processing is conducted lawfully on the basis of ‘performance of a contract’.

Where did we get your personal data from?

Directly obtained or by referral from one of our mutual contacts.

B2b marketing:

What categories of information about you do we process?

• Identity data
• Contact data
• Marketing and communications data

Why are we processing your data?

Providing our current and prospective clients with information about our services and other relevant developments within our industry. This processing is conducted lawfully on the basis of ‘our legitimate interests’.

Where did we get your personal data from?

Directly obtained or by referral from one of our mutual contacts.

Supplier contracts:

What categories of information about you do we process?

• Identity data
• Contact data
• Financial data
• Transaction data

Why are we processing your data?

General performance of our contracts with suppliers, including administering the contract, contacting suppliers/their employees and complying with any other obligations. This processing is conducted lawfully on the basis of ‘performance of a contract’.

Where did we get your personal data from?

Directly obtained or by referral from one of our mutual contacts.

What happens if I refuse to give SPEAK FIRST LIMITED my personal data?

We process some personal information as part of a contractual relationship with a data controller. Any requests to restrict this type of processing should be forwarded to the data controller; they will be responsible for discussing your concerns and making any decisions.

What do we do with cookies?

This website uses cookies to improve your experience while visiting the website. Where applicable, this website uses a cookie control system allowing you, on your first visit to the website, to allow or disallow the use of cookies on your device.

Cookies are small files saved to your device that track, save and store information about your interactions and usage of the website. This allows the website, through its server to provide you with a tailored experience within this website.

You are advised that if you wish to deny the use and saving of cookies from this website on your device you should take necessary steps within your web browser’s security settings to block all cookies from this website and its external serving vendors.

This website uses tracking software to monitor its visitors to better understand how you use it. This software is provided by google analytics which uses cookies to track visitor usage. The software will save a cookie to your device to track and monitor your engagement and usage of the website, but will not store, save or collect personal information. You can read Google’s privacy policy here for further information (https://www.google.com/privacy.html).

Other cookies may be stored to your device by external vendors when this website uses referral programs, sponsored links or adverts. Such cookies are used for conversion and referral tracking and typically expire after 30 days, though some may take longer. No personal information is stored, saved or collected.

What profiling or automated decision making does SPEAK FIRST LIMITED perform?

SPEAK FIRST LIMITED does not perform any profiling or automated decision making based on your personal data.

How long will your personal data be kept?

SPEAK FIRST LIMITED holds different categories of personal data for different periods of time. Wherever possible, we will endeavour to minimise the amount of personal data that we hold and the length of time for which it is held.

• If we process your data on the basis of ‘legitimate interests’, we will retain your data for as long as the purpose for which it is processed remains active. We review the status of our legitimate interests every twelve (12) months and will update this notice whenever we determine that either a legitimate interest no longer exists or that a new one has been found.

• All categories of personal data that are held by us because they are essential for the performance of a contract, will be held for a period of six years, as determined by reference to the limitations act 1980, for the purposes of exercising or defending legal claims.

Who else will receive your personal data?

SPEAK FIRST LIMITED passes your data to the third parties listed in the section ‘Third Party Interests’ which can be requested separately here.

Does your data leave the EU?

Yes. Details are included in the section ‘third party interests’ which can be requested separately here.

Want to find out more?

+44 (0) 20 7253 2117

We’re open Monday-Friday 09:00 to 17:00 BST


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