Privacy Notice

General

Octant Research & Analysis Ltd. (“we” or “us” or “Octant Research & Analysis Ltd.”) takes the privacy of your information very seriously. Our Privacy Notice (together with our Terms of Business if you are a client) is designed to tell you, our client or the direct or indirect user of our services (the “Services”) about our practices regarding the collection, use, and disclosure of personal information about you, your enterprise or your organisation that may be provided to us by you personally, or by email or telephone communication or collected through other means such as via our website (the “Site”).

This notice applies to personal data provided to us by our clients, prospective clients or users of the Site, whether they are a client of our service or otherwise. In this notice, “you” refers to any individual whose personal data we hold or process as a data controller (other than our staff).

This notice is governed by the EU General Data Protection Regulation (the “GDPR”).

Basis on Which We Process Personal Data

Personal data we hold about you will be processed either because:

The processing is necessary in pursuit of a “legitimate interest”, a legitimate interest in this context means a valid interest we have, or a third party has in processing your personal data which is not overridden by your interests in data privacy and security;

You have consented to the processing for the specific purposes described in this notice;

The processing is necessary in order for us to comply with our obligations under a contract between you and us.

Personal Data We Collect

We may collect and process the following personal data (information that can be uniquely identified with you) about you:

Contact information we collect from you (for example, your name, address, telephone number, email address) (“Contact Information”);

Information you provide to us when becoming our client such as personal identification information including copies of your passport, driving licence, national insurance number, banks statements, utility bills or other proof of address (“ID Information”);

Information provided relating to payment that we may collect or receive (“Payment Information”);

A record and details of any correspondence or communication between you and us or relating to any complaint submitted to us (“Communication Information”);

Replies to any surveys or questionnaires that we may use for research purposes (“Survey Information”);

Details of your visits to the Site, the resources, and pages that you access and any searches you make (“Technical Information”).

We will not collect any sensitive personal data without your prior consent. By sensitive personal data, we mean data which falls within certain ‘special categories’ which are defined in the GDPR (e.g. health data) and which require additional protection and consent measures.

We will collect information either from you directly or from a third party (for instance, if you are an individual employed by one of our clients, then we may receive information from your employer). If we do obtain your personal data from a third party, your privacy rights under this notice are not affected, and you are still able to exercise the rights contained within this notice.

You do not have to supply any personal information to us, but our Services may not be available in their entirety in practice without providing this personal data to us. You may withdraw our authority to process your personal data (or request that we restrict our processing) at any time (but our Services may not be available or may need to be withdrawn should you do so).

Personal Data We Hold as a Data Processor

There is certain information we collect that we hold as ‘data processor’. This may include the name, address, age, and other personal information of data subjects that we process on behalf of our clients.

Our client is the data controller for this data, and we are processing this data on our client’s behalf. Our terms require that our client processes this data in accordance with applicable data protection legislation. If you, as a data subject whose data is controlled by our client, require us to cease processing or delete such data or if you otherwise would like to exercise your rights as a data subject, please contact our client to make the relevant request.

IP Address

An Internet Protocol (IP) address is a number assigned to your computer by your Internet Service Provider (ISP), so you can access the Internet. We may use your IP address to diagnose problems with our server, report aggregate information, and determine the fastest route for your computer to use in connecting to our Site, and to administer and improve the Site.

How We Process Your Personal Data

Please see the table below, which sets out the manner in which we will process the different types of personal data we hold:

For any category of personal data not specifically defined in this notice, and unless otherwise specified by applicable law, the required retention period for any personal data will be deemed to be 7 years from the date of receipt by us of that data or (if later) the end of the relevant contract, arrangement, or interaction with that person.

The retention periods stated in this notice can be prolonged or shortened as may be required (for example, in the event that legal proceedings apply to the data or if there is an ongoing investigation into the data).

We review the personal data (and the categories of personal data) we are holding on a regular basis to ensure the data we are holding is still relevant to our business and is accurate. If we discover that certain data we are holding is no longer necessary or accurate, we will take reasonable steps to correct or delete this data as may be required.

If you wish to request that data we hold about you is amended or deleted, please see clause 11 below, which explains your privacy rights.

Sharing Your Information

We do not disclose any personal data you provide to any third parties other than as follows:

Where you have asked us to share your information with a third party as part of the performance of our Services;

Certain third party suppliers including technical support providers may have access to personal data;

Where we carry out research to gain an insight into the use of our Services, the results of this research (but not your personal data itself) may be transferred to interested third parties;

If we are under a duty to disclose or share your personal data in order to comply with any legal obligation (for example, if required to do so by a court order or for the purposes of prevention of fraud or other crime);

In order to enforce any terms and conditions or agreements for our services that may apply;

We may transfer your personal information to a third party as part of a sale of some or all of our business and assets to any third party or as part of any business restructuring or reorganisation, but we will take steps with the aim of ensuring that your privacy rights continue to be protected;

To protect our rights, property and safety, or the rights, property and safety of our users or any other third parties. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

Other than as set out above, we shall not disclose any of your personal information unless you give us permission to do so. If we do supply your personal information to a third party, we will take steps to ensure that your privacy rights are protected and that third party complies with the terms of this notice.

Email and Other Communications

If you have placed an order for services with us, we may from time to time contact you about similar goods or services.

When we send email and other electronic communications, we will comply with applicable regulations, including the Privacy and Electronic Communications Regulations 2003. In particular, we will identify the nature of the message and the sender clearly, and you will have an opportunity to opt out of receiving any further communications from us.

Security

We will take all reasonable steps to ensure that appropriate technical and organisational measures are carried out in order to safeguard the information we collect from you and protect against unlawful access and accidental loss or damage. These measures may include (as necessary):

Protecting our servers by both hardware and software firewalls;

locating our data processing storage facilities in secure locations;

Encrypting all data stored on our server with an industry standard encryption method that encrypts the data between your computer and our server so that in the event of your network being insecure, no data is passed in a format that could easily be deciphered;

ensuring that all communication with our servers is encrypted through Secure Sockets Layer (SSL), an industry standard encryption method that encrypts data between your computer and our servers so that in the event of your network being insecure no data is passed in a format that could easily be deciphered;

Ehen necessary, disposing of or deleting your data so it is done so securely;

Regularly backing up and encrypting all data we hold.

We will ensure that our employees are aware of their privacy and data security obligations. We will take reasonable steps to ensure that the employees of third parties working on our behalf are aware of their privacy and data security obligations.

This notice and our procedures for handling personal data will be reviewed as necessary.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the Site. Once we have received your information, we will use the procedures and security features referred to in this notice to try to prevent unauthorised access.

Your Privacy Rights

The GDPR gives you the following rights in respect of personal data we hold about you:

All SARs and other requests or notifications in respect of your above rights must be sent to us in writing to HYPERLINK “mailto:duncan.allan99@gmail.com” duncan.allan99@gmail.com.

We will endeavour to comply with such requests as soon as possible, but in any event we will comply within one month of receipt (unless a longer period of time to respond is reasonable by virtue of the complexity or number of your requests).

Data Breaches

If personal data we hold about you is subject to a breach or unauthorised disclosure or access, we will report this to the Information Commissioner’s Office (ICO).

If a breach is likely to result in a risk to your data rights and freedoms, we will notify you as soon as possible.

Other Websites

Our Site may contain links and references to other websites. Please be aware that this notice does not apply to those websites.

We cannot be responsible for the privacy policies and practices of sites that are not operated by us, even if you access them via the Site. We recommend that you check the policy of each site you visit and contact its owner or operator if you have any concerns or questions.

In addition, if you came to this site via a third party site, we cannot be responsible for the privacy policies and practices of the owners or operators of that third party site and recommend that you check the policy of that third party site and contact its owner or operator if you have any concerns or questions.

Transferring Your Information Outside Europe

As part of the Services offered to you, the information you provide to us may be transferred to, processed and stored at, countries or international organisations outside the EEA.

If we transfer your information outside the EEA, and the third country or international organisation in question has not been deemed by the EU Commission to have adequate data protection laws, we will provide appropriate safeguards, and we will be responsible for ensuring your privacy rights continue to be protected as outlined in this notice. In particular, we will ensure that there is a contract in place with our partners to ensure that your data is processed in accordance with this notice.

If you use our Services while you are outside the EEA, your information may be transferred outside the EEA in order to provide you with those Services.

By submitting your personal information to us, you agree to the transfer, storing or processing of your information outside the EEA in the manner described above.

Notification of Changes to the Contents of This Notice

We will post details of any changes to our policy on the Site to help ensure you are always aware of the information we collect, how we use it, and in what circumstances, if any, we share it with other parties.

Contact Us

If at any time you would like to contact us with your views about our privacy practices, or with any enquiry or complaint relating to your personal information or how it is handled, you can do so via the following email address: duncan.allan99@gmail.com.

If we are unable to resolve any issues you may have, or you would like to make a further complaint, you can contact the Information Commissioner’s Office by visiting www.ico.org.uk for further assistance.

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