Privacy Notice

General

Octant Research & Analysis Ltd (“we” or “us” or “Octant”) 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:

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
When you provide contact details in person or via email, telephone or via the Site	Contact Information	Necessary for our legitimate interests (to obtain necessary information in order to provide our services)
When you update or amend your contact details with us	Contact Information	Necessary for our legitimate interests (to obtain necessary information in order to provide our services) Performance of a contract with you
When you contact us about a potential engagement for our Services	ID Information. Contact Information.	Necessary for our legitimate interests (to obtain necessary information in order to provide our services)
When you engage us to provide our Services	ID Information Contact Information Payment Information	Performance of a contract with you. Necessary for our legitimate interests (for running our business and to provide you with products and services requested)
When you provide payment details in relation to our Services	ID Information Contact Information Payment Information	Performance of a contract with you Necessary for our legitimate interests (for running our business and to provide you with products and services requested and to fulfil our statutory obligations) Necessary to comply with legal obligation
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy notice; (b) Asking you to leave a review or take a survey; (c) When you submit a complaint; (d) Sending relevant information about our products and services to you.	Contact Information. Payment Information. Communication Information Technical Information	Performance of a contract with you Necessary to comply with a legal obligation Necessary for our legitimate interests (to keep our records updated and to study how customers use the services we provide)
To administer and protect our business, including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data	Contact Information Technical Information	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) Necessary to comply with a legal obligation
To use data analytics to improve the Site, services, marketing, customer relationships and experiences	Technical Information Communication Information	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

Data Retention

Our current data retention policy is to delete or destroy (to the extent we are able to) the personal data we hold about you in accordance with the following:

Category of personal data	Length of retention
Records relevant for tax purposes	8 years from the end of the tax year to which the records relate
Personal data processed in relation to a contract between you and us	7 years from either the end of the contract or the date you last used our services or placed an order with us, being the length of time following a breach of contract in which a contract party is entitled to make a legal claim
Personal data held on marketing or business development records	3 years from the last date on which you have interacted with us

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 on-going 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;

when 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:

The right to be informed	You have a right to know about our personal data protection and data processing activities, details of which are contained in this notice.
The right of access	You can make what is known as a Subject Access Request (“SAR”) to request information about the personal data we hold about you (free of charge, save for reasonable expenses for repeat requests). If you wish to make a SAR please contact us as described below.
The right to correction	Please inform us if information we hold about you is incomplete or inaccurate in any way and we will update our records as soon as possible, but in any event within one month. We will take reasonable steps to communicate the change to any third parties to whom we have passed the same information.
The right to erasure (the ‘right to be forgotten’)	Please notify us if you no longer wish us to hold personal data about you (although in practice it is not possible to provide our services without holding your personal data). Unless we have reasonable grounds to refuse the erasure, on receipt of such a request we will securely delete the personal data in question within one month. The data may continue to exist in certain backup, but we will take steps to ensure that it will not be accessible. We will communicate the erasure to any third parties to whom we have passed the same information.
The right to restrict processing	You can request that we no longer process your personal data in certain ways, whilst not requiring us to delete the same data.
The right to data portability	You have right to receive copies of personal data we hold about you in a commonly used and easily storable format (please let us know a format which suits you). You may also request that we transfer your personal data directly to third party (where technically possible).
The right to object	Unless we have overriding legitimate grounds for such processing, you may object to us using your personal data if you feel your fundamental rights and freedoms are impacted. You may also object if we use your personal data for direct marketing purposes (including profiling) or for research or statistical purposes. Please notify your objection to us and we will gladly cease such processing, unless we have overriding legitimate grounds.
Rights with respect to automated decision-making and profiling	You have a right not to be subject to automated decision-making (including profiling) when those decisions have a legal (or similarly significant effect) on you. You are not entitled to this right when the automated processing is necessary for us to perform our obligations under a contract with you, it is permitted by law, or if you have given your explicit consent.
Right to withdraw consent	If we are relying on your consent as the basis on which we are processing your personal data, you have the right to withdraw your consent at any time. Even if you have not expressly given your consent to our processing, you also have the right to object (see above).

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 of the EEA.

If we transfer your information outside of 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.