52M Consulting Limited ("52M") values your privacy and cares about the way your personal information is treated. This policy, revised in accordance with the General Data Protection Regulation (GDPR), describes:
what personal information we collect about you
how we obtain your personal information
how we use your personal information
on what basis we use your personal information
how long we keep your personal information
who we share your personal information with
how we protect your personal information
which countries we transfer your personal information to
your rights regarding your personal information
WHAT PERSONAL INFORMATION WE COLLECT ABOUT YOU
We may collect personal information from you in the course of our business, including through your use of our website, when you contact or request information from us, when you engage our legal or other services or as a result of your relationship with one or more of our staff and clients.
The personal information that we process includes:
Basic information, such as your name (including name prefix or title), the company you work for, your title or position and your relationship to a person
Contact information, such as your postal address, email address and phone number(s)
Financial information, such as payment-related information
Technical information, such as information from your visits to our website or applications or in relation to materials and communications we send to you electronically
Information you provide to us for the purposes of attending meetings and events, including access and dietary requirements
Identification and background information provided by you or collected as part of our business acceptance processes
Personal information provided to us by or on behalf of our clients or generated by us in the course or providing services to them, which may include special categories of data
Any other information relating to you which you may provide to us
HOW WE OBTAIN YOUR PERSONAL INFORMATION
We obtain your personal information in a number of ways:
We collect information from you as part of our business acceptance processes and about you and others as necessary in the course of providing consulting services
We collect your personal information while monitoring our technology tools and services, including our websites and email communications sent to and from 52M
We gather information about you when you provide it to us, or interact with us directly, for instance engaging with our staff or registering on one of our digital platforms or applications
We may collect or receive information about you from other sources, such as keeping the contact details we already hold for you accurate and up to date using publicly available sources
We collect or receive information about you when you complete online forms placed in our sponsored content
HOW WE USE YOUR PERSONAL INFORMATION
52M collects and processes personal information about you in a number of ways, including through your use of our website and in the provision of services by us. We use that information:
To provide and improve this website, including auditing and monitoring its use
To provide and improve our services to you and to our clients, including handling the personal information of others on behalf of our clients
To provide information requested by you
To promote our services, including sending updates, publications and details of events
To manage and administer our relationship with you and our clients
To fulfil our legal, regulatory and risk management obligations, including establishing, exercising or defending legal claims
For the purposes of recruitment
Use of the 52M website
A number of facilities on our website invite you to provide us with personal information, such as our email queries facilities. The purpose of these facilities is apparent at the point that you provide your personal information and we only use that information for those purposes.
Our website uses Google Analytics, a web-based analytics tool that tracks and reports on the manner in which the website is used to help us to improve it. Google Analytics does this by placing small text files called 'cookies' on your device. The information that the cookies collect, such as the number of visitors to the site, the pages visited and the length of time spent on the site, is aggregated and therefore anonymous. Please also see ‘Marketing and other emails’ below.
When you visit certain pages on our website, it also places a small text file on your device known as a 'tag'. This is then used to serve you with advertising on social media sites such as LinkedIn, Twitter and Facebook, as well as across the Google Display Network, where the advertisements you see are linked to your interactions on our website. This is known as 'remarketing' and is very common to online shops and e-commerce websites. We use it to remind you about our services and to signpost you to content that you might be interested in.
Marketing and other emails
We use personal information to understand whether you read the emails and other materials that we send to you, click on the links to the information that we include in them and whether and how you visit our website after you click on that link (immediately and on future visits). We do this by using software that places a cookie on your device which tracks this activity and records it against your email address. Please see 'Use of the 52M website' for more information on cookies and how to manage and remove them. Removal of this cookie will not affect your experience on our websites.
We may also use a relationship management tool, where permitted by applicable local law, to assess the strength of the relationship between individuals in 52M and our clients or potential clients based on the frequency of email contact between them. We use that information in order to assess, analyse and improve the services that we provide.
If you receive marketing communications from us and no longer wish to do so, you may unsubscribe at any time by emailing us at theteam [at] 52Mconsulting.com or clicking the unsubscribe link in our marketing communications.
Meetings, events and seminars
We will collect and process personal information about you in relation to your attendance at our offices or at an event or seminar organised by 52M or its business partners. We will only process and use special categories of personal information about your dietary or access requirements in order to cater for your needs and to meet any other legal or regulatory obligations we may have. We may share your information with IT and other service providers or business partners involved in organising or hosting the relevant event.
We collect, create, hold and use personal information in the course of and in connection with the services we provide to our clients. We will process identification and background information as part of our business acceptance, finance, administration and marketing processes, including anti-money laundering, conflict, reputational and financial checks. We will also process personal information provided to us by or on behalf of our clients for the purposes of the work we do for them. The information may be disclosed to third parties to the extent reasonably necessary in connection with that work. Please also see 'Who we share your personal information with' and 'Which countries we transfer your personal information to' below.
ON WHAT BASIS WE USE YOUR PERSONAL INFORMATION
We use your personal information on the following bases:
To perform a contract, such as engaging with a company to provide consulting services
For the establishment, exercise or defence of legal claims or proceedings
To comply with legal and regulatory obligations
For legitimate business purposes. Please see ‘How we use your personal information’ for more detail
HOW LONG WE KEEP YOUR PERSONAL INFORMATION
Your personal information will be retained in accordance with our data retention policy which categorises all of the information held by 52M and specifies the appropriate retention period for each category of data. Those periods are based on the requirements of applicable data protection laws and the purpose for which the information is collected and used, taking into account legal and regulatory requirements to retain the information for a minimum period, limitation periods for taking legal action, good practice and 52M's business purposes.
WHO WE SHARE YOUR PERSONAL INFORMATION WITH
We may share your personal information with certain trusted third parties in accordance with contractual arrangements in place with them, including:
Our professional advisers and auditors
Suppliers to whom we outsource certain support services such as graphic design, web development and digital marketing
IT service providers to 52M
Third parties engaged in the course of the services we provide to clients and with their prior consent, such as associate consultants
Third parties involved in hosting or organising events or seminars
Suppliers of Software as a Service (SaaS) such as Insightly, Inc who provide our Customer Relationship Management (CRM) system and Nationbuilder who host our website
Where necessary, or for the reasons set out in this policy, personal information may also be shared with regulatory authorities, courts, tribunals, government agencies and law enforcement agencies. While it is unlikely, we may be required to disclose your information to comply with legal or regulatory requirements. We will use reasonable endeavours to notify you before we do this, unless we are legally restricted from doing so.
If in the future we re-organise or transfer all or part of our business, we may need to transfer your information to new 52M entities or to third parties through which the business of 52M will be carried out.
We do not sell, rent or otherwise make personal information commercially available to any third party, except with your prior permission.
HOW WE PROTECT YOUR PERSONAL INFORMATION
We use a variety of technical and organisational measures to help protect your personal information from unauthorised access, use, disclosure, alteration or destruction consistent with applicable data protection laws.
WHICH COUNTRIES WE TRANSFER YOUR PERSONAL INFORMATION
The level of information protection in countries outside the EEA may be less than that offered within the EEA. Where this is the case, we will implement appropriate measures to ensure that your personal information remains protected and secure in accordance with applicable data protection laws. EU standard contractual clauses are in place between all 52M entities that share and process personal data. Where our third party service providers process personal data outside the EEA in the course of providing services to us, our written agreement with them will include appropriate measures, usually standard contractual clauses.
YOUR RIGHTS REGARDING YOUR PERSONAL INFORMATION TO
The European Union’s General Data Protection Regulation (GDPR) and other applicable data protection laws provide certain rights for data subjects.
You are entitled to request details of the information we hold about you and how we process it. You may also have a right in accordance with applicable data protection law to have it rectified or deleted, to restrict our processing of that information, to stop unauthorised transfers of your personal information to a third party and, in some circumstances, to have personal information relating to you transferred to another organisation. You may also have the right to lodge a complaint in relation to 52M's processing of your personal information with a local supervisory authority.
If you object to the processing of your personal information, or if you have provided your consent to processing and you later choose to withdraw it, we will respect that choice in accordance with our legal obligations.
Your objection (or withdrawal of any previously given consent) could mean that we are unable to perform the actions necessary to achieve the purposes set out above (see 'How we use your personal information') or that you may not be able to make use of the services and products offered by us. Please note that even after you have chosen to withdraw your consent we may be able to continue to process your personal information to the extent required or otherwise permitted by law, in particular in connection with exercising and defending our legal rights or meeting our legal and regulatory obligations.
We must ensure that your personal information is accurate and up to date. Therefore, please advise us of any changes to your information by emailing us at theteam [at] 52Mconsulting.com