Privacy Policy
We are committed to protecting and respecting your privacy.
Everyone has rights with regard to the way in which their personal information is handled. During the course of our activities we will collect, store and process personal information about our clients, suppliers and other third parties, and we recognise that the correct and lawful treatment of this data will maintain confidence in the organisation and will provide for successful business operations. This policy sets out the basis on which any personal information we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal information and how we will treat it.
Oliver Wight EAME LLP
For the purpose of UK data protection laws, the data controller is Oliver Wight EAME LLP, Corinium House, Barnwood Point, Corinium Avenue, Gloucester, GL4 3HX, England. From time to time, we may work in conjunction with other members of Oliver Wight International, including Oliver Wight Americas Inc and Oliver Wight Asia/Pacific, each of which is a data controller in its own right under their own national data protection laws.
Data Protection Principles
When processing your information, we will comply with the six enforceable principles of good practice. These provide that your personal information must be:
- processed lawfully, fairly and in a transparent manner,
- processed for specified, explicit and legitimate purposes,
- adequate, relevant and limited to what is necessary,
- accurate and kept up-to-date,
- kept for no longer than is necessary, and
- processed in a manner than ensures appropriate security.
Information you give to us
We may collect, use, store and transfer different kinds of personal information about you, including:
- Identity Data, such as your name, job title and your employer,
- Contact Data, such as your address, email addresses and telephone numbers,
- Third Party Data, namely Identity Data and Contact Data relating to your business colleagues and other contacts,
- Financial Data, such as payment card details and details of any payments you make to us or we make to you,
- Transaction Data, including details about services we may provide to you,
- Technical Data, including IP addresses, your log-in data, browser type and version, time-zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website,
- Profile Data, such as your username, password, purchases or orders made by you, your interests, preferences, feedback and survey responses, and
- Marketing Data, such as your preferences in receiving marketing from us and our third parties, and your communication preferences.
'Special Category' data
Information relating to your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, criminal convictions, sex life or sexual orientation, or certain types of genetic or biometric data is known as ‘special category’ data.
We would not normally collect or process ‘special category’ data about you.
How do we collect your personal information?
We may obtain personal information by directly interacting with you, such as:
- meeting with you at your (or your employer’s) premises, at events or elsewhere,
- receiving your instructions to provide services, and in the performance of those services,
- logging onto the wi-fi network in our offices,
- giving us your business card,
- entering a competition, promotion or survey organised by us, or otherwise providing us with feedback,
- subscribing to our services or publications, or otherwise requesting marketing material to be sent to you,
- corresponding with us by phone, video call, email, letters or otherwise, or
- buying or renting marketing links.
- We may obtain personal information via automated technology when you interact with our website by using cookies, server logs and other similar technologies.
- We may also collect personal information about you from third parties or publicly-available sources, such as:
• your employer, your business colleagues and other contacts,
• other members of Oliver Wight International,
• professional advisers, business networks and other companies with which we have alliances or undertake joint marketing and sales activities,
• organisers and venue hosts for events that we sponsor,
• analytics providers (such as Google),
• advertising networks,
• providers of technical, payment and delivery services, and
• by conducting searches of publicly-available databases or social media sites, such as Companies House, Facebook, X (formerly known as Twitter), LinkedIn and the electoral register.
How we use your personal information
We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
- you have given us consent,
- we need to perform a contract we are about to enter into, or have entered into, with you (including carrying out agreed services that we agree to provide to you),
- where it is necessary for our or a third party’s legitimate interests, and your interests and rights do not override those interests, or
- where we need to comply with a legal or regulatory obligation.
- we will only use ‘special category’ information:
• provided we have your explicit consent to use it,
• where we believe that we need to use that data to protect your vital interests where you are not able to provide us with your explicit consent,
• where it is necessary for reasons of substantial public interest,
• where you have previously made that data public knowledge,
• if we need to use that data to establish, exercise or defend legal claims, or
• where there is some other legal basis that allows us to use that information.
Purposes for which we will use your personal information
We may use your personal information for a number of different purposes. For each purpose, we are required to confirm the ‘legal basis’ that allows us to use your information, as follows:
- To register you as a customer of or supplier to our company. It will be necessary for the performance of the contract between you and us.
- Where you are acting as a representative of a company or organisation, then to register that company or organisation as a customer of or supplier to our company. It will be necessary for our legitimate business interests, and your company’s or organisation’s legitimate business interests, namely with a view to us providing or receiving services.
- To process your instructions as a customer and provide our services to you, or as a supplier and receive your services (including managing payments, fees and charges). It will be necessary for the performance of the contract between you and us.
- Where you are acting as a representative of a company or organisation, to process your instructions as a customer and provide our services to your company or organisation, or as a supplier and receive your company’s or organisation’s services (including managing payments, fees and charges). It will be necessary for our legitimate business interests, and your company’s or organisation’s legitimate business interests, namely with a view to us providing or receiving services.
- To obtain further information about you, any company or organisation you represent, and the matter that is the subject of the services we have agreed to provide or receive. It will be necessary for our legitimate business interests to ensure we are fully aware of all issues relating to the matter that is the subject of the services we have agreed to provide or receive.
- To collect and recover money owed to us. It will be necessary for our legitimate business interests, namely to ensure we receive payment for services that we have provided.
- To notify you about changes to our terms of business or this privacy policy. It will be necessary for our legitimate business interests, namely to ensure you are aware of our current terms and conditions.
- To administer our website, to apply online security processes and for internal operations, including troubleshooting, data analysis, remote email access, cyber-security, testing, research, statistical and survey purposes, to allow you to participate in interactive features of our service, when you choose to do so, to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you and to make suggestions and recommendations to you and other users of our website about goods or services that may interest you or them. It will be necessary for our legitimate business interests to ensure you receive the best experience possible and that appropriate cyber-security measures are applied when accessing and using our website or otherwise communicating with us electronically. We will comply with our cookie policy when processing this information.
- To enable you to participate in a prize draw, competition or complete a survey. It will be necessary for our legitimate business interests, namely to study how customers and suppliers, prospective customers and suppliers, business partners and other third parties use our services, to develop them and help grow our business.
- To enable us to generate and provide you with access codes and/or passwords to log onto the wi-fi network in our offices. It will be necessary for our legitimate business interests, namely to keep a record of who logs onto our wi-fi network because we may, in certain circumstances, be liable for the transmission of unlawful material via that network.
- To maintain and manage our CRM, marketing and sale databases and to provide you with information about special offers and other services we provide. Where you have previously received marketing communications from us, then it will be necessary for our legitimate business interests, namely to ensure you continue to receive communications that you have previously agreed to receive unless you decide to ‘opt out’ of receiving those communications. Where you specifically ask us to provide you with certain marketing communications, then it will be necessary for our legitimate business interests, namely to ensure we provide you with the communications that you have requested. In all other cases, we will only do this if you give us your consent.
- To invite you to events, such as seminars, workshops and thereafter to manage your attendance at the event in questions to include managing information on your dietary preferences if the event is catered. It will be necessary for our legitimate business interests to ensure you are aware of the latest developments in relation to the services we have provided to you, or are providing to you, or otherwise to develop our relationship with you outside of the working environment. Where you would not normally have a reasonable expectation of receiving such invites from us, we will only send you invites if you agree. Where the information collected relates to any dietary preference which may be considered to be 'special category data', for example a medical issue or allergy, we will only process this information with your explicit consent.
We will only use your personal information for the purpose(s) for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
What if you cannot or will not provide us with your personal information
It is a contractual requirement for you to provide us with certain information, namely sufficient information to allow us to perform the terms of any contract we have entered into with you, or with any company or organisation that you represent. If you do not provide us with that information, we may be unable to accept your instructions and/or provide you with the full range of our services. In cases where providing this information is optional, we will make it clear.
Disclosure of your information
We may share your personal information with the parties set out below:
- where you are referred to us by a third party, we may provide them with certain information about you,
- professional advisers and business networks with which we are connected,
- our outsourced IT services providers, Quintech, Cove data protection, N-Able, together with providers of wi-fi, IT, mailing list and system administration services to our business and our other online cloud and data-room providers,
- business partners, suppliers and sub-contractors to the extent we consider it reasonably necessary for us to perform our services,
- analytics and search engine providers that assist us in the improvement and optimisation of our website,
- caterers and hospitality staff, event organisers, venue hosts, training providers and other parties we collaborate with for the purposes of organising and staging our events,
- third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal information in the same way as set out in this policy, and
- other members of Oliver Wight International.
- We periodically appoint digital marketing agents to conduct marketing activity on our behalf, such activity may result in the compliant processing of personal information. Our appointed data processors include:
- Hubspot. The policy setting out how they collect and use personal information is available at https://legal.hubspot.com/privacy-policy.
- Olark live chat. Their privacy policy is available at https://www.olark.com/privacy-policy.
- Force24. Details regarding the way in which they handle personal information is contained in their privacy policy at https://force24.co.uk/privacy-policy/.
We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.
Where we store your personal information
Information you provide to us is stored on our secure servers in the United Kingdom, or on secure cloud-based services in a country within the European Economic Area. Some of your information may be transferred to members of Oliver Wight International in the United States of America or to recipients in countries approved by the UK government. We will take all steps reasonably necessary to ensure that your data is treated securely, including taking the following safeguards:
- Secure lockable desks and cupboards. Desks and cupboards are kept locked when not in use if they hold confidential information of any kind.
- Methods of disposal. Paper documents are disposed of by shredding in a manner that ensures confidentiality.
- Equipment. Our internal policies require that users lock or log-off from their computer when it is unattended.
- Firewalls and encryption. We apply industry-standard firewall protection and encryption technology using Fortigate 60f and Bitlocker.
- Training. We ensure our employees are trained in the importance of data security.
- Compliant agreements. Where we grant third parties access to your data, we will enter into a contract with them that complies with applicable data protection rules to ensure they process your data securely.
- Electronic access. All data stored electronically is password-protected. Where we have provided an authorised user with a password, that user is responsible for keeping this password confidential and is not permitted to share the password with anyone.
Overseas transfers
Some of the data that we collect from you may be transferred to third parties, like HubSpot, who operate our CRM system, and we may transfer information to members of Oliver Wight International in order to provide the best service to you, and this may mean the transfer and storage of data outside of the United Kingdom.
Whenever we transfer your personal information outside the United Kingdom, we ensure a similar degree of protection is afforded to it by ensuring that we apply appropriate safeguards (either by transferring data only to recipients in the European Economic Area, to recipients in countries determined by the United Kingdom to have adequate or equivalent levels of data protection, or by using specific contracts approved by the UK Information Commissioner).
Whilst we will take the safeguards outlined above, please let us know if you are concerned about the levels of data security in those countries, and we will endeavour to advise what steps will be taken to protect your data when stored overseas.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your data transmitted to our website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
How long we will store your personal information
The length of time that we will store your data will depend on the ‘legal basis’ for why we are using that data, as follows:
- Where we use/store your data because it is necessary for the performance of the contract between you and us. We will use/store your data for as long as it is necessary for the performance of the contract between you and us.
- Where we use/store your data because it is necessary for us to comply with a legal obligation to which we are subject. We will use/store your data for as long as it is necessary for us to comply with our legal obligations.
- Where we use/store your data because it is necessary for our legitimate business interests. We will use/store your data for as long as it is necessary for our legitimate business interests, or such earlier time as you ask us to stop. However, if we can demonstrate the reason why we are using/storing your data is more important than your interests, rights and freedoms, then we will be allowed to continue to use/store your data for as long as it is necessary for our legitimate business interests.
- Where we use/store your data because you have given us your specific, informed and unambiguous consent. We will use/store your data until you ask us to stop.
To determine the appropriate retention period for personal information, we consider the amount, nature and sensitive of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
Your Rights
You have various legal rights in relation to the information you give us, or which we collect about you, as follows:
- You have a right to access the information we hold about you free-of-charge, together with various information about why and how we are using your information, to whom we may have disclosed that information, from where we originally obtained the information and for how long we will use your information.
- You have the right to ask us to rectify any information we hold about you that is inaccurate or incomplete.
- You have the right to ask us to erase the information we hold about you (the ‘right to be forgotten’). Please note that this right can only be exercised in certain circumstances and, if you ask us to erase your information and we are unable to do so, we will explain why not.
- You have the right to ask us to stop using your information where: (i) the information we hold about you is inaccurate; (ii) we are unlawfully using your information; (iii) we no longer need to use the information; or (iv) we do not have a legitimate reason to use the information. Please note that we may continue to store your information, or use your information for the purpose of legal proceedings or for protecting the rights of any other person.
- You have the right to ask us to transmit the information we hold about you to another person or company in a structured, commonly-used and machine-readable format. Please note that this right can only be exercised in certain circumstances and, if you ask us to transmit your information and we are unable to do so, we will explain why not.
- Where we use/store your information because it is necessary for our legitimate business interests, you have the right to object to us using/storing your information. We will stop using/storing your information unless we can demonstrate why we believe we have a legitimate business interest which is more important than your interests, rights and freedoms.
- Where we use/store your data because you have given us your specific, informed and unambiguous consent, you have the right to withdraw your consent at any time.
- You have the right to object to us using/storing your information for direct marketing purposes.
If you wish to exercise any of your legal rights, please contact us by writing to the address at the top of this policy, by emailing us at [email protected] or by calling 01452 397200.
You also have the right, at any time, to lodge a complaint with the Information Commissioner’s Office if you believe we are not complying with the laws and regulations relating to the use/storage of the information you give us, or that we collect about you.
Opting out of receiving marketing communications
You can ask us to stop sending you marketing communications at any time by contacting us by writing to the address at the top of this policy, or by emailing us at [email protected]
Automated decision-making
We do not use automated decision-making processes.
Third party links
Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
Changes to this privacy policy
We may change this privacy policy from time to time by updating this page to reflect changes in law and/or our privacy practices. This privacy policy was last updated in April 2024.
Contact
Questions, comments and requests regarding this policy are welcomed and should be addressed to us by writing to the address at the top of this policy, or by emailing us at [email protected].