EXTERNAL PRIVACY NOTICE

(A) This Notice

This Notice is issued by The Cambridge Code Limited on behalf of itself, its subsidiaries and its affiliates (together, “The Cambridge Code”, “we”, “us” and “our”) and is addressed to our users, clients and other individuals outside our organisation with whom we interact, including clients, visitors to our Sites, and users of our services (together, “you”). Defined terms used in this Notice are explained in Section (S) below.

For the purposes of this Notice, The Cambridge Code Limited is the Controller. Contact details are provided in Section (R) below.

This Notice may be amended or updated from time to time to reflect changes in our practices with respect to the Processing of Personal Data, or changes in applicable law. We encourage you to read this Notice carefully, and to regularly check this page to review any changes we might make in accordance with the terms of this Notice.

(B) Collection of Personal Data

Collection of Personal Data: We may collect Personal Data about you from the following sources:
• Data you provide: We may obtain your Personal Data when you provide it to us (e.g., where you contact us via email or telephone, or by any other means).
• Relationship data: We may collect or obtain your Personal Data in the ordinary course of our relationship with you (e.g., if you obtain or procure a service from us).
• Data you make public: We may collect or obtain your Personal Data that you manifestly choose to make public.
• Site data: We may collect or obtain your Personal Data when you visit any of our Sites or use any features or resources available on or through a Site.
• Registration details: We may collect or obtain your Personal Data when you use, or register to use, any of our Sites, or services.
• Content and advertising information: If you choose to interact with any third party content or advertising on a Site, we may receive Personal Data about you from the relevant third party.
• Third party information: We may collect or obtain your Personal Data from third parties who provide it to us (e.g., Your employer, prospective employer or organisations that you are associated with, etc.)

(C) Creation of Personal Data

We may also create Personal Data about you, such as records of your interactions with us, reports or analysis about you derived from information provided to us by you and/or a third party and created by means of human and/or machine application or intervention, and any interactions we have with third parties concerning you or on your behalf. Any such Personal Data we create shall be made available to you on request.

(D) Categories of Personal Data we may Process

We may Process the following categories of Personal Data about you:
• Personal details: given name(s); preferred name;.
• Demographic information: gender; date of birth / age; nationality; salutation; title; and language preferences.
• Contact details: correspondence address; telephone number; and email address.
• Consent records: records of any consents you may have given, together with the date and time, means of consent and any related information (e.g., the subject matter of the consent).
• Data relating to our Sites: device type; operating system; browser type; browser settings; IP address; language settings; dates and times of connecting to a Site; username; password; security login details; usage data; aggregate statistical information.
• Employer or Organisational details: where you interact with us in your capacity as an employee or member, or prospective employee or member of another organisation, the name, address, telephone number and email address of your employer/prospective employer or organisation/prospective organisation, to the extent relevant.
• Content and advertising data: records of your interactions with our online advertising and content, records of advertising and content displayed on pages displayed to you, and any interaction you may have had with such content or advertising (including mouse hover, mouse clicks, any forms you complete (including incomplete forms not submitted) and any touchscreen interactions).
• Views and opinions: any views and opinions that you choose to send to us, or publicly post about us on social media platforms.
• Output about you or referencing you in the form of reports, feedback and follow-up data containing our scientific or professional opinion derived from the use of our tools, expertise and analysis

(E) Lawful basis for Processing Personal Data

In Processing your Personal Data in connection with the purposes set out in this Notice, we may rely on one or more of the following legal bases, depending on the circumstances:
• Consent: We may Process your Personal Data where we have obtained your prior, express consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way);
• Contract: We may Process your Personal Data where the Processing is necessary in connection with any contract that you may enter into with us. For example your agreement to answer the questions set out in our on line questionnaire constitutes part of our agreement to provide you with a report;
• Legitimate Interest: We may Process your Personal Data where the Processing is necessary or beneficial in pursuit of our legitimate interests. For example, to ensure that the services we provide are suitable for the purposes for which they are utilised and identify potential opportunities for improvement
• Legal Obligation: We may Process your Personal Data where the Processing is necessary to enable us to comply with our statutory or other legal obligations.

(F) Sensitive Personal Data

We will seek to minimise the collection or otherwise Processing of your Sensitive Personal Data. However, it may be necessary to process your Sensitive Personal Data to enable us to provide the Services to which you have agreed or to comply with our legal obligations and where we do so we rely on one of the following legal bases:
• Consent: We may Process your Sensitive Personal Data where we have, in accordance with applicable law, obtained your prior, express consent prior to Processing your Sensitive Personal Data (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).
• Legal Obligation: We may Process your Personal Data where the Processing is necessary to enable us to comply with our statutory or other legal obligations

(G) Purposes for which we may Process your Personal Data

The purposes for which we may Process Personal Data, subject to applicable law, include:
• Provision of services to you: providing our Sites, or services to you including the provision of online reports; providing you with services that you have requested; providing you with promotional items at your request; and communicating with you in relation to those services.
• Compliance checks: fulfilling our compliance obligations, including ‘Know Your Client’ checks; and confirming and verifying your identity (including by using credit reference agencies); and screening against government and/or law enforcement agency sanctions lists and other legal restrictions.
• Our Sites: operating and managing our Sites; providing content to you; displaying advertising and other information to you; communicating and interacting with you via our Sites; and notifying you of changes to any of our Sites, or our services.
• Communications: communicating with you via any means (including via email, telephone, text message, social media, post or in person) news items and other information in which you may be interested, subject to ensuring that such communications are provided to you in compliance with applicable law; maintaining and updating your contact information where appropriate; and obtaining your prior, opt-in consent where required.
• Communications and IT operations: management of our communications systems; operation of IT security systems; and IT security audits.
• Financial management: sales; finance; corporate audit; and vendor management.
• Surveys: engaging with you for the purposes of obtaining your views on our services.
• Security: physical security of our premises (including records of visits to our premises; and CCTV recordings); and electronic security (including login records and access details).
• Investigations: detecting, investigating and preventing breaches of policy, and criminal offences, in accordance with applicable law.
• Legal proceedings: establishing, exercising and defending legal rights.
• Legal compliance: compliance with our legal and regulatory obligations under applicable law.
• Improving our Sites, services: identifying issues with our Sites, or our services; planning improvements to our Sites, or our services; and creating new Sites, or services.

(H) Disclosure of Personal Data to third parties

We may disclose your Personal Data to:
• legal and regulatory authorities, upon request, or for the purposes of reporting any actual or suspected breach of applicable law or regulation;
• accountants, auditors, lawyers and other outside professional advisors to the Cambridge Code, subject to binding contractual obligations of confidentiality;
• third party Processors (such as payment services providers; shipping companies; etc.), located anywhere in the world, subject to the requirements noted below in this Section (H);
• any relevant party, law enforcement agency or court, to the extent necessary for the establishment, exercise or defence of legal rights;
• any relevant party for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties, including safeguarding against and the prevention of threats to public security;
• any relevant third party acquirer(s), in the event that we sell or transfer all or any relevant portion of our business or assets (including in the event of a reorganization, dissolution or liquidation); and
• any relevant third party provider, where our Sites use third party advertising, plugins or content. If you choose to interact with any such advertising, plugins or content, your Personal Data may be shared with the relevant third party provider. We recommend that you review that third party’s privacy policy before interacting with its advertising, plugins or content.

If we engage a third-party Processor to Process your Personal Data, the Processor will be subject to binding contractual obligations to: (i) only Process the Personal Data in accordance with our prior written instructions; and (ii) use measures to protect the confidentiality and security of the Personal Data; together with any additional requirements under applicable law.

(I) Where Personal Data will be held

Personal may be held at our offices, and third-party agencies, service providers, representatives and agents as described above. We have security measures in place to seek to ensure that there is appropriate security for information we hold.

(J) Data security

We have implemented appropriate technical and organisational security measures designed to protect your Personal Data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access, and other unlawful or unauthorised forms of Processing, in accordance with applicable law.

Because the internet is an open system, the transmission of information via the internet is not completely secure. Although we will implement all reasonable measures to protect your personal data, we cannot guarantee the security of your data transmitted to us using the internet – any such transmission is at your own risk and you are responsible for ensuring that any Personal Data that you send to us are sent securely.

(K) Data accuracy

We take every reasonable step to ensure that:
• your Personal Data that we Process are accurate and, where necessary, kept up to date; and
• any of your Personal Data that we Process that are inaccurate (having regard to the purposes for which they are Processed) are erased or rectified without delay.

From time to time we may ask you to confirm the accuracy of your Personal Data.

(L) Data minimisation

We take every reasonable step to ensure that your Personal Data that we Process are limited to the Personal Data reasonably necessary in connection with the purposes set out in this Notice. In the context of the services we provide Processing of additional Personal Data can help to ensure the accuracy and completeness of our reports and other output to the benefit of all interested parties.

(M) Data retention

We take every reasonable step to ensure that your Personal Data are only Processed for the minimum period necessary for the purposes set out in this Notice.

The criteria for determining the duration for which we will keep your Personal Data are as follows: we will retain copies of your Personal Data in a form that permits identification only for as long as is necessary in connection with the purposes set out in this Notice, unless applicable law requires a longer retention period. In particular, we may retain your Personal Data for the duration of any period necessary to establish, exercise or defend any legal rights.

(N) Your legal rights

Subject to applicable law, you may have a number of rights regarding the Processing of your Relevant Personal Data, including:
• the right not to provide your Personal Data to us (however, please note that we may be unable to provide you with the full benefit of our Sites, or our services, if you do not provide us with your Personal Data – e.g., we may not be able to process your orders without the necessary details);
• the right to request access to, or copies of, your Relevant Personal Data, together with information regarding the nature, Processing and disclosure of those Relevant Personal Data;
• the right to request rectification of any inaccuracies in your Relevant Personal Data;
• the right to request, on legitimate grounds:
• erasure of your Relevant Personal Data; or
• restriction of Processing of your Relevant Personal Data;
• the right to object, on legitimate grounds, to the Processing of your Relevant Personal Data by us or on our behalf;
• the right to have certain Relevant Personal Data transferred to another Controller, in a structured, commonly used and machine-readable format, to the extent applicable;
• where we Process your Relevant Personal Data on the basis of your consent, the right to withdraw that consent (noting that such withdrawal does not affect the lawfulness of any Processing performed prior to the date on which we receive notice of such withdrawal, and does not prevent the Processing of your Personal Data in reliance upon any other available legal bases); and
• the right to lodge complaints with a Data Protection Authority regarding the Processing of your Relevant Personal Data by us or on our behalf.

To exercise one or more of these rights, or to ask a question about these rights or any other provision of this Notice, or about our Processing of your Personal Data, please use the contact details provided in Section (R) below. Please note that:
• we may require proof of your identity before we can give effect to these rights; and
• where your request requires the establishment of additional facts (e.g., a determination of whether any Processing is non-compliant with applicable law) we will investigate your request reasonably promptly, before deciding what action to take.

(O) Cookies and similar technologies

When you visit a Site we may place Cookies onto your device, or read Cookies already on your device, subject always to obtaining your consent, where required, in accordance with applicable law. We use Cookies to record information about your device, your browser and, in some cases, your preferences and browsing habits. We may Process your Personal Data through Cookies and similar technologies.

(P) Terms of Use

All use of our Sites, or our services is subject to our Terms of Use. We recommend that you review our Terms of Use regularly, in order to review any changes we might make from time to time.

(Q) Direct marketing

We may Process your Personal Data to contact you via email, telephone, direct mail or other communication formats to provide you with information regarding services that may be of interest to you. If we provide services to you, we may send information to you regarding our services, upcoming promotions and other information that may be of interest to you, using the contact details that you have provided to us and always in compliance with applicable law.

You may unsubscribe from our promotional email list at any time by simply clicking on the unsubscribe link included in every promotional email we send. After you unsubscribe, we will not send you further promotional emails, but we may continue to contact you to the extent necessary for the purposes of any services you have requested.

(R) Contact details

If you have any comments, questions or concerns about any of the information in this Notice, or any other issues relating to the Processing of Personal Data carried out by us, or on our behalf, please contact:

The Cambridge Code Limited
4 Kensington Cloisters
5 Kensington Church Street
London
W8 4LD
Info@thecambridgecode.com
020 7368 5100

(S) Definitions

• “Controller” means the entity that decides how and why Personal Data are Processed. In many jurisdictions, the Controller has primary responsibility for complying with applicable data protection laws.

• “Cookie” means a small file that is placed on your device when you visit a website (including our Sites). In this Notice, a reference to a “Cookie” includes analogous technologies such as web beacons and clear GIFs.

• “Data Protection Authority” means an independent public authority that is legally tasked with overseeing compliance with applicable data protection laws.

• “Personal Data” means information that is about any individual, or from which any individual is directly or indirectly identifiable, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual.

• “Process”, “Processing” or “Processed” means anything that is done with any Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

• “Processor” means any person or entity that Processes Personal Data on behalf of the Controller (other than employees of the Controller).

• “Relevant Personal Data” means Personal Data in respect of which we are the Controller. It expressly does not include Personal Data of which we are not the Controller.

• “Sensitive Personal Data” means Personal Data about race or ethnicity, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, sexual life, any actual or alleged criminal offences or penalties, national identification number, or any other information that may be deemed to be sensitive under applicable law.

• “Site” means any website operated, or maintained, by us or on our behalf.

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