What does this policy cover?
This policy describes how Consulum (“we” or “us”) will make use of your data when you interact with us through our website currently located at www.consulum.com.
It also describes your data protection rights, including the right to object to some of the processing that we carry out. More information about your rights, and how to exercise them, is set out in the “What rights do I have?” section below. Our website is not intended for or directed at anyone under the age of 18. We do not intentionally or knowingly collect or maintain personal data relating to anyone under the age of 18.
Summary of how we use your data
• We use your personal data in order to provide the services to you, for service administration purposes, to personalize the content you see on our website, to identify your location and to improve the services offered to you.
• Where we rely on your consent, such as for processing your data in order to provide personalized services to you, or sending direct marketing in relation to our relevant products and services, or other products and services provided by us, you can withdraw this consent at any time.
• Respond to your request for information and provide you with more effective and efficient customer service.
• Establish, exercise, or defend our legal rights where it is necessary for our legitimate interests or the legitimate interests of others.
We will only use your personal data for the purposes 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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
What information do we collect?
We collect and process personal data about you when you interact with our website or if you interact with us in person. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
• Identity Data such as first name, maiden name, last name, username or similar identifier.
• Contact Data such as email address and telephone numbers.
• Technical Data such as IP address, 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 and password, preferences, feedback and survey responses.
• Usage Data such as information about how you use our website and services.
• Marketing and Communications Data such as your preferences in receiving marketing from us and our third parties and your communication preferences.
What information do we receive from third parties?
Sometimes, we receive information about you from third parties.
How do we use this information, and what is the legal basis for this use?
We process this personal data for the following purposes:
• As required to conduct our business and pursue our legitimate interests, in particular:
o communicating with you
o sharing your data as required for the service from time to time
o to monitor your use of our website and online services, and use your information to help us monitor, improve and protect our content, services and website, to provide you with the most user-friendly navigation experience (both online and offline)
o to personalize our website (including any future websites), products or services for you
o we use information you provide to investigate any complaints received from you or from others about our website or our products or services
o we will use data in connection with legal claims, compliance, regulatory and investigative purposes as necessary (including disclosure of such information in connection with legal process or litigation)
• Where you give us consent:
o we may send you direct marketing in relation to our relevant services, or other services provided by us or our affiliates
o we place cookies and use similar technologies in accordance with our Cookies Policy and the information provided to you when those technologies are used
o on other occasions where we ask you for consent, we will use the data for the purpose which we explain at that time, such as for the purposes of preparing user recommendations.
• For purposes which are required by law in response to requests by government or law enforcement authorities conducting an investigation.
Withdrawing consent or otherwise objecting to direct marketing
Where we rely on your consent, you will always be able to withdraw that consent, although we may have other legal grounds for processing your data for other purposes, such as those set out above. In some cases, we are able to send you direct marketing without your consent, where we rely on our legitimate interests. You have the right to opt-out of direct marketing. You can do this by contacting us at [email protected]
Who will we share this data with, where and when?
We will keep your data generally confidential, but we may share your data in the following instances:
• We will share your personal data with third parties where we obtain your consent at that time. We will only share the specific personal data which you authorize us to share with such third party. In such case they will be a data controller and they may have their own privacy terms detailing how they use that personal data.
• Personal data may be shared with government authorities and/or law enforcement officials if mandated by law or if required for the legal protection of our legitimate interests in compliance with applicable laws.
• Personal data may also be shared with third party service providers, who will process it on behalf of us for the purposes identified above. Such third parties include (without limitation) providers of website hosting, maintenance, call center operation and identity checking.
• Personal data may also be shared with professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services to us.
• In the event that our service is sold or integrated with another business, your details will be disclosed to our advisers and any prospective purchaser’s adviser and will be passed to the new supplier of such services.
• If you are accessing our website from within the European Economic Area (“EEA”), your data might be accessed, collected and/or stored on servers outside of the EEA.
What rights do I have?
You have the right to ask us for a copy of your personal data; to correct, delete or restrict (stop any active) processing of your personal data; and to obtain the personal data you provide to us for a contract or with your consent in a structured, machine readable format. In some cases where you have requested that your personal data is deleted, we may still have to keep this data as the removal of such data will impact other data. In such cases, you can request that such data is anonymized.
In addition, you can object to the processing of your personal data in some circumstances in particular, where we don’t have to process the data to meet a contractual or other legal requirement, or where we are using the data for direct marketing.
These rights may be limited, for example if fulfilling your request would reveal personal data about another person, or if you ask us to delete information which we are required by law to keep or where we have compelling legitimate interests in keeping.
To exercise any of these rights, you can get in touch with us using the details set out below.
The provision of certain information may be mandatory for the provision of certain services: if the relevant data is not provided, then we may not be able to provide you with certain services. All other provision of your information is optional. However, note that failure to provide the optional data means that we will not be able to send you communications about the goods and services that may be of interest to you, nor personalise the way that our content is presented to you.
How do I get in touch with you?
We hope that we can satisfy queries you may have about the way we process your data. If you have any concerns about how we process your data, or would like to opt-out of direct marketing, you can get in touch by emailing us at [email protected]
How long will you retain my data?
We will only keep your content for as long as is reasonably required for the purpose(s) for which it was submitted. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
Where we process personal data for marketing purposes or with your consent, we process the data until you ask us to stop and for a reasonable period after this (to allow us to implement your requests). We also keep a record of the fact that you have asked us not to send you direct marketing or to process your data indefinitely so that we can respect your request in future.