Edmund Group
Privacy Policy
Introduction
Welcome to Edmund Group Limited’s privacy policy.
Edmund Group Limited respects your privacy and is committed to safeguarding your personal data. This important policy describes our practices for collecting, using, maintaining, protecting, and disclosing the personal data we may collect from you or that you may provide when you visit our website or other digital properties, communications, or forms that link or refer to this notice (our “Website”). This policy applies to the personal data collected through our Website, regardless of the country where you are located.
Please read this policy carefully to understand our policies and practices for processing and storing your personal data. By engage with our Website, you accept and consent to the practices described in this policy. This notice may change from time to time (see Changes to this Policy, below). Your continued engagement with our Website after such revisions indicates that you accept and consent to them, so please check the notice periodically for updates.
This privacy policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.
Important Information And Who We Are
It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.
Edmund Group Limited is the controller and responsible for your personal data (collectively referred to as “Edmund Group”, “Edmund”, “we”, “our” or “us” in this privacy policy)
Contact Details
If you have any questions about this policy or our privacy practice, please contact us in the following ways:
Name: Edmund Group Limited
Address: Berkeley Suite, 35 Berkeley Square, Mayfair, London, England, W1J 5BF
Email: info@edmund.pro
Edmund Group is registered with the Information Commissioner’s Office (ICO) under registration number ZB140057.
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). See details within the Glossary. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes To The Privacy Policy And Your Duty To Inform Us Of Changes
We keep our privacy policy under regular review. This version was last updated on 14 August 2023.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third-Party Links
This 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 policy of every website you visit.
The Data We Collect And Hold?
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
• Identity Data includes name, username or similar identifier, title, date of birth and gender.
• Contact Data includes billing address, correspondence address, email address and telephone numbers.
• Financial Data includes bank account details.
• Transaction Data includes details about payments to and from you and other details of services you have received from us.
• Technical Data includes internet protocol (IP) address, your login 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 this website.
• Profile Data includes your username and password, services received from us, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our website and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
If You Fail To Provide Personal Data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.
How Is Your Personal Data Collected?
We use different methods to collect data from and about you including through:
• Direct interactions. You may give us information about you by filling in forms or by corresponding with us by phone, email or otherwise. This includes information you provide when you apply for or subscribe to our products or services, request marketing to be sent to you, participate in discussion boards or other social media functions on our Website, contribute to a survey, give us feedback, contact us and when you report a problem with our Website.
• Automated technologies or interactions. As you interact with our Website, we may automatically collect technical data about your equipment, browsing actions and patterns as specified above. We collect this information by using cookies and other similar technologies (see Cookies Policy within the Glossary).
• Third parties or publicly available sources. We may receive information about you from third parties including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies, data brokers, or aggregators, from publicly available sources such as LinkedIn, the Financial Services Register or Companies House.
How We Use Your Personal Data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. For example, where we are responding to your enquiry or in order to keep you up to date in relation to regulatory developments we consider may be of interest to you.
• Where we need to comply with a legal obligation.
Click here to find out more about the types of lawful basis that we will rely on to process your personal data.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
No automated decision-making or profiling is undertaken using the information we hold about you.
Purposes For Which We Will Use Your Personal Data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal grounds we are relying on to process your personal data where more than one ground has been set out in the table below.
To register you as a new client
(a) Identity
(b) Contact
Performance of a contract with you
To process and deliver a product or service to you, including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how clients use our services)
To enable you to provide feedback or complete a survey
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how clients use our products/services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Identity
(b) Contact
(c) Technical
(a) 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 or group restructuring exercise
(b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical
Necessary for our legitimate interests (to study how clients use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, client relationships and experiences
(a) Technical
(b) Usage
Necessary for our legitimate interests (to define types of clients for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you
(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
(f) Marketing and Communications
Necessary for our legitimate interests (to develop our products/services and grow our business)
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Promotional Offers From Us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.
Third-Party Marketing
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
Opting Out
You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, experience or other transactions.
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see Cookie Policy set out in the Glossary.
Change Of Purpose
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.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Disclosures Of Your Personal Data
We may share your personal data with the parties set out below for the purposes set out in the table above.
• Internal Third Parties as set out in the Glossary
• External Third Parties as set out in the Glossary
• Specific third parties such as Digital Marketing Services Providers. We periodically appoint digital marketing agents to conduct marketing activity on our behalf, such activity may result in the compliant processing of personal data.
• 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 data in the same way as set out in this privacy policy.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
International Transfers
Certain of our external third parties are based outside of the UK so their processing of your personal data will involve a transfer of data outside the UK. See External Third Parties identified in the Glossary.
Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring that either the transfer of personal data is limited to countries that have been deemed to provide an adequate level of protection for personal data or where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
Data Security Data Retention
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collect it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. 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.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of that information, the potential risk of harm from unauthorised use or disclosure of that information, the purposes for which we process that information, applicable legal, regulatory, tax, accounting or other requirements for holding that information, and whether we can achieve those purpose(s) through other means.
Where we have collected your personal information through our organisations conducting business, we will keep your personal information for as long as our business relationship continues; or, for as long as we have a commercial interest in holding your personal information, for example, with a view to doing business in the future.
Where you use our website and one of our cookies is activated, that cookie will operate for the duration set out in our Cookie Policy.
We will continue to provide you with regular regulatory updates until you confirm that you no longer wish to receive them.
For specific timeframes for how long we keep your personal information for, please contact us by emailing info@edmund.pro
Your Legal Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
• Request access to your personal data
• Request correction of your personal data
• Request erasure of your personal data
• Object to processing of your personal data
• Request restriction of processing your personal data
• Request transfer of your personal data
• Right to withdraw consent
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
If you wish to exercise any of the rights set out above, please contact us at info@edmund.pro
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Glossary
Lawful Basis
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
Third Parties
Internal Third Parties
Other companies in the Edmund Group and who are based in the UK.
External Third Parties
Service providers based who provide IT and system administration services. Such as:
• Edmund’s CRM tool, HubSpot. Customer data held on HubSpot is processed and secured in the EU before being transmitted and stored in the US. More information about how HubSpot stores and protects data can be found here: https://knowledge.hubspot.com/account/hubspot-cloud-infrastructure-frequently- asked-questions
• Microsoft Office 365 including SharePoint and therefore electronic versions of your personal information will be stored securely on servers within the UK and/or Europe, in accordance with the terms issued by Microsoft at the relevant time.
• Technical support providers, for example, assisting with our website.
Professional advisers and consultants acting as processors or joint controllers including lawyers, consultants, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based who require reporting of processing activities in certain circumstances.
Your Legal Rights
You have the right to:
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
• If you want us to establish the data's accuracy.
• Where our use of the data is unlawful but you do not want us to erase it.
• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Cookie Policy
Cookies are small text files that are placed on your device by a web server when you visit our website. We use cookies to identify your access and monitor usage and web traffic on our platform.
We use both persistent cookies and session cookies. A persistent cookie remains in your browser and will be read by us when you return to our website. Session cookies only last for the duration of a website visit or browser session.
We use the following types of cookies:
• Strictly necessary cookies – these are cookies that are required for the operation of our site. They include, for example, cookies that enable you to log into secure areas of our website.
• Analytical cookies – these allow us to recognise and count the number of unique visitors to our website and how they move around it. This helps us improve the way our website works and the content we provide on it.
• Functional cookies – these are used to recognise you when you return to our website.
• Targeting cookies – these record your visit to our website, the pages you view and the links you follow.
You can block cookies by activating the setting on your browser that allows you to refuse all or some cookies. However, if you do so, you may be unable to access parts of our website.
Your right to complain
If you are unhappy with the way in which we collect, process, retain, share or transfer your personal data, or with our handling of your exercise of your rights, we would welcome the opportunity to put things right for you in the first instance.
Please contact us by emailing info@edmund.pro to let us know about your concerns.
You may also complain to your local supervisory data protection authority about us, depending on where you are located.
In the UK, you can complain to the ICO if you are unhappy with how we have handled your personal information.
The ICO's address:
Information Commissioner’s Office
Wycliffe House,
Water Lane Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
You can also visit the ICO website: https://ico.org.uk/make-a-complaint/
