Privacy policy
Arete Research Services LLP (“Arete”, “us” or “we”) is aware of its obligations under the UK General Data Protection Regulation (UK GDPR)
and other data privacy legislation in force in the UK. We are committed to processing your data securely and transparently.
This privacy notice sets out the types of personal data that we collect and process about recipients of our services including when
you use our website at athenedata.com (the “Website”)
and in relation to individuals that participate in interviews with us. It also sets out how we use that information,
how long we keep it for and other relevant information about your data.
1.
Who we are
Arete is the data controller in relation to your personal data, meaning that it determines the processes to be used when
using your personal data. You may contact us at:
Privacy Officer
Arete Research Services LLP
1st Floor
10 Ely Place
London
EC1N 6RY
Tel: 0207 959 1300
E-mail: dataprivacy@arete.net
Privacy Officer
Arete Research Services LLP
1st Floor
10 Ely Place
London
EC1N 6RY
Tel: 0207 959 1300
E-mail: dataprivacy@arete.net
2.
Data protection principles
In relation to your personal data, we will:
•
Process it fairly, lawfully and in a clear, transparent way
•
Collect your data only for specified and specific purposes
•
Only collect the minimum information we need to meet the purpose
•
Only use it in the way that we have told you about
•
Ensure it is correct and up to date
•
Keep your data for only if we need it
•
Process it securely, reducing the risk of it being lost or stolen
3.
What data we collect about you
Personal data means any information capable of identifying an individual. We may process certain types of personal data
about you as follows:
Where we are required to collect personal data by law, or under the terms of the contract between us, you and/or your employer,
if you do not provide us with that data when requested, we may not be able to perform the contract. If you don't provide us
with the requested data, we may have to cancel our services with you or your employer. We do not collect sensitive data on our
client contacts or data of anyone under the age of 16.
•
Identity Data - may include your first and last name and business title
•
Contact Data - may include your email address, telephone number and business address
•
Profile Data - may include your username and password and your preferences
•
Usage Data - may include information about how you use our Website, platform, products and services
•
Technical Data - may include your login data, internet protocol addresses, browser type and version,
browser plug-in types and versions, time zone setting and location, operating system and platform and other technology
on the devices you use to access our website or platform
4.
Why we process your data
There are six lawful bases for processing personal data, which are:
We hold the following personal data of recipients of our services:
We may process your personal data for more than one lawful purpose. Please email us at dataprivacy@arete.net if you need details about the specific legal basis, we are relying on to process your personal data where more than one basis has been set out in the table above.
Direct 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 marketing.
We may also analyse your Identity, Contact, Technical, Usage and Profile data to form a view as to which products, services and offers may be of interest to you so that we can then send you relevant marketing communications.
We will get your express consent before we share your personal data with any third party for their own direct marketing purposes.
Opting out of marketing
You can ask us to stop sending you marketing communications at any time by following the opt-out links within any marketing communication sent to you or by contacting us using the contact details provided at the beginning of this policy.
If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes.
•
You give consent for us to process your data;
•
It is necessary to fulfil a contractual obligation;
•
It is necessary for us to comply with our legal obligations;
•
It is necessary in the legitimate interest of Arete to do so;
•
It is in the public interest to do so; and
•
It is in your vital interest to do so.
| Purpose/Activity | Type of data | Lawful basis for processing |
|---|---|---|
| Our customers | ||
| To register you as a new client contact |
|
|
| To provide our services to you via our Website, including your use of the Athene Platform |
|
|
To manage our ongoing relationship with you, which will include:
|
|
|
| To administer and protect our business, our website and our platform |
|
|
| To use data analytics to improve our website, platform, products and services |
|
|
| To send you relevant marketing communications and make personalised suggestions and recommendations to you about services that may be of interest to you |
|
|
| Athene Interview Participants | ||
| To participate in Athene interviews and use content you provide to us |
|
|
| To manage our ongoing relationship with you |
|
|
We may process your personal data for more than one lawful purpose. Please email us at dataprivacy@arete.net if you need details about the specific legal basis, we are relying on to process your personal data where more than one basis has been set out in the table above.
Direct 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 marketing.
We may also analyse your Identity, Contact, Technical, Usage and Profile data to form a view as to which products, services and offers may be of interest to you so that we can then send you relevant marketing communications.
We will get your express consent before we share your personal data with any third party for their own direct marketing purposes.
Opting out of marketing
You can ask us to stop sending you marketing communications at any time by following the opt-out links within any marketing communication sent to you or by contacting us using the contact details provided at the beginning of this policy.
If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes.
5.
How we collect your data
We collect personal data about you through a variety of different methods including:
•
Direct interactions: You may provide data when filling in forms on the website (or otherwise)
by communicating with us by phone, email, or otherwise, including when you subscribe to our services, create an
account on our website and/or request resources to be sent to you.
•
Automated technologies or interactions: As you use our website and/or our platform, we may automatically
collect technical data about your equipment, browsing actions and usage patterns. We collect this data by using cookies,
server logs and similar technologies. Please see our Cookie Policy for further details.
•
Third parties or publicly available sources: We may receive personal data about you from various third
parties and public sources, such as Bloomberg or LinkedIn.
6.
Sharing your data
Your data will be shared within Arete where it is necessary for staff to undertake their duties in the provision of services to
you or your employer. As part of email and server back-up services, we also share some of your data with outsourced IT providers
(Microsoft and Global Relay). We may also share your data with third parties to comply with a legal obligation upon us.
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.
Whilst your data is stored by third parties within the UK, we do share access to your data with our offices in US and Hong Kong. Whenever we transfer your personal data out of the UK to countries which have laws that do not provide the same level of data protection as the UK law, we always ensure that a similar degree of protection is afforded to it by ensuring that the following safeguards are implemented. We use the UK Addendum to the EU Standard Contractual Clauses as our appropriate safeguards for such restricted transfers outside of the UK. To obtain a copy of these contractual safeguards, please contact us using the contact details set out above.
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.
Whilst your data is stored by third parties within the UK, we do share access to your data with our offices in US and Hong Kong. Whenever we transfer your personal data out of the UK to countries which have laws that do not provide the same level of data protection as the UK law, we always ensure that a similar degree of protection is afforded to it by ensuring that the following safeguards are implemented. We use the UK Addendum to the EU Standard Contractual Clauses as our appropriate safeguards for such restricted transfers outside of the UK. To obtain a copy of these contractual safeguards, please contact us using the contact details set out above.
7.
Protecting your data
We are aware of the requirement to ensure your data is protected against accidental loss or disclosure, destruction and abuse.
We have implemented processes to guard against such. In addition, third parties must implement appropriate technical and
organisational measures to ensure the security of your data (see privacy policies of IT providers
Microsoft
and Global Relay).
8.
How long we keep your data for
We only keep your personal data for as long as necessary and in accordance with our legal and regulatory obligations. As a result,
whilst an organisation remains a client of Arete, we retain all data relating to that client relationship. Once a company is no
longer a client of Arete, we typically keep all data for seven years, other than personal contact and access information,
which may be deleted after two years.
9.
Your rights in relation to your data
The law on data protection gives you certain rights in relation to the data we hold on you. These are:
Where you have provided consent to our use of your data, you also have the unrestricted right to withdraw that consent at any time.
Withdrawing your consent means that we will stop processing the data that you had previously given us consent to use. There will
be no consequences for withdrawing your consent. However, in some cases we may continue to use the data where so permitted by
having a legitimate reason for doing so. If you wish to exercise any of the rights explained above, please contact our Privacy
Officer at dataprivacy@arete.net.
Exercising your rights
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.
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.
•
The right to be informed: This means that we must tell you how we use your data, and this is the purpose
of this privacy notice.
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The right of access: You have the right to access the data that we hold on you. To do so, you should make
a subject access request. You can read more about this in our Subject Access Request policy which is available from our
Privacy Officer.
•
The right for any inaccuracies to be corrected: If any data that we hold about you is incomplete or
inaccurate, you can require us to correct it.
•
The right to have information deleted: If you would like us to stop processing your data, you have the
right to ask us to delete it from our systems where you believe there is no reason for us to continue processing it.
•
The right to restrict the processing of the data: For example, if you believe the data we hold is
incorrect, we will stop processing the data (whilst still holding it) until we have ensured that the data is correct.
•
The right to portability: You may transfer the data that we hold on you for your own purposes.
•
The right to object to the inclusion of any information: You have the right to object to the way we
use your data where we are using it for our legitimate interests.
•
The right to regulate any automated decision-making and profiling of personal data: You have a right
not to be subject to automated decision making in way that adversely affects you.
Exercising your rights
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.
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.
10.
How to complain
We strive to meet the highest standards when collecting and using personal information. Complaints are taken very seriously,
and data subjects are encouraged to bring any issues to our attention. To do this either e-mail or write to:
Privacy Officer
Arete Research Services LLP
1st Floor
10 Ely Place
London
EC1N 6RY
Tel: 0207 959 1300
E-mail: dataprivacy@arete.net
The supervisory authority in the UK for data protection matters is the Information Commissioner’s Office (ICO). If you think your data protection rights have been abused or breached in any way by us, you are able to make a complaint to the ICO at ico.org.uk/make-a-complaint/.
Privacy Officer
Arete Research Services LLP
1st Floor
10 Ely Place
London
EC1N 6RY
Tel: 0207 959 1300
E-mail: dataprivacy@arete.net
The supervisory authority in the UK for data protection matters is the Information Commissioner’s Office (ICO). If you think your data protection rights have been abused or breached in any way by us, you are able to make a complaint to the ICO at ico.org.uk/make-a-complaint/.
11.
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.
30 October 2024