Phoenix Searches Limited (“Search Acumen“) understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits this website, www.search-acumen.co.uk (“Our Site”) and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
1. Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
“Account” means an account required to access and/or use certain areas and features of Our Site;
“Cookie” means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in Section 15, below; and
“Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;
2. Information About us
Our Site is owned and operated by Phoenix Searches Limited (“Search Acumen“), a limited Company registered in England under company number 8450163
Registered address: The Maidstone Studios, New Cut Road, Maidstone ME14 5NZ
VAT number: 168587648
Data Protection Officer: David Penney
Email address: email@example.com
Telephone number: 08002404746
Postal Address: As above
3. What Does This Policy Cover?
4. What is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
5. What Are My Rights?
Under the GDPR, you have the following rights, which we will always work to uphold:
b) The right to access the personal data we hold about you. Section 14 will tell you how to do this.
c) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Section 16 to find out more.
d) The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Section 16 to find out more.
e) The right to restrict (i.e. prevent) the processing of your personal data.
f) The right to object to us using your personal data for a particular purpose or purposes.
g) The right to data portability. This means that, if you have provided personal data to us directly, we am using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
h) Rights relating to automated decision-making and profiling. we do not use your personal data in this way.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Section 16
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office
6. What Data Do We Collect?
Identity Data: includes first name, last name, middle name, username (or similar identifier), company name and job title
Contact Data: includes email address, telephone number, postal address
Device Data: none
Financial Data: includes bank account and payment card details.
Technical Data: includes iP address, login data, web browser type and version, time zone, location and operating system.
Profile Data: includes your username and password, notification settings and preferences.
Usage Data: includes URL information about how you access and use Our Site, products and services.
Marketing Data: includes your preferences in receiving marketing communications from us
We may need to collect personal data under the terms of the contract we have entered, or are trying to enter into with you. You are not obliged to provide personal data to Search Acumen however, please be advised that if you fail to provide the data when requested, we may not be able to perform the contract and supply the product or service requested to you.
7. How Do We Collect Personal Data?
We collect personal data in the following ways:
Direct Interaction: includes giving us your identity, contact, transactional, usage and financial data by filling in online forms or contacting us via post, telephone or email. This includes personal data provided when:
You apply to become a customer of Search Acumen or user of our products or services
You use our services by logging into the Search Acumen platform, using your issued username and password, or ordering products and services from Our Site (or requesting an order be made via telephone or email)
You enter personal data into the Search Acumen platform in respect of products and services you wish to request
You store details of our products and services you have ordered or information contained within previously ordered products and services for retrieval at a later point e.g. a title register including personal data
You request marketing communications to be sent to you
You submit and enquiry or provide feedback to us
You contact us as a prospective employee of Search Acumen
8. How Do You Use My Personal Data?
Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data may be used for the following purposes:
Providing and managing your Account;
Providing and managing your access to our Site;
Personalising and tailoring your experience on our Site;
Supplying our products and services to you. Your personal details are required in order for us to enter into a contract with you.
Personalising and tailoring our products and services for you.
Communicating with you. This may include responding to emails or calls from you.
Supplying you with information by email that you have opted-in to (you may unsubscribe or opt-out at any time by using the unsubscribe option on the email you were sent).
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email, telephone, text message or post with information, news, and offers on our products and services. You will not be sent any unlawful marketing or spam. we will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.
We use the following automated systems for carrying out certain kinds of decision-making and profiling. If at any point you wish to query any action that we take on the basis of this or wish to request ‘human intervention’ (i.e. have someone review the action themselves, rather than relying only on the automated method), the GDPR gives you the right to do so. Please contact us to find out more using the details in Section 16.
The following automated decision-making method(s) may be used:
SalesForce.com CRM analytics.
The following automated profiling may take place:
Mailchimp.com Campaign Management Tools.
9. How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):
For the minimum period required by statute of limitations on any products and services we have provided you.
10. How and Where Do You Store my Personal Data?
The data we collect from you will be transferred, stored and processed using Amazon Web Servers (AWS) which are held within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the GDPR or to equivalent standards by law. AWS servers offer the highest level of security and are ISO 27001 compliant. If we transfer data outside of the EEA, Search Acumen will take steps to ensure that adequate privacy protection is established within the importing country and such protection aligned with the UK Data Protection legislation and UK GDPR.
11. Do You Share My Personal Data?
Search Acumen take all reasonable and possible steps to ensure that your personal data remains within the UK and EEA. However, in some cases we need to share data with other ATI group companies or third parties that are in countries outside of those areas, solely for the purpose in which we collect the personal data. We will always share a minimal amount of personal data necessary for the purpose of processing and, where possible, will safeguard the data by sharing the personal data in an anonymised form.
Whenever we transfer your personal data outside of the EEA, we ensure that appropriate safeguards are in place which meet the standards required by European and UK data protection laws. we use Standard Contractual Clauses approved by the European Commission and/or ensure that adequate safeguards are in place to ensure that your personal data is given the same protection it has in the UK and Europe. We share your personal data between Search Acumen and the ATI Group companies to ensure the efficient operation of our company and to provide high standards of client service.
We require any person or entity to whom we disclose personal data to respect the confidentiality and security of your personal data and to treat it in accordance with applicable laws and regulations. We do not permit recipients of your personal data to use the personal data for their own purposes, and we only allow them to process your personal data for specified purposes and in accordance with our instructions.
12. How Can I Control My Personal Data?
In addition to your rights under the GDPR, set out in Section 5, when you submit personal data via our Site, you may be given options to restrict our use of your personal data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails.
You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
13. Can I Withhold Information?
You may access certain areas of our Site without providing any personal data at all. However, to use all features and functions available on our Site you may be required to submit or allow for the collection of certain data.
14. How Can I Access my Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Section 16. To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within 10 days and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
16. How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details (for the attention of David Penney)
Email address: firstname.lastname@example.org
Telephone number: 08002404746
Postal Address: The Maidstone Studios, New Cut Road, Maidstone ME14 5NZ
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.