Privacy Notice

‍Who we are and important information

Sapient Insight Limited is a private limited company incorporated in England with company number 15091342. Our registered office is at 1 The Clock House, Brize Norton Road, Carterton, Oxfordshire, United Kingdom, OX18 3HN. [We are a registered code member of the Association of British Investigators UK GDPR Code of Conduct, which is listed by the Information Commissioner’s Office as an approved code.]

We provide open-source intelligence services to our clients in accordance with their instructions. We also carry out business development activities. We are responsible for this website.

Where we refer to “data protection law” in this notice, we are referring primarily to the UK GDPR, the EU GDPR and the Data Protection Act 2018. We respect the data protection and privacy rights of individuals, and we are committed to upholding high standards in this regard.

For the purposes of data protection law, when we process personal data, we typically do so as a controller. We are registered as a fee payer with the Information Commissioner’s Office under registration code ZB702620.

This notice is relevant to you if we process your personal data, including when you use our website, enquire about our services, request information including marketing material from us, or instruct us and become our client.

If you have any questions about this privacy notice or your personal data more generally, please contact us using the following details:

• Sapient Insight Limited, 1 The Clock House, Brize Norton Road, Carterton, Oxfordshire, United Kingdom, OX18 3HN

• info@sapient-insight.com

The personal data that we collect

Personal data means information about an individual from which they can be identified.

We may collect, use, store and transfer different kinds of personal data about you, which we have grouped together as follows:

• Identity Data: first name, last name, any previous names, username or similar identifier, marital status, title, date of birth and gender.

• Contact Data: billing address, delivery address, email address and telephone numbers.

• Financial Data: bank account and payment card details, National Insurance Number, HMRC records.

• Transaction Data: details about payments to and from you and other details of products and services you have purchased from us.

• Technical Data: 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, device ID and other technology on the devices you use to access this website.

• Profile Data: your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.  

• Usage Data: information about how you interact with and use our website, products and services.

• Marketing and Communications Data: your preferences in receiving marketing material from us and your communication preferences.

We may also collect Special Category Data and Criminal Convictions Data where we are legally required to do so, or where it is necessary for us to provide our services.

Special Category Data includes information that reveals details of race, ethnic origin, religious or political beliefs, sexual orientation, disability and health, and biometric data. We do not use this information for marketing purposes.

Criminal Convictions Data includes information relating to criminal convictions and offences, including court proceedings and allegations of a criminal nature.

We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.

How we collect your personal data

We use different methods to collect data from and about you including through:

• Your interactions with us. You may give us your personal data by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

• enquire about our products or services;

• instruct us as a client; or

• contact us or provide us with feedback.

• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our Cookie Policy for further details.

• Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:

• Technical Data is collected from analytics providers and search information providers.

• Contact, Financial and Transaction Data is collected from providers of technical, payment and delivery services.

• Identity and Contact Data is collected from data brokers or aggregators based outside the UK.

• Identity and Contact Data is collected from publicly available sources such as Companies House, the Electoral Register based inside the UK.

How we use your personal data

We must have a lawful basis to collect and use your personal data, and we typically rely on two or more of the following bases:

• Performance of a contract: Where we need to perform the contract that we are about to enter into or have entered into with you.

• Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests or those of our clients. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) 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).

• Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.

• Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.

To ensure that we process Special Category Data including information about criminal convictions in accordance with data protection law, we have an appropriate policy document in place.

Direct marketing

You may 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 communications.

We may also analyse your Identity, Contact, Technical, Usage and Profile Data to form a view of which products and services may be of interest to you, so that we can then send you relevant marketing communications.

Third-party marketing

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 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 above.

If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes.

Disclosure of your personal data

We may disclose your personal data to third parties where necessary to perform our contract with you, comply with our legal obligations, further to our legitimate interests, or if you have provided your consent for us to do so.

We require all third parties to respect the security of your personal data and to treat it in accordance with data protection 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

If we transfer your personal data to a third party, for instance a service provider, located outside of the United Kingdom, or the European Economic Area (EEA), in a country whose laws do not provide the same level of data protection as data protection law, we always ensure that a similar degree of protection is afforded to the data by ensuring that the country in question has been deemed to provide an adequate level of protection in accordance with the data protection laws, or by ensuring that appropriate safeguards are in place.

Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data Retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected 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 the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data.

Your legal rights

You have a number of rights under data protection laws in relation to your personal data.

You have the right to:

• Request access to your personal data (commonly known as a "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 in certain circumstances. 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) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.

• Object at any time to the processing of your personal data for direct marketing purposes.

• 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.

• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of 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; or

• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

If you wish to exercise any of the rights set out above, please contact us using the details above.

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.

Complaints

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). 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 notice and your duty to inform us of changes  

We keep our privacy notice under regular review.

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, for example a new address or email address.

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 notice or policy of every website you visit.