You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the official UK supervisory authority responsible for overseeing data protection compliance (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns first before you approach the ICO so we encourage you to contact us in the first instance. 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.
2. Who We Are
2.1 Here are our details:
- Our Website address is www.gambitpartners.co.uk
- Our company name is Gambit Partners Limited
- Our trading name is Gambit Partners
- Our registered address is Mazuma - Dragon House Princes Way, Bridgend Industrial Estate, Bridgend, Wales, CF31 3AQ
- Our ICO registration number is ZB342869
- Our nominated representative is Ajay Mistry and they can be contacted at firstname.lastname@example.org
3. What data we may collect
3.1 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 ability to identity a person has been completely removed (anonymous data).
3.2 We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name and last name or similar identifier. When you email, phone, make an enquiry on our Website or otherwise, we may collect information such as your first name, last name, email address and phone number.
- Contact Data includes billing address, invoicing address, email address and telephone numbers.
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments and other details of our Services you have purchased 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.
- Feedback Data includes your, feedback and survey responses given to us from time to time.
- 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/or our third parties and your communication preferences.
- Cookies Data like many websites, we use "cookies" to enhance your experience and gather information about visitors and visits to our websites. Please refer to the "Cookies" section below for information about cookies and how we use them and what kind.
3.4 We do not seek to 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.
4. How we may collect and use your data
4.1 We (or third party data processors, agents or sub-contractors acting on our behalf) may collect, store and use your personal information by way of different methods, in particular the following:
Direct interactions. You may give us your information by filling in forms via our Website or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- a) make an enquiry;
- b) use any of our Services or interact with us in relation to our provision of Services to you or your business;
- d) subscribe to our Services or publications;
- e) request marketing to be sent to you;
- f) enter a competition, promotion or survey; or
- g) give us some feedback.
4.2 In addition to the above, we may use your information in the following ways:
- a) To personalise your Website experience and to allow us to deliver the type of content and service offerings in which you are most interested.
- b) To administer a contest, promotion, survey or other site feature.
- c) If you have consented to receive our e-mail newsletter, we may send you periodic e-mails. If you would no longer like to receive promotional e-mails from us, please refer to the ‘Consent & Marketing’ section further below.
- d) Present Website content effectively to you.
- f) Carry out our contract(s) with you or your business.
- g) Provide the relevant Services to you or your business.
- h) Tell you about our charges or to contact you about payments due to us.
4.3 In some cases, the collection of personal data may be a statutory, contractual or policy requirement, and we will be limited in the services we can provide you if you don't provide your personal data in these cases.
4.4 Under UK GDPR, we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will generally only process your personal data if at least one of the following bases applies:
- a) Where we need to perform the contract we are about to enter into, or have entered into, with you.
- b) 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.
- c) Where we need to comply with a legal or regulatory obligation, for example compliance with health and safety, tax, legal, accounting, or other statutory obligations.
Consent & Marketing
4.5 Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to our marketing communications, or sending third party direct marketing communications to you, via email. You have the right to withdraw consent to marketing at any time by contacting us at email@example.com, or unsubscribing using the link in the email, and we will either delete your data from our systems or move your data to our "unsubscribe list". However, you acknowledge this could limit the information provided to you about the best possible services available to you/your business. If you have not opted-in to receive e-mail marketing, or we have not obtained your prior consent to send you e-mail marketing, you will not receive these e-mails.
6. Where we store your data, security & data retention
6.1 We may have a business need to transfer your data to providers outside the UK. If we do store or transfer data outside the UK, we will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and in accordance with the UK GDPR. Such steps may include, but not be limited to, the reliance on regulatory adequacy decisions or the use of regulatory-approved standard contractual terms between us and any third parties we engage with.
6.2 Data security is of great importance to us, and to protect your data we have put in place appropriate physical, electronic and managerial procedures to safeguard and secure data collected through our processing of your information. 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.
6.3 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.
6.4 We have implemented security measures such as a firewall to protect any data and maintain a high level of security.
6.5 Notwithstanding the security measures that we take, it is important to remember that the transmission of data via the internet may not be completely secure and we cannot guarantee it. You are advised to take suitable precautions when transmitting to us data via the internet and you acknowledge the risk that any sending of that data may turn out not to be secure despite our efforts.
6.6 We will keep personal data for as long as is necessary which is usually the life of our business relationship with you and up to a period of seven years after our relationship has ended. We may, however, be required to retain personal data for a longer period of time to ensure we comply with our legislative and regulatory requirements. We review our data retention obligations to ensure we are not retaining data for longer than we are legally obliged to.
7. Disclosing your information
7.1 We are allowed to disclose your information in the following cases:
- 7.1.1 If we want to sell our business, or our company, we can disclose it to the potential buyer.
- 7.1.2 We can disclose it to other businesses in our company group (where applicable).
- 7.1.3 We can disclose it if we have a legal obligation to do so, or in order to protect other people's property, safety or rights.
- 7.1.4 We can exchange information with others to protect against fraud or credit risks.
7.2 We may contract with third parties to supply services to you on our behalf. These may include payment processing, hosted solutions (such as CRM systems or client database platforms), search engine facilities, advertising and marketing providers. In some cases, the third parties may require access to some or all of your data.
7.3 Where any of your data is required for such a purpose, we will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under UK GDPR and the law. Any third party that we share data with will not be permitted to use it for any other purpose than fulfilling their contract with us.
8. Your rights
8.1 When you submit information to us, you may be given options to restrict our use of your data. We aim to give you strong controls on our use of your data (including the ability to opt-out of receiving emails from us which you may do by unsubscribing).
8.2 Under the UK GDPR, you have the right to:
- request access to, deletion of or correction of your personal data held by us at no cost to you (unless an exception applies by law);
- request that your personal data be transferred to another person (data portability);
- restrict processing; and
- object to processing of your personal data.
10. English law