PRIVACY POLICY

Please read this privacy policy carefully as it contains important information on Transcend and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us.

 

ABOUT THIS PRIVACY POLICY

This Privacy Policy applies when you visit our website www.wetranscend.co.uk. It also applies where we are in contact with you in other ways whether in your capacity as a director, shareholder, partner, employee or other representative of a company or other organisation.

This Privacy Policy does not apply to information you might provide to us or we might collect in the context of an active business relationship where we supply you with tools, services or solutions. In this case, our Client Data Protection Policy will apply.

ABOUT US

We are Transcend Group Limited, a limited company registered in England and Wales Transcend Group Limited is a private limited company registered in England and Wales under number 8953502. Its registered address is Sears Business Centre, 3-9 Station Street, Sittingbourne, ME10 3DU (“TGL”, “we”, “our”, and “us”).
We are registered with the UK Information Commissioner’s Office (“ICO”) under registration number ZA058676.

GETTING IN TOUCH

We are not required to appoint a formal data protection officer under data protection laws. However, we have appointed a Privacy Manager who you can contact about any queries you may have in relation to this Privacy Policy. Our Privacy Manager is Paul Glover.

If you have any questions about our privacy policy or your information, or to exercise any of your rights as described in this privacy policy or under data protection laws, you can contact us:

By post: Privacy Manager (Paul Glover), Transcend Group Limited, Sears Business Centre, 3-9 Station Street, Sittingbourne, Kent. ME10 3DU
By telephone: +44 (0)20 7628 2000
By email: privacy@wetranscend.co.uk

DATA PROTECTION PRINCIPLES

TGL adheres to the following principles when processing your personal data:
1. Lawfulness, fairness and transparency – data must be processed lawfully, fairly and in a transparent manner.
2. Purpose limitation – data must be collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes.
3. Data minimisation – data must be adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
4. Accuracy – data must be accurate and, where necessary, kept up to date.
5. Storage limitation – data must be kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed.
6. Integrity and confidentiality – data must be processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage by using appropriate technical or organisational measures.

INFORMATION WE COLLECT

Information you provide us

You may choose to provide us with personal data when you are introduced to us, when we meet you in person, or when we are in contact by phone, email, via our website or otherwise.
Personal data from our contacts, which covers both potential and prior customers, as well as potential and prior employees, are held in our customer relationship management tool (CRM tool). This information is entered into the CRM tool after contact is made between a director or staff member of Transcend Group and a business contact.
The categories of personal data you provide includes:
• first and last name;
• job title and company name;
• email address;
• phone numbers;
• postal address;
• marketing and communications data includes your preferences in receiving marketing from us and your communication preferences.

Information we collect from third parties

We collect most of this information from you directly. However, we may also collect information about you:
• from publicly accessible sources, e.g. Companies House;
• from third party sources of information, e.g. due diligence providers;
• which you have made public on websites associated with you or your company or on social media platforms such as LinkedIn;
• from a third party, e.g. a person who has introduced you to us or other professionals you may engage.

Information we collect online

We collect, store and use information about your visits to our website and about your computer, tablet, mobile or other device through which you access our website. This includes the following:
• technical information, including the Internet protocol (IP) address, browser type, internet service provider, device identifier, your login information,  time zone setting, browser plug-in types and versions, operating system and platform, and geographical location;
• information about your visits and use of the Site, including the full Uniform Resource Locators (URL), clickstream to, through and from our Site, pages you viewed and searched for, page response times, length of visits to certain pages, referral source/exit pages, page interaction information (such as scrolling, clicks and mouse-overs), and website navigation and search terms used;
• information collected by cookies on our website (for more information on cookies, please see the section on cookies below).

When visitors leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection

Sensitive personal data

We do not generally seek to collect sensitive (or special categories of) personal data. Sensitive personal data is defined by data protection laws to include personal data revealing a person’s racial or ethnic origin, religious or philosophical beliefs, or data concerning health. If we do collect sensitive personal data, we will ask for your explicit consent to our proposed use of that information at the time of collection.

Children

Our website is not intended for or directed at children under the age of 16 years and we do not knowingly collect data relating to children under this age.

HOW WE USE YOUR INFORMATION

The purpose for which we use and process your information (excluding sensitive personal data) and the legal basis on which we carry out each type of processing is explained below.

Purposes for which we will process the information
To provide you with information and services that you request from us.
To send you alerts, newsletters, bulletins, announcements, and other communications concerning TGL, HR industry developments or notifications we believe may be of interest to you.
To invite you to seminars, events, or other functions we believe may be of interest to you.
To enforce the terms and conditions and any contracts entered into with you.
To send you information regarding changes to our policies, other terms and conditions and other administrative information.
To administer our website including troubleshooting, data analysis, testing, research, statistical and survey purposes; To improve our website to ensure that consent is presented in the most effective manner for you and your computer, mobile device or other item of hardware through which you access our website; and To keep our website safe and secure.
Legal Basis for the processing
It is in our legitimate interests to respond to your queries and provide any information requested to generate and develop business. To ensure we offer a good and responsive service, we consider this use to be proportionate and will not be prejudicial or detrimental to you.
It is in our legitimate interests to market our services. We consider this use to be proportionate and will not be prejudicial or detrimental to you.
You will always be able to opt-out of receiving direct marketing-related email communications or text messages by following the unsubscribe link.
It is in our legitimate interests to market our services. We consider this use to be proportionate and will not be prejudicial or detrimental to you.
You will always be able to opt-out of receiving direct marketing-related email communications or text messages by following the unsubscribe link.
It is in our legitimate interests to enforce our terms and conditions of service. We consider this use to be necessary for our legitimate interests and proportionate.
It is in our legitimate interests to ensure that any changes to our policies and other terms are communicated to you. We consider this use to be necessary for our legitimate interests and will not be prejudicial or detrimental to you.
For all these categories, it is in our legitimate interests to continually monitor and improve our services and your experience of our website and to ensure network security. We consider this use to be necessary for our legitimate interests and will not be prejudicial or detrimental to you.

Where we rely on legitimate interests as a lawful basis, we will carry out a balancing test to ensure that your interests, rights and freedoms do not override our legitimate interests. If you want further information on the balancing test we have carried out, you can request this from our Privacy Manager.

If you do not wish to provide us with your personal data and processing such information is necessary for the performance of a contract with you, we may not be able to perform our obligations under the contract between us.

TGL 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 we need to use your personal data for an unrelated purpose, we will notify you in a timely manner and we will explain the legal basis which allows us to do so.

EMAIL MARKETING

For email marketing to an individual subscriber (that is, a non-corporate email address) with whom we have not previously engaged as a client, we need your consent to send you unsolicited email marketing.
Where you provide consent, you can withdraw your consent at any time, but without affecting the lawfulness of processing based on consent before its withdrawal.
You have the right to opt out of receiving email marketing communications from us at any time by:
• contacting our Privacy Manager using the contact details set out above; or
• using the “unsubscribe” link in emails.

WHO WE SHARE YOUR PERSONAL DATA WITH

We will only share personal data with others when we are legally permitted to do so.  When we share data with others, we put contractual arrangements and security mechanisms in place to protect the data and to comply with our data protection, confidentiality and security standards.

Personal data held by us may be transferred to:
• Third party organisations that provide applications/functionality, data processing or IT services to us. We use third parties to support us in providing our services and to help provide, run and manage our IT systems.  For example, providers of information technology, cloud based software as a service providers, identity management, website hosting and management, data analysis, data back-up, security and storage services
• Third party organisations that otherwise assist us in providing goods, services or information
• Auditors and other professional advisers
• Law enforcement or regulatory agencies or those required by law or regulations

Occasionally, we may receive requests from third parties with authority to obtain disclosure of personal data, such as to check that we are complying with applicable law and regulation, to investigate an alleged crime or to establish, exercise or defend TGL’s legal rights, protect the vital interests of a person.  We will only fulfil requests for personal data where we are permitted to do so in accordance with applicable law or regulation.

In addition, TGL may disclose information about you in the following circumstances:
• in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
• if all or substantially all of TGL’s assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets;

INTERNATIONAL TRANSFERS

Where possible, personal data resides within the UK territory but may be transferred to, and stored at, a destination outside the European Economic Area (EEA). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. We will take all reasonable steps to ensure that your data is treated securely, in accordance with this privacy statement.

We have taken steps to ensure all personal data is provided with adequate protection and that all transfers of personal data outside the EEA are done lawfully.  Where we transfer personal data outside of the EEA to a country not determined by the European Commission as providing an adequate level of protection for personal data, the transfers will be under an agreement which covers the EU requirements for the transfer of personal data outside the EU.

SECURITY OF YOUR PERSONAL DATA

We use physical and procedural security measures to protect information from the point of collection to the point of destruction. This includes encryption, firewalls, access controls, policies and other procedures to protect information from unauthorised access.

Where data processing is carried out on our behalf by a third party, we take steps to ensure that appropriate security measures are in place to prevent unauthorised disclosure of personal data.

Despite these precautions, however, TGL cannot guarantee the security of information transmitted over the Internet or that unauthorized persons will not obtain access to personal data. In the event of a data breach, TGL have put in place procedures to deal with any suspected breach and will notify you and any applicable regulator of a breach where required to do so.

HOW LONG WE KEEP YOUR PERSONAL DATA

Your personal data will not be kept for longer than is necessary for the purposes for which it was collected and processed and for the purposes of satisfying any legal, accounting, or reporting requirements.

The general criteria we aim to use for retaining different types of personal data, includes the following:
• General queries – when you make an enquiry or contact us by email or telephone, we will retain your information for as long as necessary to respond to your queries. After this period, we will not hold your personal data for longer than six years if we have not had any active subsequent contact with you;
• Direct marketing – where we hold your personal data on our database for direct marketing purposes, we will retain your information for no longer than six years if we have not had any active subsequent contact with you.
• Legal and regulatory requirements – we may need to retain personal data for up 7 years after we cease providing services and products to you where necessary to comply with our legal obligations, resolve disputes or enforce our terms and conditions.

If you leave a comment on our website, the comment and its metadata are retained indefinitely. This is so we can recognise and approve any follow-up comments automatically instead of holding them in a moderation queue.

YOUR RIGHTS

Access to and updating your personal data

You have the right to access information which we hold about you. If you so request, we shall provide you with a copy of your personal data which we are processing (“data subject access request”). We may refuse to comply with a subject access request if the request is manifestly unfounded or excessive or repetitive in nature.

You may also have the right to receive personal data which you have provided to us in a structured and commonly used format so that it can be transferred to another data controller (“data portability”). The right to data portability only applies where your personal data is processed by us with your consent or for the performance of a contract and when processing is carried out by automated means.

We want to make sure that your personal data is accurate and up to date. You have the right to have inaccurate personal data rectified, or completed if it is incomplete. You can update your details or change your privacy preferences by contacting us as provided in “Getting in touch” above. We may refuse to comply with a request for rectification if the request is manifestly unfounded or excessive or repetitive.

Right to object

Direct marketing: You have the right to object at any time to our processing of your personal data for direct marketing purposes.
Where we process your information based on our legitimate interests: You also have the right to object, on grounds relating to your particular situation, at any time to processing of your personal data which is based on our legitimate interests. Where you object on this ground, we shall no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.

Your other rights

You also have the following rights under data protection laws to request that we rectify your personal data which is inaccurate or incomplete.
In certain circumstances, you have the right to:
• request the erasure of your personal data erasure (“right to be forgotten”);
• restrict the processing of your personal data to processing in certain circumstances.
Please note that the above rights are not absolute and we may be entitled to refuse requests, wholly or partly, where exceptions under the applicable law apply. We may refuse a request for erasure, for example, where the processing is necessary to comply with a legal obligation or necessary for the establishment, exercise or defence of legal claims. We may refuse to comply with a request for restriction if the request is manifestly unfounded or excessive or repetitive in nature.

EXERCISING YOUR RIGHTS

You can exercise any of your rights as described in this Privacy Policy and under data protection laws by contacting us as provided in “Contacting us” above.

Except as described in this Privacy Policy or provided under data protection laws, there is no charge for the exercise of your legal rights. However, if your requests are manifestly unfounded or excessive, in particular because of their repetitive character, we may either: (a) charge a reasonable fee taking into account the administrative costs of providing the information or taking the action requested; or (b) refuse to act on the request.
Where we have reasonable doubts concerning the identity of the person making the request, we may request additional information necessary to confirm your identity.

COOKIES

If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.

If you have an account and you log in to this site, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.

When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.

If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.

LINKS & EMBEDDED CONTENT

Our website may, from time to time, contain links to and from third-party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and TGL does not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website. These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracing your interaction with the embedded content if you have an account and are logged in to that website.

EMAIL MONITORING

Whilst every member of the Transcend team has a personal private email address, email which you send to us or which we send to you may be monitored by Transcend Group to ensure compliance with professional standards and our internal compliance policies. Monitoring is not continuous or routine, but may be undertaken on the instruction of a director where there are reasonable grounds for doing so. Occasional spot checks or audits may also be undertaken on the instruction or with the authority of a director.

COMPLAINTS

If you have any questions or complaints regarding our Privacy Policy or practices, please contact us as provided in “Getting in touch” above.
You have the right to make a complaint at any time with a supervisory authority, in particular in the EU (or EEA) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is ICO who can be contacted at https://ico.org.uk or telephone on 0303 123 1113.

CHANGES TO OUR PRIVACY POLICY

From time to time, we may change this Privacy Policy. The current version of this Policy will always be available from us in hard copy or on our website. We will post a prominent notice on our website to notify you of any significant changes to this Policy or update you by other appropriate means.

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