ClarusONE Sourcing Services | London, UK

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TMF Group, 8th Floor, 20 Farringdon Street, London EC4A 4AB, UK

 

 

Privacy Statement

 

ClarusONE Sourcing Services LLP is the controller and responsible for your personal data (hereinafter referred to as “we”, “us” and “our”).  We respect your privacy and are committed to protecting your personal data and this privacy statement describes our current policies and practices with regard to your personal data which we collect from you directly and/or through your use of our website. 

This privacy statement applies to everyone about whom we hold personal data who is not deemed current (or former) staff, agent or contractor or someone who has applied for a job with us.

 

Personal Data We Collect About You

Personal data or personal information means any information about you from which you can be identified.  It does not include data where the identity has been removed (“Anonymous Data”).

 

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

  • Identity and Contact Data includes name, title, address, email address, telephone number and business contact information to include your role, position and/or job title within your employment, occupation and country of residence;

  • 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/device you use to access this website; and

  • Usage Data includes information about how you use our website.

 

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy statement.

 

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, 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.

How Your Personal Data Is Collected

 

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

  • Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you give us feedback or contact us.

  • 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 from the following parties:

      • analytics providers such as Google

      • search information providers such as Bing.

How Do We Use Your Personal Data?

 

We process your personal data in accordance with the provisions of the General Data Protection Regulation (EU) 2016/679 (“General Data Protection Regulations”) and other applicable data protection provisions.

 

Data will be processed only insofar as is necessary and permitted under data protection law, and we will process your personal data on one or more of the following legal grounds:

  • for the performance of a contract or in order to take steps prior to entering into a contract with you;

  • where it is necessary for the legitimate interests of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience (or those of a third party) and your interests and fundamental rights do not override those interests;

  • where we need to comply with a legal obligation that we are subject to; and

  • if you have expressly consented to the processing, (you may withdraw consent at any time, as detailed below).

 

Purposes of Data Processing 

We use your personal data in the following situations:

  • to respond to any query you have submitted;

  • to respond to any requests made by you;

  • to make this website available to you;

  • to administer and protect our business and this website (including troubleshooting, testing, system maintenance, support, reporting and hosting of data);

  • to comply with our legal and regulatory obligations and respond to requests for information from government authorities;

  • to ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution;

  • to conduct data analytics studies relating to your use of our website and to improve our website.  WIX use analytics services and therefore cookies that allow the analysis of your surfing habits. This enables WIX to improve the quality of our website. We learn how the website is used and can continually optimise our service;

  • to gather evidence and investigate any matter related to a concern or dispute; and / or

  • to exercise and/or defend our legal rights.

 

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.

Sharing Your Personal Data

Your personal data will only be shared with:

  • our staff (including external consultants), professional advisers and agents;

  • Internal departments or organisational units and other companies affiliated with us or our members on a confidential basis;

  • External third parties which process your personal data on our behalf and who are bound by contractual obligations to keep your personal data confidential and appropriately secure; and

  • Any government, regulatory agency, and law enforcement officials, if required for the purposes specified above, if mandated by law, or if required for the legal protection of our legitimate interests in compliance with applicable laws.

International Transfers

 

We may transfer the personal data we collect from you to parties based outside the European Economic Area (“EEA”) which may include countries which do not provide the same level of protection as the laws enjoyed within the EEA. We will ensure that any such international transfers are made subject to appropriate or suitable safeguards as required by the General Data Protection Regulation or other relevant laws. This includes entering into the European Commission: Model contracts for the transfer of personal data to third countries and where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.  We will be happy to provide you with the relevant, detailed information on request.

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 staff, 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.

 

Rights of Access, Correction, Erasure and Restriction

 

You are entitled, by law to the following rights:

  • Request Access to your personal data (commonly known as a "data 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;

  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it;

  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground;

  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data, for example if you want us to establish the data's accuracy;

  • Request the transfer of your personal data to you or to a third party; and

  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to process that personal information unless we have another legitimate basis for doing so.  An email is sufficient.

 

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

 

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.

 

Are You Required to Provide Personal Data?

 

In principle, you are under no obligation to provide us with personal data. However, if you do not provide us with personal data, we cannot respond to enquiries that you send to us.

 

Further Questions, Feedback or Complaints

 

If you have any questions about this privacy statement or you would like to raise a complaint or comment please contact us by emailing us at DataProtection@clarusonesourcing.com or by writing to us at: ClarusONE Sourcing Services LLP Russell Square House, 10-12 Russell Square, London, WC1B 5EH UK

 

You have the right to make a complaint at any time to the Information Commissioner's Office (“ICO”), the UK supervisory authority 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.

 

Amendments to this Privacy Statement

 

We keep our privacy statement under regular review and reserve the right to amend this privacy statement at any time. Any changes will be published on our website and shall take effect immediately. Please therefore regularly check this privacy statement to make sure you are aware of the latest version.

 

Last updated November 2018