ACTINUM Limited Privacy Statement
Last update: 2022-01-11 @ 16:59
*) Date and time in the United Kingdom.
- Who we are
- Companies and websites within scope
- Collection of personal data
- Lawful bases for the processing of personal data
- Storage of personal data
- Security measures
- Your rights as a data subject
Thank You for the trust you place in us when sharing your personal data. The security of that data is very important to us. This document explains how we collect, use and protect your personal data.
We also explain what rights you have with regards to your personal data and how you can exercise those rights.
Who we are
ACTINUM Limited is the data controller and determines what data is collected, how this data is going to be used and how this data is protected.
Our registered office address is:
c/o Intouch Accounting,
ACTINUM Limited is registered in England & Wales, company number 10589083.
ICO Registration number: ZA316096
If you have questions about how we process personal data, or would like to exercise your data subject rights, please contact us via our contact page or by emailing info [at] actinum [dot] co [dot] uk.
Companies and websites within scope
The following companies and websites are within scope for this privacy statement:
Unless specifically stated, we consider our websites to be UK based websites; see section “Storage” for more information on non-EU data processing.
This privacy statement covers personal data that is collected through our websites, by telephone, by email, postal mail, through LiveChat and through any related social media applications.
Collection of personal data
Most of the personal information we process is provided to us directly by you for one of the following reasons:
- You have made an enquiry to us.
- You have signed a contract with us.
- You have made a complaint to us.
- You wish to attend, or have attended, an event.
- You subscribe to our e-newsletter.
- You have applied for a job or tender with us.
- You are representing your organisation.
We collect personal data from you for one or more of the following purposes:
- To provide you with information that you have requested or which we think may be relevant to a subject in which you have demonstrated an interest;
- To initiate and complete commercial transactions with you, or the entity that you represent, for the purchase of products and/or services;
- To fulfill a contract that we have entered into with you or with the entity that you represent;
- To ensure the security and safe operation of our websites and underlying business infrastructure, and
- To manage any communication between you and us.
The table in section “Lawful Bases” provides more detail about the data that we collect for each of these purposes, the lawful basis for doing so, and the period for which we will retain each type of data.
In addition, and in order to ensure that each visitor to any of our websites can use and navigate the site effectively, we may collect the following:
- Technical information, including the Internet Protocol (IP) address used to connect your device to the Internet;
- Your login information, browser type and version, time zone setting, browser plug-in types and versions;
- Operating system and platform;
- Information about your visit, including the Uniform Resource Locators (URL) clickstream to, through, and from our site.
In section “Your rights”, we identify your rights in respect of the personal data that we collect and describe how you can exercise those rights.
Lawful bases for the processing of personal data
The table below describes the various forms of personal data we collect and the lawful bases for processing this data. Our business architecture, accounting and systems infrastructure and compliance organisation means that all personal data is processed on common platforms. We have processes in place to make sure that only those people in our organisation who need to access your data can do so. A number of data elements are collected for multiple purposes, as the table below shows. Some data may be shared with third parties and, where this happens, this is also identified.
|Purpose of collection||Information category||Data collected||Purpose for collection||Lawful basis for processing||Data shared with?||Retention period|
|1. To provide you with information||Subject matter information||Name, company name, geographic location, email address, business sector.||To provide appropriate online or email information about services that you have requested||Contractual||Internally only||Maximum 7 years from the end-date of the performance of the contract.|
|To provide further, related, online or email information and ongoing news updates in relation to the identified area of interest.||Legitimate interest||Internally only||6 months if a marketing email is left unopened, or no response received.|
|Telephone number||Follow-up to ensure requested information meets needs and identify further requirements||Legitimate interest||Internally only||Maximum 7 years from the end of the contract date the information is collected|
|Personal contact information as provided through website forms or at trade shows or any other means.||General mailing list subscription||Consent||Internally only||Until Consent is withdrawn, or maximum 18 months after the date of last interaction, which ever is the earlier.|
|2. Transaction information||Transaction details||Name, physical address, email address, telephone number, bank account details, other medium of content delivery||To process purchase transactions for services with customers, and to ensure any transaction issues can be dealt with.||Contractual||Internally and professional advisers||Maximum 7 years from the end-date of the performance of the contract.|
|For accounting and taxation purposes||Statutory obligation||Internally and professional advisers||Maximum 7 years from the date of the performance of the contract.|
|Documentation should any contractual legal claim arise||Legitimate interest||Internally and professional advisers||Maximum 7 years from the end-date of the performance of the contract.|
|3. Fulfillment information||Fulfillment data||Name, dietary requirements||Appropriate catering arrangements for training courses||Contractual||Internally and training venues||Maximum 7 years from the date of the performance of the contract.|
|Name, contact and identification details||Access to training courses, attendance registers||Contractual||Internally and training venues|
|Name, address(es), email address, contact details||Actual delivery of products or services, in physical or digital form, that you may have purchased from us.||Contractual||Internally and any third party logistics or supplier companies with whom we contract in order to fulfil these requirements.|
|4. Security||Security information||Technical information and any other information that may be required for this purpose||To protect our websites and infrastructure from cyber attack or other threats and to report and deal with any illegal acts.||Legitimate interest||Internally, forensic and other organisations with whom we might contract for this purpose.||Relevant statutes of limitation|
|5. Communications||Contact information||Names, contact details, identification details||To communicate with you about any issue that you raise with us or which follows from an interaction between us.||Legitimate interest||Internally and, as necessary, with professional advisers.||Relevant statutes of limitation.|
Storage of personal data
ACTINUM Limited is a UK-domiciled organisation whose primary offices are in the UK.
- Our websites and web applications are hosted in the EU and are accessed only by our EU-based staff.
- Our customer relationship management, marketing and accounting systems for our business are either EU-based or hosted by companies who were participating in the (now defunct and yet to be replaced) EU – U.S. Privacy Shield Framework.
- We use a range of Cloud Service Providers (CSPs) as part of our processing environment. Unless we specifically state otherwise, we are, in respect of all these CSPs, the data controller.
- Unless we specifically state otherwise all of the CSPs that we use utilise EU-located processing facilities.
- Our payment processors and banking arrangements are based in the UK.
- We operate a data retention policy in respect of all data, whether paper-based or digital and those aspects of it which relate to personal data are contained in the table above.
We have appropriate security controls in place to protect personal data. Risk assessment, including assessing risks to the rights and freedoms of data subjects, is at the heart of our information security management approach.
We do not, however, have any control over what happens between your device and the boundary of our information infrastructure. You should be aware of the many information security risks that exist and that you should take appropriate steps to safeguard your own information.
We accept no liability in respect of breaches that occur beyond our sphere of control.
Your rights as a data subject
As a data subject whose personal information we hold, you have certain rights. If you wish to exercise any of these rights, please contact us via our contact page or by emailing info [at] actinum [dot] co [dot] uk.
In order to process your request, we will contact you and ask you to provide two valid forms of identification for verification purposes.
You are not required to pay any charge for exercising your rights. We have one month to respond to you.
We will inform you if answering requests is likely to require additional time or incurs unreasonable expense (which you may have to meet). We will explain if there are exceptional circumstances that mean we can refuse to provide the information. We reserve the right to refuse requests that are frivolous or vexatious.
Your rights are as follows:
Your right to be informed
As a data controller, we are obliged to provide clear and transparent information about our data processing activities. This is provided by this privacy statement and any related communications we may send you.
Your right of access
You have the right to ask us for copies of your personal information we hold. This right always applies. We will verify your identity and, if relevant, the authority of any third-party requester. There are some exemptions, which means you may not always receive all the information we process. You can read more about this right at the ICO.
Your right to rectification
You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete. This right always applies. You can read more about this right at the ICO.
Your right to erasure (the ‘right to be forgotten’)
You have the right to ask us to erase your personal information in certain circumstances. You can read more about this right at the ICO.
Your right to restriction of processing
You have the right to ask us to restrict the processing of your information in certain circumstances. You can read more about this right at the ICO.
Your right to object to processing
You have the right to object to our processing of your data where
- Processing is based on legitimate interest;
- Processing is for the purpose of direct marketing;
- Processing is for the purposes of scientific or historic research;
- Processing involves automated decision-making and profiling.
Your right to data portability
This only applies to information you have given us. You have the right to ask that we transfer the information you gave us from one organisation to another or give it to you. The right only applies if we are processing information based on your consent or under, or in talks about entering into a contract and the processing is automated. You can read more about this right at the ICO.
Please contact us via our contact page or by emailing info [at] actinum [dot] co [dot] uk , if you wish to make a request.
Should you wish to discuss a complaint, please feel free to contact us using the details provided above via our contact page or by emailing info [at] actinum [dot] co [dot] uk. All complaints will be treated in a confidential manner.
Should you feel unsatisfied with our handling of your data, or about any complaint that you have made to us about our handling of your data, you are entitled to escalate your complaint to a supervisory authority within the European Union. For the United Kingdom, this is the Information Commissioner’s Office (ICO), who is also our lead supervisory authority. Its contact information can be found at https://ico.org.uk/global/contact-us/.