Polygonevents.com is the website of Polygon Events Limited, registered in the United Kingdom (company number 11251562, registered address 43 Marlborough Crescent, London W4 1HG, England). Polygon Events Limited runs its business under the business names of “Polygon Events” and “Polygon Coaching”. Any reference in this policy to “Polygon Events”, “Polygon Coaching”, “we”, “us” or “our” is to Polygon Events Limited.
When you interact with us through our website (or otherwise) you may provide, or we may collect, certain information from which you are personally identifiable (which is referred to as personal data). For the purposes of the General Data Protection Regulation or “GDPR” (and all other laws relating to the use your personal data), we are the “data controller”, meaning that we are responsible for deciding how your personal data is used and more importantly, for keeping your data safe and only using it for legitimate reasons.
WHAT THIS POLICY TELLS YOU
1. What types of personal data you provide to us (or which we collect from you) when using our website or when you directly interact with us on other occasions;
2. How and why we use this data and the reasons we are legally allowed to do so;
3. Whom we share your data with; and
4. Your rights over your data and how you can exercise those rights.
WHAT INFORMATION DO WE COLLECT AND WHAT DO WE USE IT FOR?
We collect information from you as part of our business acceptance processes and about you and others as necessary in the course of providing consultancy services. You may also provide us with the following types of personal information when you become a client of Polygon Events, Polygon Coaching or otherwise when you directly interact with us (when using our website or otherwise):
· Identity - first name (including prefix or title), surname, the company you work for, your title or position;
· Contact – email address, telephone numbers and postal address;
· Financial – all payment related information including background information provided by you or collected as part of our business acceptance processes;
· Personal Information – provided to us by or on behalf of our clients or applicants, or generated by use in the course of providing services to our clients, which may include special categories of data;
· Technical – information in relation to materials and communications we send to you electronically;
· Marketing – contact information to send you newsletters, publications and invitations; and
· Any other information relating to you which you may provide to us (this may include information provided to us for the purposes of attending meetings and events).
The table below sets out how we use your personal data and our lawful basis for doing so. We may process your personal data for more than one lawful basis depending on the specific purpose for which we are using it. Importantly, we will only use your personal data when the law allows us to.
Use of Polygon Events website
The ‘Contact’ section of our website invites you to provide us with personal information through our email queries facility. The purpose of this facility is apparent at the point that you provide your personal information and we only use that information for those purposes.
Marketing and other emails
If you receive marketing communications from us and no longer wish to do so, you can opt-out at any time either by contacting us or by using the opt-out function detailed in the relevant marketing email. Please note that we may still need to send you service notifications by email, such as advising you of updated privacy terms or terms of business.
Meetings, events and seminars
We will collect and process personal data about you in relation to your attendance at our offices or at an event or seminar organised by Polygon Events, Polygon Coaching or its business partners. We will only process and use special categories of personal information about your dietary or access requirements in order to cater for your needs and to meet any other legal or regulatory obligations we may have. We may share your information with service providers or business partners involved in organising or hosting the relevant event.
WHO DO WE SHARE YOUR DATA WITH?
We do not pass your personal data onto any third parties for them to market their products/services to you. If in the future we decide that we want to, we will only do so if we have your consent.
We may also share your personal information with certain trusted third parties in accordance with contractual arrangements in place with them, including:
· our professional advisers and auditors;
· suppliers to whom we outsource certain support services such as translation, photocopying and document review;
· IT service providers;
· third parties engaged in the course of the services we provide to clients and with their prior consent; and
· third parties involved in hosting or organising events or seminars.
Where necessary, or for the reasons set out in this policy, personal data may also be shared with regulatory authorities, courts, tribunals, government agencies and law enforcement agencies. While it is unlikely, we may be required to disclose your information to comply with legal or regulatory requirements, we will use reasonable endeavours to notify you before we do this, unless we are legally restricted from doing so.
If we share personal data with third parties, we will ensure that access is limited on a strictly need-to-know basis and is subject to suitable obligations relating to confidentiality and security.
DO WE SEND ANY OF YOUR DATA OUTSIDE OF THE EEA?
The European Economic Area or “EEA” is deemed to have good standards when it comes to data privacy. As such, we consciously limit the occasions when we may need to transfer or handle your data outside of the EEA. Where we do, for example where our service providers are based outside of the EEA, we make sure that your data is still treated fairly and lawfully in all respects (including making sure we have a legal ground for sending your data outside the EEA and putting in place all necessary safeguards for such arrangement).
Where relevant, you will have the right to see a copy of any safeguards we put in place for international transfers of your data. Just get in touch with us if you would like to find out more.
HOW WE KEEP YOUR DATA SECURE?
We ensure your data is kept safe and secure and to prevent unauthorised access or use or loss of your data. We also make sure that third parties who need to handle your data when helping us to deliver our services are subject to suitable confidentiality and security standards.
Despite the security measures we implement, please be aware that the transmission of data via the internet is not completely secure. As such, we cannot guarantee that information transmitted to us via the internet will be completely secure and any transmission is at your own risk.
HOW LONG DO WE KEEP YOUR DATA FOR?
We will keep your data for as long as you are a Polygon Events/Polygon Coaching client and/or where you are still happy to hear from us about our latest news, events and services. Once you no longer wish to be engaged with Polygon Events/Polygon Coaching we may still need to keep hold of your data based on the requirements of applicable data protection laws and the purpose for which the information is collected and used, taking into account legal and regulatory requirements to retain the information for a minimum period, limitation periods for taking legal action, good practice and Polygon Events’/Polygon Coaching’s business purposes.
In certain situations, you are entitled to:
· access a copy of your personal data;
· correct or update your personal data, which you can do by contacting us and informing us of any changes;
· erase your personal data;
· object to the processing of your personal data where we are relying on a legitimate interest (as set out in the above table);
· restrict the processing of your personal data;
· request the transfer of your personal data to a third party; or
· where you have provided your consent to certain of our processing activities, in certain circumstances, you may withdraw your consent at any time.
Your objection (or withdrawal of any previously given consent) could mean that we are unable to perform the actions necessary to achieve the purposes set out above (see ‘WHAT INFORMATION DO WE COLLECT AND WHAT DO WE USE IT FOR?’) or that you may not be able to make use of the services offered by us. Please note that even after you have chosen to withdraw your consent, we may be able to continue to process your personal information to the extent required or otherwise permitted by law, in particular in connection with exercising and defending our legal rights or meeting our legal and regulatory obligations.
If you want to exercise any of these rights, please contact us. The good news is that you don’t have to pay a fee to exercise your rights, unless your request is clearly unfounded, repetitive or excessive (in which case we can charge a reasonable fee). Alternatively, we may refuse to comply with your request in these circumstances. Where your request is legitimate, we will always respond within one month (unless there is a legal reason to take longer, such as where your request is particularly complex). We may also need you to confirm your identify before we proceed with your request if it is not clear to us who is making the request.
In addition to the above, you may get in touch with the ICO (Information Commissioner’s Office) if you are concerned about the way in which we are handling your personal data. However, where possible, we would really appreciate you speaking with us first if you have any concerns.
If you would like to discuss anything in this policy or if you want to exercise your rights, please get in touch with Alastair Ruxton at: Polygon Events Limited, 43 Marlborough Crescent, London W4 1HG, United Kingdom (and email is firstname.lastname@example.org).
22 March 2019