The following definitions will be used throughout this document:
1. WHAT WE COLLECT
We may collect and process the following data about our Customers, some of which may include Personal Data:
1.2 (any of the information above, “Customer Information”).
2 USES WE MAY MAKE OF CUSTOMER INFORMATION
2.1 We use Customer Information in the following ways:
2.2. We will only ever use Request Details for the purposes of providing the Customer who submitted the request with our Services. For the avoidance of doubt, we reserve the right to retain any publicly available information within our C6 Databases whether or not such information is the same as any Request Details.
3. DISCLOSURE OF CUSTOMER INFORMATION TO THIRD PARTIES
3.1 INFORMATION DISCLOSED TO OTHER PARTIES
3.1.1 We may disclose the Customer Information to third parties for the following purposes:
THIRD PARTY DATA
4. THIRD PARTY DATA
4.1 The Third Party Data we hold may include the Personal Data of third parties, including government officials, companies, corporations and groups throughout the world.
4.2 We may hold data on third parties who fall into any of the following categories:-
1. Individuals who have been reported in news media to have been accused or have committed acts which are criminal, fraudulent or unlawful;
2. Individuals who have been reported to have been engaged in terrorist activities, and/or engaged with groups and/or associations which have been reported to have been engaged in or supported terrorist activities;
3. Companies, groups, organisations and/or associations, which are subject to national or international sanctions;
4. Individuals and their close associates who, because of their prestige or high office, might be considered ‘politically exposed’; and
5. Individuals, companies, organisations and/or associations which have or may have been suspected of engaging in illegal or fraudulent activities.
In addition to the above, we may also hold information about individuals who have gone bankrupt, companies which have become insolvent and/or have been wound up and charities.
5. HOW WE USE THE THIRD PARTY DATA
5.1 We use Third Party Data to detect and prevent unlawful activity (including fraud). We do this in a number of ways, including, by allowing Customers to search against individual names on our C6 Databases, by using Request Details to conduct searches on behalf of our Customers from time to time and/or by compiling, on behalf of our Customers, Reports. Our Customers will only be able to access the Third Party Data if Request Details they have provided us with match any names held within our C6 Databases, in which case the only Third Party Data that will be disclosed to them will relate to the matched name.
5.2 In our terms and conditions, we restrict our Customer’s ability to use any Third Party Data that we disclose to them.
5.3 We may disclose the Content to third parties other than Customers for the following purposes:
6. WHERE WE GET THE THIRD PARTY DATA FROM
6.1 We obtain Third Party Data from publicly available sources, including government sanction lists, inter-governmental sanction lists, news media, law enforcement agencies and governmental agencies.
6.2 Sometimes we get Third Party Data from sources which we have to pay, including:
1. Companies House – from which we obtain details of companies and their directors and details of individuals disqualified from acting as a director of the company;
2. The Charities Commission – from which we obtain the names and addresses of charities and their trustees
3.General Records Office – from which we obtain details of registered deaths;
4. The Stationery Office – from which we obtain details of bankruptcies.
We also access services provided by other organisations to run specific checks against named individuals. In these cases we do not obtain or store the database of details held by them.
6.3 The sources detailed in this clause 7 are only intended to be illustrative of the sources we are currently using. From time to time, we may use other similar sources in addition to those referenced above.6
6.4 WE DO NOT OBTAIN CONTENT FROM MARKETING LISTS OR OTHER SIMILAR SOURCES.
7 DATA SECURITY
7.1 It is our policy to ensure that all Personal Data held by us is handled correctly and appropriately according to the nature of the information, the risk associated with mishandling the data, including the damage that could be caused to a Data Subject and/or Customer as a result of loss, corruption and/or accidental disclosure of any such data, and in accordance with any applicable legal requirements.
7.3 We have a set of formal procedures that must be adhered to within our organisation to ensure that security standards are maintained and that data privacy is respected.
8. WHERE WE STORE PERSONAL DATA
8.1 Our Customers have offices world-wide, and we provide them with services to meet world-wide commitments. As such, we may store and send Personal Data held by us 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. Finally, Third Party Suppliers may require Personal Data to be transferred outside the EEA for identity verification checking.
8.2 Currently we have servers within the EEA and in Singapore. However, this may change from time to time.
While we will always take steps to try to ensure that any Personal Data held by us is held safely whether inside or outside the EEA, by for instance, imposing contractual restrictions on data centres, or by dealing with data centres that have met internationally recognised data security standards, it is important to note that places outside of the EEA may have laws which offer lower levels of data protection than the UK.
By submitting any Personal Data to us, you agree to this transfer, storing or processing.
9. THE RIGHTS OF DATA SUBJECTS
9.1 From time to time we may use a Customer’s Personal Data to send them information about new products which we think may be of interest. You have the right to ask us not to process Personal Data about you for marketing purposes. If you wish to withdraw your consent, please notify us by emailing us at email@example.com.
9.2 A Data Subject has the right to access the information which we hold about them. The Data Subject’s right of access can be exercised in accordance with the DPA, and the Data Subject can contact us at our registered address given above. Any access request may be subject to a fee to meet our costs in providing the Data Subject with details of the information we hold about them. We may need to request further information and identification to help us comply with any such request.
9.3 A Data Subject also has the right to ensure that we hold correct and up-to-date information. If you believe that any information we hold about you is incorrect or out of date, please contact us at our registered address. We may need to ask you for further information and identification to help us to comply with this request.
9.4 Our Website may from time to time contain links to and from the websites of our partner networks, advertisers and affiliates, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any Personal Data to these websites.