Data & Privacy Policy

SCHEDULE 1 – C6 PRIVACY POLICY

The following text is a full statement of the privacy policy of C6 Intelligence Information Systems Limited, with registered office at 10 Queen Street Place, London, England, EC4R 1BE (company no. 05048084), (“we”, “us”, “our”). We are registered as data controllers with the Information Commissioner’s Office. Our registration number is: Z86330055.

This policy sets out the basis on which we collect data from you and/or any third parties and how we use it. Please read the following carefully to understand our views and practices regarding personal data. If you have any questions in relation to our privacy policy, please contact us by post at the above address or by email to enquiries@c6-intelligence.com.

DEFINITIONS

 The following definitions will be used throughout this document:

 

 

 

 

 

 

 

 

 

 

 

 

 

 Throughout this privacy policy: any reference to a particular law is a reference to it as it is in force for the time being, taking account of any amendment, extension, application or re-enactment and includes any subordinate legislation for the time being in force made under it; words in the singular include the plural and in the plural include the singular; and references to “including” and “include(s)” shall be deemed to mean respectively, “including without limitation” and “include(s) without limitation.

  

CUSTOMER INFORMATION

1. WHAT WE COLLECT

 We may collect and process the following data about our Customers, some of which may include Personal Data:

  1. Information provided to us by a Customer which may include the names, email addresses and the place of work of a Subscriber and/or Permitted User;
  2. . Details of a Customer’s use of our Product (including, but not limited to traffic data, location data, weblogs and other communication data) and the resources that a Customer accesses or transactions that a Customer undertakes;
  3. Any third party details submitted by a Customer to us for the purpose of receiving our Services; (“Request Details”);
  4. Any other information a Customer may provide from time to time in relation to any customer surveys provided by us;

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:

  1. To provide the Customer with the Services. This may include the provision by us of Customer Information to third party suppliers of components of the Services (“Third Party Suppliers”). We need to do this where a Third Party Supplier contractually requires the right to access, use, store, transfer and process Customer Information in order to provide their component of the Services;
  2. For the purposes of resolving any disputes which may arise in respect of the provision of our Services;
  3. To ensure that our Product is presented in the most effective manner for our Customers;
  4. For research purposes, provided that any such data will be anonymised before it is used for these purposes;
  5. To notify our Customers about changes to our Services; and
  6. To provide our Customers with information, products or services which we feel may be of interest. Where we do send out any marketing or promotional literature, we will always include the option to unsubscribe from receiving any further marketing correspondence.

 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.

 2.3. By accepting the terms of this privacy policy you are consenting to the various uses of your information described above by us. However, if you wish to withdraw your consent at any time, please notify us by emailing us at c6-intelligence.com. Please note that if you do withdraw your consent we may be unable to provide some or all of our Services to you, and you accept and acknowledge that we have no liability to you in any such event.

 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:

  1. to our employees and third parties (“data processors”) who are contracted to provide services to us to assist us in the provision of our Services. Any employees and/or data processors contracted by us will be subject to strict contractual requirements only to use your personal data in accordance with our privacy policy.
  2. In the event that we sell or buy any business or assets, in which case we may disclose Customer Information to the prospective seller or buyer of such business or assets, solely for the purpose of the sale or purchase. We will never sell Customer Information as a sole asset;
  3. If all or substantially all of our assets are acquired by a third party, in which case, personal data held by us about our Customers may be one of the transferred assets; or
  4. If we are under a duty to disclose or share Customer personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements or to protect the operation of our website, or the rights, property, or safety of us, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

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:

  1. To our employees and data processors who are contracted to provide services to us to assist us in the provision of our Services. Any employees and/or data processors contracted by us will be subject to strict contractual requirements only to use the Third Party Data in accordance with our privacy policy;
  2. In the event that we sell or buy any business or assets, in which case we may disclose the Third Party Data to the prospective seller or buyer of such business or assets, solely for the purpose of the sale or purchase;
  3. If we or substantially all of our assets are acquired by a third party, in which case, the Third Party Data may be one of the transferred assets;
  4. If we are under a duty to disclose or share the Third Party Data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements or to protect the operation of our website, or the rights, property, or safety of us, our Customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

 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.

7.2 We undertake regular security and risk reviews and we monitor all of the controls that we have in place to ensure the security, accuracy and integrity of the Personal Data we hold. We also endeavor to ensure that such data is only accessed by authorised personnel for a legitimate purpose (in accordance with our privacy policy).

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 enquiries@c6-intelligence.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.

10. CHANGES TO OUR PRIVACY POLICY

 10.01 Any changes we may make to our privacy policy in the future will be posted on our Website and, where appropriate, notified to our Customers by e-mail.

11.CONTACT

11.1 Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to enquiries@c6-intelligence.com.