SPARQ

Welcome to the privacy notice of SPARQ TECH LTD (The Company). The Company (collectively referred to as "we", "us" or "our" in this privacy notice) respects your privacy and is committed to protecting your personal data. This privacy notice informs you how we look after your personal data when you visit our website (regardless of where you visit it from) and tells you about your privacy rights and how the law protects you. This privacy policy is in a layered format so that you can click through to the specific areas below. We have also included a Glossary at the end of this document to help you to understand the meaning of some of the terms used in this privacy notice.

Restrictions and responsibilities

1.1

Purpose of this privacy notice

This privacy notice confirms how The Company collects and processes your personal data through your use of the following services (Website):
1. Bot building and management portal;
2. Web application for advisory firm team members to interact with the bot;
3. Web application for end clients to interact with the bot using the advisory firm custom domain and branding.
4. Web application for managing system configuration;
5. Identity Provider - web application for managing identities and authentication.
These websites are not intended for children.
It is important that you read this privacy notice together with any other privacy notice, fair processing notice or terms of use we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements any other related notices and is not intended to override them.
We may make changes to this privacy notice from time to time and will publish any new version on our website.

1.1

Purpose of this privacy notice

This privacy notice confirms how The Company collects and processes your personal data through your use of the following services (Website):
1. Bot building and management portal;
2. Web application for advisory firm team members to interact with the bot;
3. Web application for end clients to interact with the bot using the advisory firm custom domain and branding.
4. Web application for managing system configuration;
5. Identity Provider - web application for managing identities and authentication.
These websites are not intended for children.
It is important that you read this privacy notice together with any other privacy notice, fair processing notice or terms of use we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements any other related notices and is not intended to override them.
We may make changes to this privacy notice from time to time and will publish any new version on our website.

1.1

Purpose of this privacy notice

This privacy notice confirms how The Company collects and processes your personal data through your use of the following services (Website):
1. Bot building and management portal;
2. Web application for advisory firm team members to interact with the bot;
3. Web application for end clients to interact with the bot using the advisory firm custom domain and branding.
4. Web application for managing system configuration;
5. Identity Provider - web application for managing identities and authentication.
These websites are not intended for children.
It is important that you read this privacy notice together with any other privacy notice, fair processing notice or terms of use we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements any other related notices and is not intended to override them.
We may make changes to this privacy notice from time to time and will publish any new version on our website.

1.1

Purpose of this privacy notice

This privacy notice confirms how The Company collects and processes your personal data through your use of the following services (Website):
1. Bot building and management portal;
2. Web application for advisory firm team members to interact with the bot;
3. Web application for end clients to interact with the bot using the advisory firm custom domain and branding.
4. Web application for managing system configuration;
5. Identity Provider - web application for managing identities and authentication.
These websites are not intended for children.
It is important that you read this privacy notice together with any other privacy notice, fair processing notice or terms of use we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements any other related notices and is not intended to override them.
We may make changes to this privacy notice from time to time and will publish any new version on our website.

1.2

Controller

The Company is the controller and responsible for the personal data of its Customers.
Information on the dedicated Web application for end clients provided under the Customer subdomain name and Web application for advisory firm, where The Company acts as a processor and not as controller, is set out below.

1.2

Controller

The Company is the controller and responsible for the personal data of its Customers.
Information on the dedicated Web application for end clients provided under the Customer subdomain name and Web application for advisory firm, where The Company acts as a processor and not as controller, is set out below.

1.2

Controller

The Company is the controller and responsible for the personal data of its Customers.
Information on the dedicated Web application for end clients provided under the Customer subdomain name and Web application for advisory firm, where The Company acts as a processor and not as controller, is set out below.

1.2

Controller

The Company is the controller and responsible for the personal data of its Customers.
Information on the dedicated Web application for end clients provided under the Customer subdomain name and Web application for advisory firm, where The Company acts as a processor and not as controller, is set out below.

1.3

Processor

The Company is the processor in respect of personal data provided by clients of its Customers who provide information to the robots on the dedicated, white labelled Web application for end clients or personal data of Customers clients provided by Customers staff via the Web application for advisory firm.

1.3

Processor

The Company is the processor in respect of personal data provided by clients of its Customers who provide information to the robots on the dedicated, white labelled Web application for end clients or personal data of Customers clients provided by Customers staff via the Web application for advisory firm.

1.3

Processor

The Company is the processor in respect of personal data provided by clients of its Customers who provide information to the robots on the dedicated, white labelled Web application for end clients or personal data of Customers clients provided by Customers staff via the Web application for advisory firm.

1.3

Processor

The Company is the processor in respect of personal data provided by clients of its Customers who provide information to the robots on the dedicated, white labelled Web application for end clients or personal data of Customers clients provided by Customers staff via the Web application for advisory firm.

1.4

Contact details

Customer hereby undertakes

1.4

Contact details

Customer hereby undertakes

1.4

Contact details

Customer hereby undertakes

1.4

Contact details

Customer hereby undertakes

1.5

Changes to the privacy notice and your duty to inform us of changes

We keep our privacy policy under regular review. Historic versions can be obtained by contacting us.
It is essential that the personal data we hold about Customers is accurate and current. Customers should keep us informed of any changes to the personal data supplied to us.

1.5

Changes to the privacy notice and your duty to inform us of changes

We keep our privacy policy under regular review. Historic versions can be obtained by contacting us.
It is essential that the personal data we hold about Customers is accurate and current. Customers should keep us informed of any changes to the personal data supplied to us.

1.5

Changes to the privacy notice and your duty to inform us of changes

We keep our privacy policy under regular review. Historic versions can be obtained by contacting us.
It is essential that the personal data we hold about Customers is accurate and current. Customers should keep us informed of any changes to the personal data supplied to us.

1.5

Changes to the privacy notice and your duty to inform us of changes

We keep our privacy policy under regular review. Historic versions can be obtained by contacting us.
It is essential that the personal data we hold about Customers is accurate and current. Customers should keep us informed of any changes to the personal data supplied to us.

1.6

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 notice of every website you visit.

1.6

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 notice of every website you visit.

1.6

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 notice of every website you visit.

1.6

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 notice of every website you visit.

The data we collect about you

2.1

Data Processor Function

This is relevant to clients of The Company's Customers.
Your adviser, as a Customer, may ask you to provide data about yourself on their dedicated Clients' Web Workspace, provided under their subdomain name. The Company acts as a data processor for this data which is controlled by your adviser.
When acting as a data processor, The Company will process personal data in accordance with the terms and conditions agreed with its Customers and your adviser is required to have arranged for the collection of that personal data in accordance with its own privacy policy. You need to check your adviser's own privacy policy to ensure that you understand how your personal data may be processed.
The lawful basis of processing any such data, to the extent that we do so, will be either or all of
1. explicit consent,
2. for the purposes of advising on, arranging or administering an insurance contract and
3. for the establishment, exercise or defence of legal claims.
We may process Special Categories of Personal Data in respect of such information; this includes information about your health and, to the extent that you decide to include such information in the free text box, details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, and genetic and biometric data. To the extent of and where we do so, the lawful basis of processing such data will be either or all of:
1. explicit consent,
2. for the purposes of advising on, arranging or administering an insurance contract and
3. for the establishment, exercise or defence of legal claims.

2.1

Data Processor Function

This is relevant to clients of The Company's Customers.
Your adviser, as a Customer, may ask you to provide data about yourself on their dedicated Clients' Web Workspace, provided under their subdomain name. The Company acts as a data processor for this data which is controlled by your adviser.
When acting as a data processor, The Company will process personal data in accordance with the terms and conditions agreed with its Customers and your adviser is required to have arranged for the collection of that personal data in accordance with its own privacy policy. You need to check your adviser's own privacy policy to ensure that you understand how your personal data may be processed.
The lawful basis of processing any such data, to the extent that we do so, will be either or all of
1. explicit consent,
2. for the purposes of advising on, arranging or administering an insurance contract and
3. for the establishment, exercise or defence of legal claims.
We may process Special Categories of Personal Data in respect of such information; this includes information about your health and, to the extent that you decide to include such information in the free text box, details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, and genetic and biometric data. To the extent of and where we do so, the lawful basis of processing such data will be either or all of:
1. explicit consent,
2. for the purposes of advising on, arranging or administering an insurance contract and
3. for the establishment, exercise or defence of legal claims.

2.1

Data Processor Function

This is relevant to clients of The Company's Customers.
Your adviser, as a Customer, may ask you to provide data about yourself on their dedicated Clients' Web Workspace, provided under their subdomain name. The Company acts as a data processor for this data which is controlled by your adviser.
When acting as a data processor, The Company will process personal data in accordance with the terms and conditions agreed with its Customers and your adviser is required to have arranged for the collection of that personal data in accordance with its own privacy policy. You need to check your adviser's own privacy policy to ensure that you understand how your personal data may be processed.
The lawful basis of processing any such data, to the extent that we do so, will be either or all of
1. explicit consent,
2. for the purposes of advising on, arranging or administering an insurance contract and
3. for the establishment, exercise or defence of legal claims.
We may process Special Categories of Personal Data in respect of such information; this includes information about your health and, to the extent that you decide to include such information in the free text box, details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, and genetic and biometric data. To the extent of and where we do so, the lawful basis of processing such data will be either or all of:
1. explicit consent,
2. for the purposes of advising on, arranging or administering an insurance contract and
3. for the establishment, exercise or defence of legal claims.

2.1

Data Processor Function

This is relevant to clients of The Company's Customers.
Your adviser, as a Customer, may ask you to provide data about yourself on their dedicated Clients' Web Workspace, provided under their subdomain name. The Company acts as a data processor for this data which is controlled by your adviser.
When acting as a data processor, The Company will process personal data in accordance with the terms and conditions agreed with its Customers and your adviser is required to have arranged for the collection of that personal data in accordance with its own privacy policy. You need to check your adviser's own privacy policy to ensure that you understand how your personal data may be processed.
The lawful basis of processing any such data, to the extent that we do so, will be either or all of
1. explicit consent,
2. for the purposes of advising on, arranging or administering an insurance contract and
3. for the establishment, exercise or defence of legal claims.
We may process Special Categories of Personal Data in respect of such information; this includes information about your health and, to the extent that you decide to include such information in the free text box, details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, and genetic and biometric data. To the extent of and where we do so, the lawful basis of processing such data will be either or all of:
1. explicit consent,
2. for the purposes of advising on, arranging or administering an insurance contract and
3. for the establishment, exercise or defence of legal claims.

2.2

Controller Function

Personal data, or personal information, means any information about an individual from which that person 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 as follows:
1. Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
2. Contact Data includes billing address, delivery address, email address and telephone numbers.
3. Financial Data includes financial transactions.
4. Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
5. 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, screen resolution, and other technology on the devices you use to access this website.
6. Profile Data includes your username and password, purchases or orders made by you, your preferences, feedback and survey responses.
7. Usage Data includes information about how you use our website, products and services.
8. Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does 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.
We will not collect Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, 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. If we need to collect any Special Categories of Personal Data about you, we will first obtain your consent for this.
We may, however, process Special Categories of Personal Data about your clients as explained in the section above "Data Processor Function".
If you provide any personal information on behalf of someone else, you must have their consent to use their personal information.
If you fail to provide personal data
1. Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

2.2

Controller Function

Personal data, or personal information, means any information about an individual from which that person 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 as follows:
1. Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
2. Contact Data includes billing address, delivery address, email address and telephone numbers.
3. Financial Data includes financial transactions.
4. Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
5. 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, screen resolution, and other technology on the devices you use to access this website.
6. Profile Data includes your username and password, purchases or orders made by you, your preferences, feedback and survey responses.
7. Usage Data includes information about how you use our website, products and services.
8. Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does 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.
We will not collect Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, 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. If we need to collect any Special Categories of Personal Data about you, we will first obtain your consent for this.
We may, however, process Special Categories of Personal Data about your clients as explained in the section above "Data Processor Function".
If you provide any personal information on behalf of someone else, you must have their consent to use their personal information.
If you fail to provide personal data
1. Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

2.2

Controller Function

Personal data, or personal information, means any information about an individual from which that person 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 as follows:
1. Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
2. Contact Data includes billing address, delivery address, email address and telephone numbers.
3. Financial Data includes financial transactions.
4. Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
5. 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, screen resolution, and other technology on the devices you use to access this website.
6. Profile Data includes your username and password, purchases or orders made by you, your preferences, feedback and survey responses.
7. Usage Data includes information about how you use our website, products and services.
8. Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does 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.
We will not collect Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, 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. If we need to collect any Special Categories of Personal Data about you, we will first obtain your consent for this.
We may, however, process Special Categories of Personal Data about your clients as explained in the section above "Data Processor Function".
If you provide any personal information on behalf of someone else, you must have their consent to use their personal information.
If you fail to provide personal data
1. Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

2.2

Controller Function

Personal data, or personal information, means any information about an individual from which that person 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 as follows:
1. Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
2. Contact Data includes billing address, delivery address, email address and telephone numbers.
3. Financial Data includes financial transactions.
4. Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
5. 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, screen resolution, and other technology on the devices you use to access this website.
6. Profile Data includes your username and password, purchases or orders made by you, your preferences, feedback and survey responses.
7. Usage Data includes information about how you use our website, products and services.
8. Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does 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.
We will not collect Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, 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. If we need to collect any Special Categories of Personal Data about you, we will first obtain your consent for this.
We may, however, process Special Categories of Personal Data about your clients as explained in the section above "Data Processor Function".
If you provide any personal information on behalf of someone else, you must have their consent to use their personal information.
If you fail to provide personal data
1. Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

How is your personal data collected?

3.1

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

Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
1. apply for our products or services;
2. create an account on our website;
3. subscribe to our service or publications;
4. request marketing to be sent to you;
5. enter a promotion or survey; or
6. give us some feedback.
Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.
Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
1. Technical Data from the following parties:
  1. analytics providers such as Google and MailChimp based outside the EU; and
  2. search information providers such as Google, Bing or Yahoo based outside the EU.
2. Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
3. Identity and Contact Data from data brokers or aggregators based inside the EU.
4. Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.

3.1

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

Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
1. apply for our products or services;
2. create an account on our website;
3. subscribe to our service or publications;
4. request marketing to be sent to you;
5. enter a promotion or survey; or
6. give us some feedback.
Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.
Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
1. Technical Data from the following parties:
  1. analytics providers such as Google and MailChimp based outside the EU; and
  2. search information providers such as Google, Bing or Yahoo based outside the EU.
2. Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
3. Identity and Contact Data from data brokers or aggregators based inside the EU.
4. Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.

3.1

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

Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
1. apply for our products or services;
2. create an account on our website;
3. subscribe to our service or publications;
4. request marketing to be sent to you;
5. enter a promotion or survey; or
6. give us some feedback.
Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.
Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
1. Technical Data from the following parties:
  1. analytics providers such as Google and MailChimp based outside the EU; and
  2. search information providers such as Google, Bing or Yahoo based outside the EU.
2. Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
3. Identity and Contact Data from data brokers or aggregators based inside the EU.
4. Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.

3.1

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

Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
1. apply for our products or services;
2. create an account on our website;
3. subscribe to our service or publications;
4. request marketing to be sent to you;
5. enter a promotion or survey; or
6. give us some feedback.
Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.
Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
1. Technical Data from the following parties:
  1. analytics providers such as Google and MailChimp based outside the EU; and
  2. search information providers such as Google, Bing or Yahoo based outside the EU.
2. Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
3. Identity and Contact Data from data brokers or aggregators based inside the EU.
4. Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.

How we use your personal data

4.1

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Where we need to perform the contract we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests (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 or regulatory obligation.

4.1

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Where we need to perform the contract we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests (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 or regulatory obligation.

4.1

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Where we need to perform the contract we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests (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 or regulatory obligation.

4.1

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Where we need to perform the contract we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests (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 or regulatory obligation.

4.2

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third-party direct marketing communications to you via email or text message.

4.2

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third-party direct marketing communications to you via email or text message.

4.2

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third-party direct marketing communications to you via email or text message.

4.2

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third-party direct marketing communications to you via email or text message.

4.3

You have the right to withdraw consent to marketing at any time by contacting us.

4.3

You have the right to withdraw consent to marketing at any time by contacting us.

4.3

You have the right to withdraw consent to marketing at any time by contacting us.

4.3

You have the right to withdraw consent to marketing at any time by contacting us.

4.4

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we use your data. Please contact us if you need details about the specific legal ground we rely on to process your personal data where more than one ground has been set out in the table below

4.4

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we use your data. Please contact us if you need details about the specific legal ground we rely on to process your personal data where more than one ground has been set out in the table below

4.4

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we use your data. Please contact us if you need details about the specific legal ground we rely on to process your personal data where more than one ground has been set out in the table below

4.4

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we use your data. Please contact us if you need details about the specific legal ground we rely on to process your personal data where more than one ground has been set out in the table below

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To register you as a new customer

Identity
Contact

Performance of a contract with you

To process and deliver your service/order including:

Manage payments, fees and charges
Collect and recover money owed to us

Identity
Contact
Financial
Transaction
Marketing Communications

and

Performance of a contract with you
Necessary for our legitimate interests

(to recover debts due to us)

To manage our relationship with you which will include:

Notifying you about changes to our terms or privacy policy
Asking you to leave a review or take a survey

Identity
Contact
Profile
Marketing Communications

and

Performance of a contract with you
Necessary to comply with a legal obligation
Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To enable you to partake in a prize draw or complete a survey

Identity
Contact
Profile
Usage
Marketing Communications

and

Performance of a contract with you
Necessary for our legitimate interests

(to study how customers use our products/services, to develop them and grow our business)

To administer and protect our business and this website

(including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

Identity
Contact
Technical

Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

Identity
Contact
Profile
Usage
Marketing Communications
Technical

and

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

Technical
Usage

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

To make suggestions and recommendations to you about goods or services that may be of interest to you

Identity
Contact
Technical
Usage
Profile

Necessary for our legitimate interests (to develop our products/services and grow our business)

4.5

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

4.5

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

4.5

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

4.5

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

4.6

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased from us or if you provided us with your details when you registered for a promotion and, in each case, you have not opted out of receiving that marketing.

4.6

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased from us or if you provided us with your details when you registered for a promotion and, in each case, you have not opted out of receiving that marketing.

4.6

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased from us or if you provided us with your details when you registered for a promotion and, in each case, you have not opted out of receiving that marketing.

4.6

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased from us or if you provided us with your details when you registered for a promotion and, in each case, you have not opted out of receiving that marketing.

4.7

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third-party company for marketing purposes.

4.7

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third-party company for marketing purposes.

4.7

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third-party company for marketing purposes.

4.7

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third-party company for marketing purposes.

4.8

OPTING OUT

You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing messages sent to you or by contacting us at any time.
Where you opt-out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.

4.8

OPTING OUT

You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing messages sent to you or by contacting us at any time.
Where you opt-out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.

4.8

OPTING OUT

You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing messages sent to you or by contacting us at any time.
Where you opt-out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.

4.8

OPTING OUT

You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing messages sent to you or by contacting us at any time.
Where you opt-out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.

4.9

You can set your browser to refuse all or some browser cookies or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.

4.9

You can set your browser to refuse all or some browser cookies or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.

4.9

You can set your browser to refuse all or some browser cookies or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.

4.9

You can set your browser to refuse all or some browser cookies or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.

4.10

Change of purpose

We will only use your personal data for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you, and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

4.10

Change of purpose

We will only use your personal data for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you, and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

4.10

Change of purpose

We will only use your personal data for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you, and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

4.10

Change of purpose

We will only use your personal data for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you, and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Disclosures of your personal data

5.1

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above with:

External Third Parties as set out in the Glossary.
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

5.1

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above with:

External Third Parties as set out in the Glossary.
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

5.1

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above with:

External Third Parties as set out in the Glossary.
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

5.1

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above with:

External Third Parties as set out in the Glossary.
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

5.2

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

5.2

International Transfers

6.1

Many of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

6.1

Many of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

6.1

Many of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

6.1

Many of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

6.2

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
Where we use certain service providers, we may use specific contracts approved by the European Commission, which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
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.

6.2

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
Where we use certain service providers, we may use specific contracts approved by the European Commission, which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
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.

6.2

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
Where we use certain service providers, we may use specific contracts approved by the European Commission, which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
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.

6.2

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
Where we use certain service providers, we may use specific contracts approved by the European Commission, which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
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.

6.3

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

6.3

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

6.3

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

6.3

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

Data Security

7.1

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 those employees, 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.

7.1

7.2

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.

7.2

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.

7.2

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.

7.2

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

8.1

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including the purposes of satisfying any legal, accounting, or reporting requirements.

8.1

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including the purposes of satisfying any legal, accounting, or reporting requirements.

8.1

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including the purposes of satisfying any legal, accounting, or reporting requirements.

8.1

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including the purposes of satisfying any legal, accounting, or reporting requirements.

8.2

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

8.2

8.3

Details of retention periods for different aspects of your personal data are available on request from us.

8.3

Details of retention periods for different aspects of your personal data are available on request from us.

8.3

Details of retention periods for different aspects of your personal data are available on request from us.

8.3

Details of retention periods for different aspects of your personal data are available on request from us.

8.4

In some circumstances, you can ask us to delete your data: see the Request erasure section below for further information.

8.4

In some circumstances, you can ask us to delete your data: see the Request erasure section below for further information.

8.4

In some circumstances, you can ask us to delete your data: see the Request erasure section below for further information.

8.4

In some circumstances, you can ask us to delete your data: see the Request erasure section below for further information.

8.5

In some circumstances, we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

8.5

Your legal rights

9.1

Under certain circumstances, you have rights under data protection laws in relation to your personal data, including:

Request access to your personal data.
Request correction of your personal data.
Request erasure of your personal data.
Object to processing of your personal data.
Request restriction of processing your personal data.
Request transfer of your personal data.
Right to withdraw consent.

9.1

Under certain circumstances, you have rights under data protection laws in relation to your personal data, including:

Request access to your personal data.
Request correction of your personal data.
Request erasure of your personal data.
Object to processing of your personal data.
Request restriction of processing your personal data.
Request transfer of your personal data.
Right to withdraw consent.

9.1

Under certain circumstances, you have rights under data protection laws in relation to your personal data, including:

Request access to your personal data.
Request correction of your personal data.
Request erasure of your personal data.
Object to processing of your personal data.
Request restriction of processing your personal data.
Request transfer of your personal data.
Right to withdraw consent.

9.1

Under certain circumstances, you have rights under data protection laws in relation to your personal data, including:

Request access to your personal data.
Request correction of your personal data.
Request erasure of your personal data.
Object to processing of your personal data.
Request restriction of processing your personal data.
Request transfer of your personal data.
Right to withdraw consent.

9.2

Further details about each of these rights are set out below.

9.2

Further details about each of these rights are set out below.

9.2

Further details about each of these rights are set out below.

9.2

Further details about each of these rights are set out below.

9.3

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

9.3

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

9.3

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

9.3

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

9.4

No fee usually required

This Agreement may be executed in counterparts each of which will be deemed to be an original and all of which together will be deemed to be one and the same document. This Agreement may be delivered by the exchange of signed copy by email with a PDF copy attached, and any such version of the Agreement shall have the same force and effect as an originally signed version of Agreement.

9.4

No fee usually required

9.4

No fee usually required

9.4

No fee usually required

9.5

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

9.5

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

9.5

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

9.5

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

9.6

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

9.6

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

9.6

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

9.6

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

The glossary

10.1

Website

Clients Web Workspace means the dedicated, white labelled website provided under the Customer domain name, where the Customers Clients interact with the Robots, including providing their personal data.
Web application for advisory firm means the website provided by The Company to its customers where the Customers staff is able to interact with the Robots, including providing personal data of their clients.

10.1

Website

Clients Web Workspace means the dedicated, white labelled website provided under the Customer domain name, where the Customers Clients interact with the Robots, including providing their personal data.
Web application for advisory firm means the website provided by The Company to its customers where the Customers staff is able to interact with the Robots, including providing personal data of their clients.

10.1

Website

Clients Web Workspace means the dedicated, white labelled website provided under the Customer domain name, where the Customers Clients interact with the Robots, including providing their personal data.
Web application for advisory firm means the website provided by The Company to its customers where the Customers staff is able to interact with the Robots, including providing personal data of their clients.

10.1

Website

Clients Web Workspace means the dedicated, white labelled website provided under the Customer domain name, where the Customers Clients interact with the Robots, including providing their personal data.
Web application for advisory firm means the website provided by The Company to its customers where the Customers staff is able to interact with the Robots, including providing personal data of their clients.

10.2

Lawful basis

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Complying with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Special Categories of Personal Data means personal data that needs more protection because it is sensitive.

10.2

Lawful basis

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Complying with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Special Categories of Personal Data means personal data that needs more protection because it is sensitive.

10.2

Lawful basis

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Complying with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Special Categories of Personal Data means personal data that needs more protection because it is sensitive.

10.2

Lawful basis

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Complying with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Special Categories of Personal Data means personal data that needs more protection because it is sensitive.

10.3

Third Parties

External Third Parties
1. Service providers acting as processors who provide various services, are listed here: https://trust.sparq.tech/subprocessors
2. Professional advisers, including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
3. HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.

10.3

Third Parties

External Third Parties
1. Service providers acting as processors who provide various services, are listed here: https://trust.sparq.tech/subprocessors
2. Professional advisers, including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
3. HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.

10.3

Third Parties

External Third Parties
1. Service providers acting as processors who provide various services, are listed here: https://trust.sparq.tech/subprocessors
2. Professional advisers, including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
3. HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.

10.3

Third Parties

External Third Parties
1. Service providers acting as processors who provide various services, are listed here: https://trust.sparq.tech/subprocessors
2. Professional advisers, including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
3. HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.

10.4

Your legal rights

You have the right to:
1. 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.
2. 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, though we may need to verify the accuracy of the new data you provide to us.
3. 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 to continue to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons, which will be notified to you, if applicable, at the time of your request.
4. 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object to where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
5. Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful, but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
6. Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
7. 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 provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

10.4

Your legal rights

You have the right to:
1. 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.
2. 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, though we may need to verify the accuracy of the new data you provide to us.
3. 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 to continue to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons, which will be notified to you, if applicable, at the time of your request.
4. 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object to where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
5. Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful, but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
6. Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
7. 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 provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

10.4

Your legal rights

You have the right to:
1. 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.
2. 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, though we may need to verify the accuracy of the new data you provide to us.
3. 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 to continue to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons, which will be notified to you, if applicable, at the time of your request.
4. 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object to where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
5. Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful, but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
6. Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
7. 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 provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

10.4

Your legal rights

You have the right to:
1. 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.
2. 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, though we may need to verify the accuracy of the new data you provide to us.
3. 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 to continue to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons, which will be notified to you, if applicable, at the time of your request.
4. 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object to where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
5. Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful, but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
6. Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
7. 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 provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.