QuMind – Standard Privacy Policy

QuMind Limited (We) are committed to protecting and respecting your privacy. This policy together with our Terms of Use sets out how and why we collect, store, use and share any information relating to you (your personal data) in connection with your use of our website, QuMind.co.uk (Website) and during our business interactions with you.

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

When we collect and use your personal data we are subject to the UK General Data Protection Regulation (UK GDPR). We are also subject to the EU General Data Protection Regulation (EU GDPR) in respect of services we offer in the European Economic Area (EEA).

If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us using the details set out below.

This privacy policy relates to your use of our Website and our business interactions with you only. We have a separate privacy policy that covers our market research panels. Please contact us, using the details set out below, if you would like a copy of our market research panels privacy policy.

What is covered?

• Information we collect from you
• How is your information collected?
• Use of your information
• Cookies
• Who we share your information with
• Where we store your personal data and how we keep it safe
• Retaining and deleting your personal data
• Marketing
• Your rights
• Third Party Links
• Changes to this Privacy Policy
• How to complain
• Contact details

1. Information we collect from you

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). The personal data we collect about you depends on the particular activities carried out through our Website. We may collect, use, store and transfer different kinds of personal data about you, which we have grouped together as follows:

• Identity Data includes first name, maiden name, last name, username or similar identified.
• Contact Data includes email address, telephone numbers and address.
• Financial Data includes bank account and payment card details.
• Technical Data includes the Internet protocol (IP) address used to connect your computer to the Internet; browser type and version; time zone setting; browser plug-in types and versions and the operating system and platform.
• Usage Data includes information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our Website (including date and time), page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any name, email address or phone number used to contact us. This information is usually collected indirectly using the technologies explained in the section on Cookies below.

We also collect, use and share Aggregated Data, such as statistical or demographic data for any purpose.

Aggregated Data could be derived from your personal data, but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data, Profile Data and Technical Data to create a summarised report of browsing actions and patterns for our clients.

We do not collect any 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.

2. How is your information collected?

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:
  • apply for our services;
  • create an account on our website;
  • subscribe to our service or publications; or
  • give us feedback or contact us.
• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data and Usage Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.

3. Use of your information

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. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own.
• Where we need to comply with a legal obligation.

We have set out below, in 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. Please contact us if you need details about the specific legal ground we are relying on to process your 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 Financial	Contract
To manage our relationship with you Manage payments, fees and charges To communicate with you including to notify you about changes to our services	Identity Contact Financial	Contract Necessary for our legitimate interests for running our business
To carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us	Identity Contact	Contract Necessary for our legitimate interests for running our business
For internal use and to administer the Website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes	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)
To use data analytics to improve our website, services, customer relationships and experiences To ensure that content from our Website is presented in the most effective manner for you and for your device	Technical Usage	Necessary for our legitimate interests (to keep our website updated and relevant

4. Cookies

Our Website uses cookies to distinguish you from other users of our Website. This helps us to provide you with a good experience when you browse our Website and allows us to improve our Website.

A cookie is a small text file which will be placed onto your device when you use our Website. Generally, cookies work by assigning to your device a unique number that has no meaning outside of the Website. The cookies do not gather any personal data and we only use them to personalize and improve your experience when using our Website. To find out more about cookies by visiting: www.allaboutcookies.org/manage-cookies/.

5. Who we share your information with

We routinely share personal data with:

• third parties we use to help deliver our services to you, such as business partners, suppliers and sub-contractors;
• credit reference agencies for assessing your credit score, where this is a condition of us entering a contract with you.

We or the third parties mentioned above occasionally also share personal data with:

• our and their external auditors, e.g. in relation to the audit of our or their accounts, in which case the recipient of the information will be bound by confidentiality obligations;
• our and their professional advisers (such as lawyers and other advisers), in which case the recipient of the information will be bound by confidentiality obligations;
• law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations;
• other parties that have or may acquire control or ownership of our business (and our or their professional advisers) whether by way of sale, public offering or in the event of our insolvency – usually information will be anonymised, but this may not always be possible, but the recipient of any of your personal data will be bound by confidentiality obligations.

If you would like more information about who we share our data with and why, please contact us.

6. Where we store your personal data and how we keep it safe

The data that we collect from you will be transferred to, and stored at, a destination inside the UK or EEA. It will also be processed by staff operating inside the UK or EEA who work for us or for one of our suppliers.

We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine need to access it.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

7. Retaining and deleting your personal data

Your personal data shall not be kept for longer than we need it for the purpose for which it is used, although we may retain your personal data for longer if it is necessary for our compliance with certain legal obligations. It is therefore not possible for us to always specify in advance how long your personal data may be retained. If you would like more information about our data retention periods, please contact us.

8. Marketing

You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your personal data) if we intend to use your personal data for such purposes or if we intend to disclose your personal data to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your personal data. You can also exercise the right at any time by contacting us at [email protected].

9. Your rights

You generally have the following rights:

1. the right of access;
2. the right to rectification;
3. the right to erasure;
4. the right to restrict processing;
5. the right to data portability;
6. the right to object to use;
7. the right not to be subject to decisions without human involvement; and
8. the right to withdraw consent.

For further information on each of these rights, including the circumstances in which they do and do not apply, please contact us. You may also find it helpful to refer to the guidance issued from time to time by the UK’s Information Commissioner on your rights under the UK GDPR.

If you would like to exercise any of the above rights, please contact us.

10. Third Party Links

Our Website may, from time to time, contain links to the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, any personal data that you submit on those websites will be processed in accordance with our partner networks, advertisers and affiliates’ own privacy policies and will not be subject to this privacy policy. Please therefore check these policies before you submit any personal data to these websites. We do not accept any responsibility for any personal data that you may submit to websites linked from our Website.

11. Changes to this Privacy Policy

We may change this privacy policy from time to time. Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.

12. How to complain

Please contact us if you have any queries or concerns about our use of your personal data. We hope we will be able to resolve any issues you may have.

You also have the right to lodge a complaint with the Information Commissioner in the UK and, where appropriate, the relevant data protection supervisory authority in the EEA. The UK’s Information Commissioner may be contacted using the details at https://ico.org.uk/make-a-complaint/ or via their helpline on 0303 123 1113.

13. Contact details

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to:

[email protected]

QuMind Limited, c/o Styles & Associates, Berkeley House, Amery Street, Alton, Hampshire, England, GU34 1HN

Data Protection Act 2018 (Registration: Z461462X) Registered in England No: 03853602 VAT No: 756 7490 86



QuMind Limited, July 2023