Privacy Policy - Albany Associates

ALBANY PRIVACY NOTICE

At Albany we are committed to protecting and respecting your rights to privacy.

Albany Associates International Limited (Albany) (company number 05256920) whose registered office is at 5-7 Tanner Street Tanner Street, London, England, SE1 3LE is registered with the Information Commissioner’s Office as a data controller. Any questions you have in relation to this policy and how we use your data should be sent to dpo@albanyassociates.com or sent to the Data Protection Officer, Tintagel House, 92 Albert Embankment, London, SE1 7TY.
This notice sets out the basis on which any personal data (i.e. any information which identifies you, or relates to you personally) we may collect from you, or that you provide to us, will be processed by us. This document has been reviewed and updated in advance of the GDPR enforcement date of 25 May 2018.

We will never sell your personal data, and will only ever share it with organisations we work with where necessary and if its privacy and security are guaranteed.

INFORMATION WE COLLECT FROM YOU

We collect the following information directly from you to enable us to provide you with the requested services, to inform you of the services we can provide, and to honour any contractual obligations we have to you:
• Your full name and your job title; and,
• Your contact details, including your e-mail address(es), telephone number and the name of your company or organisation, where applicable.

We may also collect and process the following data about you:
• If you contact us, we may keep a record of that correspondence;
• Details of your interests and preferences; and,
• Details of your visits to our website including, but not limited to, traffic data, location data, weblogs and other communication data, and the resources that you access.
• Information about your computer, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers.

The collection of your data is a requirement for the formation of a contract between you and us, namely to enable us to administer your account and to provide to you the products and services you have requested. You are not under an obligation to provide any of your personal data. However, this might result in us being unable to provide you with the requested services and/or full access to our website.
We will store your data for as long as it is required for the performance of our obligations under the contract between you and us. Should you decide to terminate your contractual agreement with us, we will delete your contact details from our distribution list within one calendar month from the date of receipt of your request to delete your data, unless specified otherwise by you. We continually review what information we hold and delete what is no longer required.
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SENSITIVE PERSONAL DATA
We do not normally collect or store sensitive personal data (such as information relating to health, beliefs and political affiliations). One exception to this is for members of our team who visit and work in higher-risk environments, where we will keep a secure record of their blood group and next-of-kin.
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USES MADE OF THE INFORMATION
We use information held about you in the following ways:
• To carry out our obligations arising from any contracts entered into between you and us, including any subscription to various communications;
• To ensure that content from our website is presented in the most effective manner for you and for your operating system;
• To notify you about changes to our service.
In addition to the above specified uses of your personal data, from time to time we would like to contact you with details of other products and services that we provide, including briefing notes on current trends and topics, updates on ‘breaking news’ and recent events, or with information regarding our new products and product updates. We might also contact you for the purposes of informing you of upcoming events that we consider might be of particular relevance to you or your business.
You can decide not to receive communications or change how we contact you at any time, either by managing your preferences via the link in one of our emails, or by emailing dpo@albanyassociates.com.
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WHERE WE STORE YOUR PERSONAL DATA
Data that we collect may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff may be engaged in provision of support services. By submitting your personal data, you agree to this transfer, storing and or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with the relevant data protection requirements and that the transfers of data are subject to appropriate safeguards including, where applicable, reliance on an adequacy decision by the European Commission, or, in the case of absence thereof, the use of relevant contractual safeguards, including the use of mechanisms prescribed by the relevant Data Protection laws such as binding corporate rules and the use of standard model clauses approved by the European Commission or the Information Commissioner’s Office, copies of which can be obtained on request by e-mailing dpo@albanyassociates.com.
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HOW WE PROTECT YOUR DATA
We use a variety of technical and physical measures to keep your data safe and to prevent unauthorised access to, or use or disclosure of your personal information.
Electronic data and databases are stored on secure computer systems and we control who has access to information (using both physical and electronic means). Our staff receive data protection training and we have a set of detailed data protection procedures which personnel are required to follow when handling personal data.
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DISCLOSURE OF YOUR INFORMATION
We will never sell your personal data. We may disclose your personal information to any member of our group to assist us in provision of the services requested by you. We may also disclose your personal information to our service providers from time to time to enable us to provide you with the requested services. In any event, any such disclosure will be in accordance with the applicable Data Protection laws using relevant safeguards to ensure that your personal data is protected at all times.
We may also disclose your personal information to third parties:

• In the event that we sell any of our business or assets or buy any other business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
• If Albany is acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets;
• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect the rights, property, or safety of Albany, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

YOUR RIGHTS
You have the right to ask us not to process your personal data for marketing purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at dpo@albanyassociates.com, or by managing your preferences via links in the emails we send to you.
In addition to the rights set out above, the GDPR provides the following rights for individuals:
• The right to be informed
• The right of access
• The right to rectification
• The right to erasure
• The right to restrict processing
• The right to data portability
• The right to object
• Rights in relation to automated decision making and profiling.

You can exercise any of the above rights at any time by contacting us at dpo@albanyassociates.com.
If you consider that our processing of your personal data breaches any of your rights under the Data Protection laws currently in force, and following our reasonable efforts to rectify any shortcomings in the way we manage your data you continue to be dissatisfied with the way your data is handled by us, you have the right to complain to the national supervisory authority. The national supervisory authority for the UK is the Information Commissioner’s Office. For further information on how the Information Commissioner’s Office can assist you, please visit their website which can be accessed by following this link https://ico.org.uk/.